SITEGROUND MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

This Modern Slavery and Human Trafficking Statement (the “Statement”) is made on behalf of SiteGround Hosting Ltd., a company registered and existing under the laws of England and Wales, registered in the Company House in the United Kingdom, with Company number 09348602, with registered address at 7th Floor 50 Broadway, London SW1H 0DB, United Kingdom (“SiteGround”, the “Company”, “we”, “us”, “our”) and has been prepared in accordance with Section 54(1) of the Modern Slavery Act 2015 (the “Act”). 

We are committed to highly respecting human rights and acting ethically and with integrity in our business activities. We have a zero tolerance approach to any form of modern slavery and human trafficking and are committed to taking appropriate action to combat modern slavery and human trafficking in our business and supply chains. We work closely with our supply chain to ensure that we meet our obligations under the Act. 

  1. STRUCTURE, BUSINESS ACTIVITIES AND SUPPLY CHAINS

SiteGround provides services in many countries worldwide, incl. the United Kingdom, Australia, Singapore, Canada, etc. 

SiteGround Hosting Ltd. is part of the SiteGround Group of companies, consisting of companies registered in the USA, UK, Spain, Bulgaria and Cyprus (the “SiteGround Group” or the “Group”). The SiteGround Group operates in the field of web hosting, software and product development. Currently the SiteGround Group offers hosting solutions trusted by the owners of appr. 3 000 000 domains worldwide. SiteGround delivers its services to a wide variety of industries and business sectors, as well as to individuals and freelancers. 

SiteGround has established and maintains contractual relationships with third-party service providers, business partners, vendors and contractors outside the SiteGround Group (the “Third Parties”) who are carefully selected to support SiteGround’s business by implementing the highest industry standards. The Third Parties provide us with the following services:

  • provision of server functionality and network connectivity services;

  • security services;

  • banking and financial services;

  • marketing and advertising services;

  • audit, accounting, insurance, consultancy and legal services, etc.

On a Group level the SiteGround Group has approximately 500 people spread across the Group offices, engaged in software development, management and maintenance, technical support and customer service, marketing, product management and development, web design, legal and finance, HR and general administration.

  1. SITEGROUND’S PROCESSES AND POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. 

SiteGround implements the following rules in order to deal with modern slavery and human trafficking:

  • SiteGround monitors and strictly opposes the use of forced, compulsory, excessive or trafficked labour, or anyone held in slavery or servitude, whether adults or children by any of the Third Parties;

  • SiteGround will not use the services of any Third Party that is suspected of or proven to be in breach of the above declaration;

  • SiteGround commits to acting ethically and with integrity in all business relationships and to implementing and enforcing effective controls to ensure that slavery and human trafficking do not occur anywhere in its supply chains.

With respect to employment - SiteGround will always ensure that every employee has the right to work in the United Kingdom and is paid above the National Living Wage. 

SiteGround also adheres to Group-level policies and procedures designed to ensure that each SiteGround company conducts its business in an ethical and responsible manner, such as the SiteGround Anti-Bribery Policy, the ESG commitments, etc.

  1. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

One of the core SiteGround principles is crafting our services, software and products in-house, within the Group, to our own high-quality standards. Оur supply chain is therefore rather limited. However, we do rely on Third Parties to support certain parts of our business operations.

Before engaging with any Third Party and where appropriate, we conduct a due diligence process to assess the potential relationship and to better identify and mitigate any risks. We take the following steps: 

  • We conduct an initial review of the Third Party's business and supply chain, where reasonably practicable, with regard to reputation and business ethics, including modern slavery policies/statements; 

  • We conduct risk assessments to evaluate any business, operational or reputational risks that may arise during our relationship with the Third Party;

  • We negotiate such contractual arrangements to ensure compliance with the applicable local laws and regulations. 

After engaging the respective Third Party, we will periodically review and/or audit our relationship to ensure that all ethical standards and anti-slavery commitments are being met. 

  1. RISK ASSESSMENT

To the date of this Statement, SiteGround has not identified any issues concerning modern slavery or human trafficking within its business or supply chains.

SiteGround has also not received any information or indication of issues with any of its Third Parties and/or their supply chains. 

Based on the above and given that our main business activities are software development and the provision of products and services online, we do not consider that our business gives rise to a high risk of modern slavery or human trafficking. 

  1. TRAINING

SiteGround provides annual training to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and business. 

  1. EFFECTIVENESS OF ANTI-SLAVERY MEASURES

We regularly review the effectiveness of our anti-slavery policies and procedures. We are committed to reviewing our measures each year and making improvements where necessary.

This Statement is made for the financial year ending 31 December 2023.

This Statement was approved on 18 September 2024 by the Board of Directors of SiteGround Capital Ltd, in the capacity as sole owner of SiteGround Hosting Ltd.