Modern Slavery Act Statement


Introduction

Commvault has implemented policies and procedures to ensure that modern slavery and human trafficking does not occur in our business operations or within our supply chain, pursuant to our Human Rights Policy the requirements of the UK Modern Slavery Act 2015, and similar laws and regulations.

Our Business

Commvault sells software and services to customers and partners. The development of our software occurs predominantly through writing source code, a sophisticated and complex process that requires high levels of education and training. The majority of our source code is created in-house by Commvault employees, and as a result, we maintain direct oversight of the software development process.

Our Commitment

Commvault maintains the following policies that assist with the identification and prevention of modern slavery risks in our operations:

  • Code of Ethics – The Code of Ethics clearly defines the level of actions and behaviors expected of 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 behavior, including compliance with applicable laws and regulations.
  • Ethics and Integrity Reporting Policy – Commvault encourages employees and any concerned individuals to report ethics concerns or complaints through its Ethics and Integrity Reporting platform. Commvault maintains a no-retaliation policy to protect individuals who report issues in good faith.
  • Supplier Code of Conduct – Commvault has developed a Supplier Code of Conduct to outline expectations regarding ethical behavior in its supply chain. Suppliers are also responsible for upholding contractual obligations regarding compliance with applicable laws and regulations, including those that prohibit modern slavery and human trafficking. 
  • Background Screening – Commvault conducts comprehensive background screening as part of the hiring process to assist with identifying human trafficking risks. 
  • Customer and Partner Screening – All customers and partners are continually screened against U.S. and International sanctions lists, including the US – DHS Uyghur Forced Labor Prevention Entity List.


Board Approval

This statement has been approved by the Board of Directors of Commvault Systems, Inc.