Modern Slavery Act Statement
Fiscal year ended December 31, 2022
Introduction and Organizational Structure
The organizational structure of Jamf (“The Company”) comprises Jamf Holdings Corp. and its twenty-eight subsidiaries located in various jurisdictions. Jamf Holdings Corp. is listed as a public company on the NASDAQ Stock Exchange under the name of JAMF. This joint statement and the measures described herein are applicable to Jamf Holdings Corp and its subsidiaries because all entities operate in the same sector, use the same policies and processes, and have many shared suppliers. Refer to the Appendix herein for a list of Jamf Holding Corp.’s subsidiaries.
Jamf is controlled by a Board of Directors. The Head Office is in Minneapolis (US) with other offices located in Amsterdam (NL), Austin (US), Brno (CZ), Cupertino (US), Eau Claire (US), Emmen (NL), Hong Kong, Katowice (PL), London (UK), New York (US), San Francisco (US), Sydney (AU), Stockholm (SE), Taipei (TW) and Tokyo (JP). Jamf operates largely in these jurisdictions but also conducts business in a wider number of countries around the world via re-sellers, managed service providers and other partners.
Jamf, being the standard in Apple Enterprise Management, is predominantly involved in providing device management and IT security solutions to businesses, schools, and government organizations through its software.
Jamf considers that modern slavery encompasses:
- Human trafficking.
- Forced work, through mental or physical threat.
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
- Being dehumanized, treated as a commodity, or being bought or sold as property.
- Being physically constrained or to have restriction placed on freedom of movement.
Jamf acknowledges its responsibilities under the Modern Slavery legislation and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. Jamf understands that this requires an ongoing review of both its internal practices in relation to its labor force and its supply chains.
Jamf has a zero-tolerance policy towards modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships. It will refrain from doing business, and/or will discontinue any current business with any other organization which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labor.
The labor supplied to Jamf in pursuance of the services it provides is carried out in the countries where those services are provided as appropriate. No labor provided to Jamf in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Jamf strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislations, and in many cases exceeds those minimums in relation to its employees.
Jamf employees are offered a competitive remuneration package. The Company conducts surveys on an anonymous basis to give employees a voice on their individual employment, their department, and the company as appropriate.
Jamf has implemented and enforces 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.
Jamf regularly assesses the risks in relation to modern slavery and human trafficking within our business and supply chain. We consider these risks to be low, particularly because of the sector (SaaS mobile device management) in which we operate, the limited nature of our supply chains (mainly distribution channels), and the values and policies that guide the actions of our directors, officers, employees, and contractors.
Jamf’s labor force is primarily made up of full-time employees and temporary contingent workers. All employees undergo background checks and training. We source goods and services from reputable suppliers and the nature of the goods and services we do procure typically 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 conducts 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. The Code includes our expectation for business partners to comply with Modern Slavery legislation. Business partners include vendors, integrators, resellers, contractors, consultants, and agents.
2. Employee Code of Conduct: This code promotes honest and ethical business practices and requests compliance with applicable laws and regulations. All directors, officers and employees are required to read and acknowledge 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 and centralized procurement function.
- Vendors deemed higher risk are monitored and reviewed periodically for Modern Slavery.
- Vendors are screened against relevant sanction and denied parties lists which includes human trafficking violations. Jamf does not enter into contracts with organizations under sanctions imposed by the UK, US, UN, EU etc.
- Jamf conducts Code of Conduct and HR training for all employees at joining and requires certification 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. In 2022, all Jamf employees completed this training.
- Temporary workers are required to acknowledge Jamf’s Code of Conduct and complete Modern Slavery Awareness Training, which prohibits modern slavery of any kind and encourages reporting of any known violations.
- 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 use of its Whistleblower Hotline available for Jamf employees to anonymously report any concerns regarding modern slavery and will investigate any complaints thoroughly. Management takes all reports seriously and performs timely investigations to determine necessary actions in line with the Jamf Whistleblowing Policy.
5. Due Diligence:
- Finance, Legal, Information Security, Compliance and HR teams perform detailed reviews before entering into vendor agreements.
- 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
To ensure effectiveness in combatting modern slavery, Jamf maintains an accurate supplier list including contact details. It will ensure action is taken in response to reports of modern slavery in its supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with the policy.
As in the previous fiscal year, Jamf has not received any reports or complaints about being involved in activities covered by the Modern Slavery Act
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 published in compliance with the United Kingdom Modern Slavery Act of 2015 and Australia Modern Slavery Act of 2018. The Board of Directors and management of Jamf are fully committed to sustaining a work environment and supply chain free of human trafficking and modern slavery of any kind.
This statement is applicable to all Jamf legal entities and was approved for the fiscal year ending December 31, 2022, by the Board of Directors on May 2nd, 2023. It will be reviewed and approved annually by senior leadership and the Board of Directors.