Modern Slavery and Human Trafficking Statement

This statement is published by Trustpilot Group plc pursuant to section 54 (1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the slavery and human trafficking statement for the financial year 1 January 2022 to 31 December 2022 for Trustpilot Group plc and each of its subsidiaries further listed in the “Organisational structure & supply chains” section below (together the “Trustpilot Group”).

The Trustpilot Group takes a zero tolerance approach to slavery and human trafficking in our business operations and supply chains.

Business overview

Trustpilot was founded in 2007 with a vision to create an independent currency of trust.

A digital platform that brings businesses and consumers together to foster trust and inspire collaboration. We are free to use, open to everybody and built on transparency.

Trustpilot hosts reviews to help consumers shop with confidence and deliver rich insights to help businesses improve the experience they offer. The more consumers use our platform and share their own opinions, the richer the insights we offer businesses, and the more opportunities they have to earn the trust of consumers, from all around the world.

As at the date of this statement, the Trustpilot Group has over 850 employees and is headquartered in Copenhagen, with operations in London, Edinburgh, New York, Denver, Melbourne, Berlin, Vilnius, Milan and Amsterdam.

Organisational structure & supply chains

Trustpilot Group plc was incorporated on 8 February 2021 and as part of Trustpilot’s initial public offering became the ultimate parent company in the Trustpilot Group on 26 March 2021. Prior to this date the ultimate parent company in the Trustpilot Group was Trustpilot A/S, which is a limited liability company registered in Denmark.

Trustpilot Group plc is a public limited company whose shares are admitted to the premium listed segment of the Official List of the UK Financial Conduct Authority and to trading on the main market of the London Stock Exchange.

The Trustpilot Group operates globally across the UK, EMEA, APAC and the US. Subsidiaries that form part of the Trustpilot Group and which are also covered by this statement are:

• Australia: Trpilot PTY Limited

• Denmark: Trustpilot A/S

• Germany: Trustpilot GmbH

• Italy: Trustpilot S.r.l

• Lithuania: Trustpilot UAB

• The Netherlands: Trustpilot B.V.

• United Kingdom: Trustpilot Ltd

• United States: Trustpilot, Inc.

As a SaaS business, our people, expertise and intellectual property rights are our business. Although we engage with suppliers for a range of services, the majority of our suppliers provide us with IT hardware, network services, and software. Our business model therefore does not carry with it a high level of slavery risk.

Our approach

Across the Trustpilot Group we strive to work to the highest professional standards and comply with all laws, regulations and rules relevant to our business.

Vendors

Our People (HR) and Legal teams work in conjunction with our Procurement function to help ensure that the aims and provisions of the Act are complied with and to manage any concerns or breaches.

Our Modern Slavery Code of Conduct sets out the standard of conduct for customers, contractors, and vendors working with us. It is publicly available on our website and we seek to impose contractual obligations on vendors to comply with this as part of contractual negotiations for supply contracts where possible.

Employees

Our recruitment and employment procedures include appropriate pre-employment screening of all Trustpilot Group employees, such as right to work checks and reference checks. New employees also receive an induction and new hire training which explains Trustpilot Group policies and confirms that employees are able to contact our People team or our whistleblower email account confidentially on any matter of concern, throughout their employment.

We are also committed to paying the Real Living Wage to our employees and contractors across all our locations in the UK.

We expect all Trustpilot Group employees to conduct business with honesty and integrity and we have a zero tolerance approach to bribery and corruption, as set out in our Anti-Bribery & Corruption Policy.

Customers

In our Code of Ethics we describe our commitment to conducting our business with the highest ethical standards. Trust, transparency, and integrity are values that are important to the entire Trustpilot Group, which means we expect the people who work for us, and those we do business with, to always act with integrity, build trust and promote transparency, and make decisions that reflect strong ethics.

We avoid doing business with businesses that do cause or create harm, do not align with our ethical standards, or do not share the same values and core beliefs as us. These “bad-fit” businesses may harm Trustpilot’s reputation and undermine the trustworthiness of our platform. Our Action We Take Policy sets out what types of businesses we regard as a “bad-fit” for Trustpilot. We also explain what measures we’ll take to stop any active communication or cooperation with “bad-fit” businesses.

Additionally, we require customers to comply with our Modern Slavery Code of Conduct under our Terms of Use & Sale for Businesses.

Trustpilot Group policies

Our Trustpilot Group policies work to identify and prevent any slavery and human trafficking within our operations. We work to maintain high professional and ethical standards and ensure our employees know their role in maintaining these.

All Trustpilot Group employees are provided with a written contract of employment, including Trustpilot’s Code of Ethics, and are governed by corporate policies available on the Trustpilot intranet including Trustpilot’s Code of Ethics, Contract Approval & Signing Matrix, Anti-Bribery & Corruption Policy, Non-Discrimination & Anti-Harassment Policy and Speaking Up Policy.

Our Modern Slavery Code of Conduct is publicly available on Trustpilot’s website for all vendors, customers and contractors to access.

Due diligence/Risk assessment

We seek to work with customers, contractors, and vendors who match and complement our ethical standards and organisational values.

To identify sectors and categories with high modern slavery risks, we have used the following indicators that are generally known to increase risk likelihood:

• Reliance on low-skill workforce.

• Reliance on migrant workforce.

• Presence of children.

• Hazardous or undesirable work.

• Based in a country that experiences high levels of corruption, weak governance, and poor enforcement of human rights.

As Trustpilot is an online-based business, our main vendors comprise providers of online-based services to facilitate our platform, and general advisory services from reputable businesses. Based on these factors, we consider the risk of modern slavery in our supply chain to be low.

We continue to:

• Undertake due diligence when short-listing our vendors and contractors.

• Review on a regular basis the vendors and contractors we use.

• Enter into business relationships with vendors that reflect our organisational values.

• Seek to ensure that any vendor or contractor has an ethical treatment clause in the vendor contract they provide us especially where we deem them to be medium to high risk based on their geographical location or otherwise. This is to ensure that the work environment and conditions they provide to their employees meet standards under our Modern Slavery Code of Conduct.

If a vendor or contractor fails to live up to our expectations or is unwilling to make any changes, we may end our engagement with them.

Further steps

We continue to strive to improve the measures we take across the Trustpilot Group to ensure that we mitigate the risk of modern slavery within our supply chains.

• We have developed modern slavery specific training for all employees in the Trustpilot Group involved in the recruitment of staff and procurement of vendors to support them in identifying risk factors, understanding the implications, and assisting with implementing the requirements of the Act effectively.

• We continue to seek contractual rights to request compliance-related information and the right to audit vendors at our discretion, as well as seeking improvements in ensuring that risk areas are documented, monitored and taken into consideration when contracting with vendors.

This statement was approved by the Trustpilot Group plc Board of Directors on 23 May 2023 and is signed by