Modern Slavery Act Statement
Commvault Systems Limited (“Commvault”) has prepared this Modern Slavery Statement pursuant to its Human Rights Policy and the Modern Slavery Act 2015.
This Statement describes the steps Commvault has taken to ensure that modern slavery and human trafficking is not taking place in any part of our business or within our supply chains.
Commvault’s operations are primarily within the UK, with some activities taking place in other countries within Europe, the Middle East and Africa. Commvault Systems Limited is a wholly owned subsidiary of Commvault Systems International B.V. located in the Netherlands.
Commvault is a provider of backup and recovery software, solutions and services to a broad range of customers. We sell our software and services directly to customers and via a group of trusted partners.
Commvault sells our own internally developed products and services, and as such we do not have a traditional supply chain for raw materials, components or equipment. The creation and development of our software and solutions is effectuated predominantly through writing source code, which is a sophisticated and complex process that requires high levels of education and training.
The majority of our source code is proprietary and is written by Commvault employees at our own offices, primarily located in the US, but also in India, and as a result we have direct oversight of this process. The development of our products also involves working with some key third-party suppliers, such as Microsoft and Fujitsu, who have their own Modern Slavery Statements upon which we rely.
Our Commitment to addressing Modern Slavery
Commvault operates the following policies that assist with the identification of modern slavery risks and describe the steps taken to prevent slavery and human trafficking in our operations:
- Code of Business Ethics and Conduct for employees – This code makes clear the level of actions and behaviour expected of Commvault employees when representing the company. Commvault requires employees, directors, vendors and other third parties working on our behalf to uphold the highest standards of professional and ethical behaviour, including compliance with applicable laws and regulations such as the Modern Slavery Act.
- Whistleblowing policy – Commvault maintains an Employee Ethics Hotline and encourages employees to report any concerns or complaints relating to breach of the Code of Business Ethics and Conduct, including any circumstances which may give rise to an enhanced risk of human trafficking or slavery. The policy is designed to make it easy for employees to make disclosures without fear of retaliation.
- Contractual obligations for suppliers – Key suppliers involved in the development and delivery of Commvault products and services are contractually obligated to comply with all applicable laws and regulations, such as the Modern Slavery Act 2015.
- Background screening for employees – As part of the employee hiring process Commvault conducts a comprehensive screening process to assist with identifying any human trafficking risks.
This Statement has been approved by the Board of Directors of Commvault Systems Limited.