Modern Slavery
and Human Trafficking
Prevention Policy

HashiCorp, Inc. (collectively with its subsidiaries, “HashiCorp”) is committed to promoting high standards of honest and ethical business conduct and compliance with applicable laws, rules and regulations. As part of this commitment and support of the Modern Slavery Act of 2015, and in accordance with FAR 52.222-50, HashiCorp has adopted this Modern Slavery and Human Trafficking Prevention Policy for its employees, officers, directors and authorized independent contractors (the “Policy”). HashiCorp has no tolerance for modern slavery and human trafficking. Under the HashiCorp Whistleblower Policy, HashiCorp employees may report and escalate slavery and human trafficking issues, without fear of retaliation.

Under this Policy, in connection with their work with or for HashiCorp, HashiCorp employees and their agents shall not:

  1. Engage in any form of trafficking in persons;

  2. Procure commercial sex acts;

  3. Use forced labor;

  4. Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or drivers' licenses, regardless of issuing authority;

  5. (i) Use misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language understood by the employee or potential employee, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant costs to be charged to the employee or potential employee, and, if applicable, the hazardous nature of the work; and (ii) Use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;

  6. Charge employees or potential employees recruitment fees;

  7. (i) Fail to provide return transportation or pay for the cost of return transportation upon the end of employment: A. For an employee who is not a national of the country in which the work is taking place and who was brought into that country for the purpose of working on a U.S. Government contract or subcontract (for portions of contracts performed outside the United States); or B. For an employee who is not a United States national and who was brought into the United States for the purpose of working on a U.S. Government contract or subcontract, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee (for portions of contracts performed inside the United States); except that (ii) The requirements of this paragraph (7) shall not apply to an employee who is legally permitted to remain in the country of employment and who chooses to do so, or is exempted by an authorized official of a U.S. Government contracting agency from the requirement to provide return transportation or pay for the cost of return transportation; (iii) The requirements of this paragraph (7) are modified for a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons. HashiCorp shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity. This paragraph does not apply when the exemptions at paragraph (7)(ii) apply.

  8. Provide or arrange housing that fails to meet the host country housing and safety standards;

  9. If required by law or contract, fail to provide an employment contract, recruitment agreement, or other required work document in writing. Such written work document shall be in a language the employee understands. If the employee must relocate to perform the work, the work document shall be provided to the employee at least five days prior to the employee relocating. The employee’s work document shall include, but is not limited to, details about work description, wages, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.

Supply Chain

In addition to the foregoing, HashiCorp is committed to ensuring transparency within its global business and supply chains and that steps are taken to prevent, detect and report any form of modern slavery or human trafficking, and expects the same commitment from its contractors and suppliers. From time to time, contractors and suppliers engaged with HashiCorp may be required to complete certifications acknowledging commitment to, understanding of, and prior and ongoing compliance with this Policy. Any contractor or supplier who violates the Policy or who fails to make or falsifies any certification required under this Policy will be subject to sanctions from HashiCorp, up to and including termination of the business relationship.

In the event of a violation of this Policy by employees, actions against employees may include, but are not limited to, removal from any contract with the U.S. Government, a reduction in benefits, or termination of employment. In addition, HashiCorp shall immediately inform the appropriate governmental agency of any credible information received regarding any allegation of an employee, subcontractor or subcontractor employee, or agent that has engaged in conduct that violates this Policy.

This Policy shall be posted on our website and internal employee website and will be reviewed annually.