Modern Slavery Act Statement
The United Kingdom Modern Slavery Act of 2015 and Australia Modern Slavery Act of 2018 requires certain companies to publish an annual statement disclosing the efforts taken to prevent slavery and human trafficking anywhere in their own business or their supply chain. Jamf’s Board of Directors and senior management are fully committed to sustaining a work environment and supply chain free of human trafficking and modern slavery of any kind.
Jamf Holding Corp., the standard in Apple Enterprise Management, extends the legendary Apple experience people love to businesses, schools and government organizations through its software and the largest online community of IT admins focused exclusively on Apple in the world, Jamf Nation. Headquartered in Minneapolis, Minnesota, Jamf has offices across the world including Amsterdam, Austin, Cupertino, Eau Claire, Emmen, Hong Kong, Katowice, London, New York, Sydney, Stockholm, Taipei and Tokyo. Jamf operates largely in these jurisdictions but also conducts business in a wider number of countries around the world.
Since the last statement was published, Jamf has been listed as a public company on the NASDAQ stock exchange and has been working towards becoming an industry leader in its compliance efforts.
Policies and Controls
Jamf has a zero-tolerance policy around modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships. Jamf has implemented and enforces effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our distribution channels. The Board of Directors and senior leadership are accountable for the governance and oversight of modern slavery risks. Jamf’s Risk & Compliance team is responsible for day-to-day activities and due diligence.
Risk Assessment & Due Diligence
Jamf’s Risk & Compliance team engages with internal and external stakeholders on a regular basis to understand and prioritize business risks. The team manages identification and tracking of known severe and traceable risks via a GRC platform.
Jamf considers modern slavery risk in our supply chain to be low, particularly because of the sector (SaaS mobile device management) in which we operate, the limited nature of our supply chains, and the values and policies that guide the actions of our directors, officers, employees and contractors. We source goods and services from reputable suppliers and the nature of the goods and services we do procure do not demand the types of labor at risk for slavery and human trafficking. Jamf management weighs and understands the risks associated with international expansion.
Jamf’s labor force is primarily made up of full-time employees and temporary contingent workers. All employees undergo background checks and training.
In 2021, Jamf noted that travel and entertainment purchases have significantly decreased due to the COVID-19 global pandemic, thus reducing the risk of modern slavery even further.
Jamf takes the following actions to help prevent forced labor, modern slavery, and human trafficking:
1. Partner Code of Conduct: This code sets forth the principles and ethical standards we expect our business partners to comply with throughout the course of our business relationship. Business partners include vendors, integrators, resellers, contractors, consultants and agents.
2. Code of Ethics: This code promotes honest and ethical business practices and compliance with applicable laws and regulations. All directors, officers and employees are required to be familiar with the Code, comply with its provisions and report any suspected violations.
3. Vendor Agreements:
- All vendors are subject to legal terms and conditions with Jamf.
- Assessments of potential vendors are conducted as part of our vendor onboarding process.
- Vendors deemed highest risk are audited or reviewed on a periodic basis for Modern Slavery and SOC 2 compliance. We work closely with vendors to develop corrective action plans and carry out all audit findings.
- Vendors are screened against relevant sanctions and denied parties lists which includes human trafficking violations. Jamf does not enter into contracts with organizations sanctioned by the US Government.
- Jamf conducts Code of Conduct and HR training for all employees and certified annually. Those who do not comply with requirements are subject to our Disciplinary Policy.
- Jamf provides Modern Slavery Employee Awareness Training to all employees on an annual basis.
- We expect our vendors to communicate the principles in the Partner Code to their employees and third-party partners through training, policy and other messaging.
- Jamf encourages employees to report suspicious activity via our Whistleblower Hotline.
5. Due Diligence:
- Finance, Legal, Information Security, Compliance and HR teams perform detailed reviews before entering into vendor agreements. Jamf evaluates vendor Modern Slavery compliance as part of vendor due diligence.
- High risk vendors are monitored via an industry recognized cyber security tool.
- Jamf’s Risk & Compliance team performs an analysis of existing high-risk vendor compliance with Jamf’s Modern Slavery Policy annually.
- Jamf’s Risk & Compliance team completes a review of internal policies and procedures to ensure alignment with this statement annually.
Assessment of Effectiveness
Jamf continues to monitor and develop formal processes to conduct more thorough investigations in relation to the subject matter of this statement.
As a result of the above actions, Jamf will also consider whether to implement additional electronic tools, training or other appropriate controls on an ongoing basis.
Should Jamf become aware of any policy violations or issues related to slavery or human trafficking, we will consult with our HR and Legal Departments to ensure that appropriate measures are taken, which may include reporting this information to authorities and terminating our relationship with the supplier.
This statement is applicable to all Jamf legal entities and was approved for the financial year ending December 31, 2020 by the Board of Directors on 05/25/2021. It will be reviewed and approved on an annual basis by the senior leadership and the Board of Directors.
Chief Executive Officer and Director