Modern Slavery Statement 2025

Introduction

Lusha Systems Ltd. and its affiliated companies in its groups (“Lusha” or “the Company”) has a zero-tolerance approach to modern slavery in our operations and business relationships. Modern slavery is a crime and a grave violation of fundamental human rights. It takes various forms, including servitude, forced or compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. 

Acting ethically and with integrity is at the heart of how we do business, and we have implemented effective systems and controls to ensure that modern slavery is not occurring anywhere within our organisation or in our supply chains. We emphasise transparency in our efforts to tackle modern slavery and expect the same commitment from our business partners.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015, in addition to the Universal Declaration of Human Rights, and the UN Guiding Principles on Business and Human Rights, and affirms Lusha’s commitment to combating modern slavery and human trafficking in all parts of our business and supply chains.

Our Business and Supply Chains

Lusha is a platform-as-a-service (PaaS) provider of business data solutions. We do not produce or manufacture any physical goods or parts, and we do not operate factories or industrial facilities. As a result, certain modern slavery risk factors common in manufacturing supply chains (e.g., factory labour exploitation) are not present in our business model. Our supply chain consists primarily of services and professional suppliers rather than physical goods. 

We strive to work only with reputable suppliers and partners that share our values and standards. We do not knowingly do business with any organisation involved in modern slavery or human trafficking. 

Given that most of our suppliers are in relatively low-risk sectors or jurisdictions, we assess our overall risk as lower than companies in manufacturing or raw materials industries. However, we remain vigilant and expect all our contractors, suppliers, and business partners to uphold the same high standards of human rights and labour ethics that we do. We also expect that our suppliers, in turn, hold their own supply chain to these high standards.

Lusha maintains a robust Anti-Slavery and Human Trafficking Policy reflecting our zero-tolerance stance. This policy explicitly prohibits the use of forced, compulsory or trafficked labour, slavery, or servitude of any kind. It applies to all persons working for us or on our behalf, in any capacity. This includes everyone from our full-time and part-time employees, directors, and officers to interns, contractors, consultants, third-party representatives, and partners.

We are committed to conducting all business dealings and relationships in an ethical, transparent manner, and to enforcing effective systems and controls to ensure we are not complicit in any form of modern slavery. 

In our contracting and procurement processes, we include specific clauses prohibiting the use of forced or trafficked labour and other human rights abuses, and we require suppliers to agree to these terms. We also communicate our Anti-Slavery Policy and expectations to new and existing suppliers. Our suppliers are formally informed of our zero-tolerance approach and are asked to confirm their compliance with anti-slavery standards, either through contractual commitments or by adhering to our Global Vendors Code of Conduct. 

Lusha will not hesitate to discontinue relationships with suppliers or partners who are found to be engaging in or turning a blind eye to modern slavery.

Our commitment to combating modern slavery is underpinned by broader adherence to international norms. As a company, we support and respect internationally proclaimed human rights and labour standards, including the principles of the United Nations Global Compact. We continuously work to ensure that our own operations, as well as those of our partners, reflect these values of dignity and respect for all individuals.

Risk Areas and Assessment

We recognise that no industry or supply chain is completely free from risk. While our direct business operations consist of a highly skilled professional workforce and our supply chain is primarily service-oriented, we still carefully assess potential risk areas. In particular, we consider the following as areas of higher potential risk in our context:

• Facilities Services: cleaning and catering services can carry higher vulnerability to labour exploitation. We pay special attention to their labour practices and standards;
• Technology Hardware Suppliers: while we do not manufacture products, we purchase standard office hardware and IT equipment from external suppliers, recognising risks of forced labour at raw material or manufacturing stages. We mitigate this by sourcing from reputable, responsible providers; 
• Professional Services and Contractors: in regions with higher human trafficking risks or differing labour law enforcement, we remain attentive to warning signs and perform due diligence appropriate to the risk level.

Overall, our business has not identified any specific instance of modern slavery within our operations or direct suppliers to date, and we assess the risk in our immediate business to be low. However, we understand that risk levels can shift due to changes in our supplier base or the geopolitical environment, and we therefore review our risk assessment periodically.

To prevent modern slavery and human trafficking in any part of our supply chain, Lusha has instituted several due diligence and supplier management measures:

• Supplier Screening and Onboarding: we perform risk-based due diligence on new suppliers, including questions on their labour practices and policies. High-risk suppliers may be subject to enhanced vetting; 
• Contractual Controls: supplier contracts include clauses mandating compliance with the relevant laws. Breaches are treated as material breaches allowing for contract termination;
• Vendor Code of Conduct: we maintain and communicate a Vendor Code of Conduct outlining expectations on human rights and labour standards, as set out in the UK’s Modern Slavery Act 2015; 
• Ongoing Monitoring: we adopt a continuous improvement approach to supplier due diligence and remain alert to red flags or emerging risks;

Whistleblowing and Remediation: we provide confidential reporting mechanisms for employees and suppliers to raise concerns. Reports are taken seriously, investigated, and addressed promptly.

Ultimate responsibility for our anti-slavery efforts rests with Lusha’s Board of Directors. Day-to-day implementation is delegated to senior management, led by the Legal and Compliance team, with management at all levels responsible for ensuring team adherence. 

We recognise that risks of modern slavery evolve, and we remain committed to continuous improvement in our approach. Planned steps include refining supplier onboarding questionnaires, enhancing due diligence tools, and increasing internal awareness campaigns.