Introduction
This Modern Slavery and Human Trafficking Statement (“Statement”) addresses the reporting requirements set out in section 54(1) of the United Kingdom Modern Slavery Act of 2015 (the “Modern Slavery Act 2015”) and the Australian Modern Slavery Act 2018 (the “Australian Act”). The Modern Slavery Act 2015 and Australian Act require certain businesses to disclose their modern slavery risks and efforts to mitigate those risks in their operations and supply chains.
This Statement is given on behalf of New Relic, Inc., which is a reporting entity for the purposes of the Australian Act, and its subsidiaries (collectively, “New Relic”). New Relic is committed to complying with modern slavery laws and effectively managing its modern slavery risks. New Relic strives to act ethically and with integrity in all its business relationships, which means that New Relic takes great effort to implement and enforce effective systems and controls, including those that would address the risks of modern slavery practices occurring in New Relic's operations or supply chain.
In this Statement, the collective expressions 'New Relic', 'we', 'us' and 'our' are used conveniently to refer to New Relic, Inc. and its subsidiaries. This is because, in relation to modern slavery risk assessment and management, we operate using group-wide policies and procedures. It is not intended to convey how we are structured, managed or controlled.
Organizational Structure and Operations
New Relic is a San Francisco-based technology company that delivers a software platform for customers to land all their telemetry data quickly and affordably in one place and derive actionable insights from that data in a unified front-end application. New Relic, Inc. is incorporated in Delaware and is privately owned by Francisco Partners, a leading global investment firm that specializes in partnering with technology businesses, and TPG, a leading global alternative asset management firm. New Relic, Inc. is headquartered in San Francisco, California but has significant operations through its subsidiaries and various regional offices in several markets throughout the world. New Relic has over 2,100 employees worldwide and operates in 16 countries.
New Relic, Inc. operates in the following countries through its subsidiaries as stated below:
- New Relic, Inc. operates in the United Kingdom through its subsidiary New Relic UK Limited
- New Relic, Inc. operates in the Australia through its subsidiary New Relic Australia Pty Ltd
- New Relic, Inc. operates in the Belgium through its subsidiary New Relic Belgium SRL
- New Relic, Inc. operates in the Canada through its subsidiary New Relic Canada ULC
- New Relic, Inc. operates in the France through its subsidiary New Relic France SAS
- New Relic, Inc. operates in the Germany through its subsidiary New Relic Germany GmbH
- New Relic, Inc. operates in the Ireland through its subsidiary New Relic International Limited
- New Relic, Inc. operates in the Israel through its subsidiary New Relic Israel Ltd
- New Relic, Inc. operates in the Japan through its subsidiary New Relic K.K.
- New Relic, Inc. operates in Korea through its subsidiary New Relic Korea Co., Ltd.
- New Relic, Inc. operates in the India through its subsidiaries New Relic One India Private Limited and Kay Two Cyber Security India Private Limited
- New Relic, Inc. operates in the Singapore through its subsidiary New Relic Singapore Pte. Ltd.
- New Relic, Inc. operates in the Spain through its subsidiary New Relic Spain, S.L.
- New Relic, Inc. operates in the Switzerland through its subsidiary New Relic Switzerland GmbH
- New Relic, Inc. operates in the Netherlands through its subsidiary New Relic Netherlands B.V.
- New Relic, Inc. operates in the United States through its subsidiaries K2 Cyber Security, LLC and New Relic One India Management LLC.
New Relic’s subsidiaries are primarily engaged in supporting New Relic’s business of providing cloud-based observability solutions under the NEW RELIC trademark and related marks.
Operations and Risks
Overall, due to the nature of New Relic's business as a developer and provider of a software platform, New Relic considers itself to be low risk with respect to modern slavery practices in its operations. This is based on an assessment of New Relic's geographical footprint against the Global Slavery Index's list of high, medium and low risk countries. New Relic primarily operates in lower geographic risk countries and regions, including in the United States, Europe, Australia, Japan, Singapore and South Korea. New Relic also operates in Israel and India, which are recognized by the Global Slavery Index as above average vulnerability risk.
New Relic's workforce is primarily made up of skilled full-time permanent employees, which further supports our low-risk status. New Relic does, however, engage some contractors, which is addressed further below.
Supply Chain and Risks
New Relic’s suppliers primarily provide us with software, software-as-a-service, professional services, and finished physical products, such as computer hardware, office equipment, and related goods. New Relic does not directly manufacture goods, supplies or physical products. We also procure goods and services, such as computer hardware, cleaning, security, telecommunications and other contractor services, and engages placement and recruiting agencies to source independent contractors.
Although some of the goods and services that New Relic procures (including computer hardware, cleaning services, security, telecommunications and other contractor services) may be higher risk due to their country of origin and other factors, New Relic strives to source goods and services only from reputable third parties, as assessed based on commercial reputation, background checks, sanctions screens, reference calls, and other due diligence mechanisms. We also continue to enhance our supply chain selection and management processes with these risks in mind. For example, New Relic has recently introduced a “Enhanced Compliance Requirements” schedule that is mandatory for inclusion in contracts with vendors located countries at higher risk for corruption (including modern slavery), and New Relic is currently in the process of improving its due diligence and background checking programs for vendors and customers alike. In addition, New Relic’s suppliers and partners are predominantly based in the United States and Europe and are mostly technology and services providers. Only a very small percentage of New Relic’s suppliers provide hardware, and those vendors are also typically large, multinational companies, with their own company codes of conduct, often including human rights commitments. Our technology and services providers include the likes of Amazon.com, Inc., Google LLC, Salesforce.com, Inc., and Microsoft Corporation, each of which have stated codes of conduct and ethics.
Overall, due to the nature of New Relic’s software business, and taking into account modern slavery risk factors and an assessment of New Relic's geographical footprint against the Global Slavery Index's list of high, medium and low risk countries, New Relic considers itself to be low risk with respect to slavery and human trafficking issues in its supply chain. However, New Relic recognizes that risks of modern slavery and human trafficking can exist for global organizations, especially with regards to supplies to the IT and software sector linked to electrical product manufacturing, which is a known high-risk sector.
Additionally, New Relic generally uses placement and recruiting agencies to source independent contractors for its workforce, and these agencies are selected following a standard sourcing process that includes vendor due diligence, background checks, and other compliance processes intended to reduce or eliminate corruption and modern slavery risk. All workers employed by New Relic and its suppliers are subject to background checks, if allowed under applicable local law. New Relic requires its suppliers to adhere to applicable laws, including employment laws related to child labor, wages, working hours, and working conditions. Further, if New Relic learns that any party has acted in a manner inconsistent with its ethical standards, as specified in New Relic’s Vendor Code of Conduct, posted publicly on New Relic’s webpage here. New Relic will take appropriate action such as requiring additional training on ethics and compliance requirements, financial penalties for non-compliance, termination of suppliers’ contracts, and reporting to the respective authorities/regulators.
New Relic Policies and Values
New Relic believes that its corporate culture has been a critical component to its success. New Relic has invested substantial time and resources in building its team and ensuring that the type of people it employs or works with have high moral standards and integrity. In its offices worldwide, New Relic’s workforce celebrates diverse perspectives and unique identities, respects each other, and makes a real impact every day. New Relic ensures that the highest level of integrity is maintained throughout all areas of its business by promoting its five core values:
- Authentic – Be genuine, honest, and inclusive.
- Accountable – Take pride in what one does and hold oneself to high standards. Deliver on commitments.
- Bold – Take risks to deliver ground-breaking innovation. Be courageous.
- Passionate – Be inspired by, and seek to inspire, customers. Strive to make a difference.
- Connected – Build trusted, personal connections with each other. Be a team.
New Relic’s employees and contractors are also required to adhere to a Code of Conduct (the “Code”), which can be downloaded here. All employees complete training when they join us and at least annually thereafter to ensure they remain aware of and agree to comply with our Code and other applicable policies and procedures. The Code reflects the business practices and principles of behavior that supports our values and is reviewed for any necessary updates regularly. Among other things, the Code sets forth guidelines regarding:
- honest and ethical conduct;
- legal compliance in relation to applicable laws, including modern slavery laws;
- international business laws;
- conflicts of interest;
- fair dealings; and
- compliance standards and procedures.
The Code also includes mechanisms for dealing with violations, encouraging reporting and redressing concerns.
New Relic’s suppliers are separately required to adhere to the Vendor Code of Conduct, posted publicly on New Relic’s webpage here. The Vendor Code of Conduct outlines that New Relic will not tolerate any human rights abuses or offenses (including those relating to modern slavery) by our vendors or their affiliates, employees, agents, or subcontractors. The Vendor Code of Conduct further states that vendors must regularly review their employment practices and perform due diligence to ensure against modern slavery and human trafficking in their own supply chains. The Vendor Code of Conduct also provides contact details for suppliers to report concerns to our Chief Legal Officer and New Relic promptly investigates all matters submitted and responds appropriately.
In accordance with these guidelines and values, New Relic aims to ensure that it hires and works with people who portray high ethical standards and integrity that would have zero tolerance towards any sort of modern slavery or human trafficking.
New Relic strives to act ethically and with integrity in all its business relationships, which means that New Relic takes great effort to implement and enforce effective systems and controls, including those that would prevent slavery and human trafficking from existing in any part of New Relic’s business or supply chains, as described further below.
Controls and Due Diligence Processes
To ensure all those in New Relic’s supply chains and contractors comply with New Relic’s values, New Relic enters into appropriate agreements with its suppliers and partners. As part of this, New Relic requires suppliers and partners to comply with all applicable laws, which includes the Modern Slavery Act 2015 and the Australian Act if applicable. New Relic also may require certain suppliers and partners to adhere to the Code, or to certify that they have implemented a code of conduct with the same effects. However, we recognize that in order to manage its growth and increasing risks effectively and sustainably, New Relic must continue to improve its operational, financial, and management systems and controls by, among other things:
- effectively attracting, training, and integrating new employees, particularly members of sales and marketing teams and employees and consultants in all jurisdictions;
- enhancing information, training, and communication systems to ensure that employees are well-coordinated, well-informed, and can effectively communicate with each other and customers; and
- when entering new contracts, undertaking due diligence to ensure that the third parties have the relevant policies and procedures in place to address modern slavery risks and requiring additional contractual assurances related to compliance and anti-corruption where appropriate.
A component of New Relic’s growth strategy involves the further expansion of its operations and customer adoption internationally. Operating in international markets requires significant resources and management attention and subjects New Relic to regulatory, economic, and political risks that are different from those in the United States — e.g., the Modern Slavery Act 2015 and the Australian Act. New Relic regularly keeps up to date with changing legislation and keeps its employees informed through appropriate training and updates.
Assessing the Effectiveness of our Actions
New Relic recognizes the importance of reflecting on and assessing the effectiveness of our efforts to address modern slavery risk. While this is an ongoing and dynamic exercise, we currently consider the following key performance indicators (KPIs) in measuring our effectiveness:
- the nature and extent of training and awareness-raising programs delivered; and
- the nature and extent of contracts with suppliers and partners that require compliance with all applicable laws, including those that would prevent slavery and human trafficking.
Additionally, New Relic regularly evaluates processes to determine whether it would be appropriate to adopt further policies or procedures, or join related third-party organizations, each in light of the goal of effectively addressing the risk of modern slavery practices in our operations and supply chains, and regularly makes improvements to such processes to achieve greater efficiency and effectiveness
New Relic has reviewed its performance during fiscal year 2024 against the established KPIs. During fiscal year 2024, New Relic has:
- undertaken continued training efforts related to modern slavery for staff involved in the company’s procurement function, including with respect to appropriate terms for inclusion in negotiated agreements;
- continued efforts to include in all vendor agreements provisions that require suppliers and partners to comply with all applicable laws, including those that would address modern slavery risks; and
- continued to evaluate and implement mechanisms, software and training programs to improve employee knowledge regarding compliance with applicable policies
In these ways, we assess the effectiveness of our actions to address modern slavery risks in our operations and supply chains.
Governance
To ensure that New Relic is successful in continuing to implement the foregoing efforts, New Relic’s Chief Legal Officer oversees program responsibilities, which include:
- investigating possible violations;
- requiring contractors and vendors to alert the company and relevant authorities of possible violations;
- training new employees;
- conducting regular training sessions to refresh employees’ familiarity;
- obtaining annual confirmations from employees as to compliance with applicable policies;
- updating policies as needed and alerting employees to any updates; and
- otherwise promoting an atmosphere of responsible and ethical conduct.
Any employee, contractor, or third party can contact New Relic’s Chief Legal Officer by emailing legal@newrelic.com.
In addition, to ensure that compliance is maintained throughout the company, New Relic’s Board of Directors (the “Board”) must exercise its judgment in the best interest of New Relic, while continually reviewing and assessing the adequacy of its policies, controls, and guidelines.
New Relic has zero tolerance to inaction in relation to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with New Relic’s values, New Relic has in place mechanisms for our employees, suppliers, and third parties to ask questions or to report concerns about possible violations of New Relic’s policies and applicable laws, including those related to modern slavery. These feedback mechanisms also enable us to assess the effectiveness of our actions to address modern slavery risks in our operations and supply chains.
Consultation
As noted above, New Relic took a group-wide approach in preparing this Statement. This involved engaging with relevant personnel of New Relic's subsidiaries during the drafting process. The Board of New Relic, Inc., New Relic Australia Pty Ltd and New Relic UK Ltd were given an opportunity to review and comment on this Statement.
Looking Ahead
Compliance with the Modern Slavery Act 2015 and the Australian Act is an ongoing commitment. As an organization, New Relic is continuing to develop the way it works to ensure that modern slavery risks are effectively identified and managed throughout our operations and supply chains. Going forward, we intend to continue to engage with key suppliers to improve modern slavery risk awareness, review relevant policies and explore opportunities for collaboration and partnerships to combat modern slavery.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and section 13 of the Australian Act and constitutes New Relic’s slavery and human trafficking statement for the financial year ending 31 March 2024.
Ashish Agarwal
Chief Financial Officer and Director, New Relic, Inc.
Director, New Relic UK Ltd.
Director, New Relic Australia Pty Ltd.
Drew Delmonico
SVP, Chief Accounting Officer and Director, New Relic, Inc.
Director, New Relic UK Ltd.
Director, New Relic Australia Pty Ltd.
Thomas Lloyd
Chief Legal Officer and Director, New Relic, Inc.
Director, New Relic UK Ltd.
Director, New Relic Australia Pty Ltd.
Lauren Walz
VP, Assistant General Counsel and Director, New Relic, Inc.
Director, New Relic UK Ltd.
Director, New Relic Australia Pty Ltd.
This statement was approved by the Board of Directors of New Relic, Inc. on September 25, 2024.