Upwork Inc.
UK Modern Slavery Act
Transparency Statement

The UK Modern Slavery Act 2015 requires that any commercial organization in any sector that supplies goods or services, carries on a business or part of a business in the United Kingdom, and is above a specified total turnover must produce a slavery and human trafficking transparency statement for each financial year of the organization. The transparency statement must include the steps the organization has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.

Upwork Inc. and its subsidiaries (“Upwork,” “we” or “our”) are opposed to all forms of human trafficking, slavery, servitude, child labor, forced or compulsory labor and all other trafficking-related activities. We are committed to (i) fully complying with all applicable labor and employment laws, rules and regulations, and (ii) working to mitigate the risk of human trafficking in our business and supply chains. This Transparency Statement is provided to comply with the UK Modern Slavery Act.

Upwork provides an online platform that enables businesses to connect with independent professionals and agencies for all their hiring and remote work needs and that enables independent professionals and agencies to market their services to prospective clients. Users of Upwork's platform, located at www.upwork.com, may only use Upwork for remote, knowledge-based work, and payments must be made through the platform.

Because Upwork is only a platform and does not supply the services that are purchased on its platform, Upwork’s supply chain consists of the supplies and services that enable the operation of the platform itself and the provision of related services to the users that transact on its platform. Upwork engages employees, leased employees, and independent contractors to perform services for Upwork. Upwork does not outsource significant operations to agencies or other entities that engage workers on behalf of Upwork without Upwork having visibility into such arrangements.

Upwork’s Code of Business Conduct and Ethics (the “Code”) requires that its employees, independent contractors, officers and directors obey the law while performing work for Upwork and comply with U.S.laws, rules and regulations governing the conduct of business by U.S. citizens and corporations outside theUnited States. The Code also contains a specific requirement that Upwork and its employees comply with all applicable environmental, health and safety laws and regulations. Upwork trains all employees and officers and certain independent contractors in Code policies as part of the onboarding process. Upwork’s Whistleblower Policy indicates that Upwork expects its employees to internally report concerns about activity that is unlawful or otherwise violates Upwork’s policies, including the Code, and provides reporting procedures for employees who wish to anonymously submit a concern or complaint regarding such matters.

The Code includes reporting procedures and provides for protection against retaliation for those making a report. If Upwork becomes aware of a violation of its policies, Upwork will reasonably investigate the matter and take appropriate action. Furthermore, if Upwork becomes aware that laws, rules or regulations have been violated, Upwork will cooperate fully with the appropriate authorities.

Upwork’s standard vendor agreements require that vendors adhere to applicable laws, rules and regulations.In addition, Upwork conducts employment-related business due diligence regarding the operations of vendors that provide staffing services prior to engagement to ensure that such vendors have appropriate employment practices in place and comply with all employment laws and regulations.

The Upwork Inc. Board of Directors has approved this Transparency Statement for the fiscal year ended December 31, 2020 and delegated authority to sign it on their behalf to the Corporate Secretary.

Date: March 3, 2021


Brian Levey
Corporate Secretary