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 of 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.
Organization Structure and Operations
New Relic is a San Francisco-based technology company that delivers a software platform for customers to land all of 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 a publicly traded company on the New York Stock Exchange. New Relic, Inc. is headquartered in San Francisco, California but has significant operations through its subsidiaries and various regional offices in a number of markets throughout the world. New Relic has over 2,000 employees worldwide and operates in 16 countries.
New Relic operates in the United Kingdom through its subsidiary New Relic UK Ltd. and in Australia through its subsidiary New Relic Australia Pty Ltd.
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, including in the United States, Europe, Australia and South Korea. New Relic also operates in Singapore which is recognized by the Global Slavery Index as medium 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.
Overall, due to the nature of New Relic’s software business and taking into account modern slavery risk factors, New Relic considers itself to be low risk with respect to slavery and human trafficking issues in its supply chain. However, New Relic recognize 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.
Although some of the goods and services that New Relic procures may be higher risk including computer hardware, cleaning services, security, telecommunications and other contractor services, New Relic strives to source goods and services from reputable third parties and we continue to enhance our supply chain selection and management processes with these risks in mind. 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.
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. All workers employed by New Relic and its suppliers are subject to background checks, as allowed under applicable local law. New Relic contractually 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, New Relic will take appropriate action.
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;
- 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 page 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 General Counsel 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. 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 effect. 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 a large number of 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 into new contracts, undertake due diligence to ensure that the third parties have the relevant policies and procedures in place to address modern slavery risks.
New Relic believes that no individual should be subjected to any form of modern slavery and New Relic will continue to review its processes to take necessary steps within its power to prevent this from existing within its business and supply chains. New Relic is committed to engaging with and educating its suppliers and workforce regarding modern slavery risk identification and mitigation.
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.
New Relic has reviewed its performance during fiscal year 2021 against the established KPIs. During fiscal year 2021, New Relic has:
- made our statements submitted pursuant to the Modern Slavery Act 2015 available to the public as well as the employees and contractors working for New Relic.
- undertaken continued training efforts related to modern slavery for staff involved in the company’s procurement function, including with respect to audits of vendors and 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.
To ensure that New Relic is successful in continuing to implement the foregoing efforts, New Relic’s General Counsel 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 General Counsel by emailing firstname.lastname@example.org.
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 and its stockholders, while continually reviewing and assessing the adequacy of its policies, controls, and guidelines. New Relic’s Board has set up a Nominating and Corporate Governance Committee, which in part oversees all aspects of the company’s corporate governance functions and reports any findings back to the full Board.
New Relic has zero tolerance to inaction in relation 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.
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.
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 2021.
This statement was approved by the Board of Directors of New Relic, Inc. on January 19, 2022.
Director and Chief Executive Officer, New Relic, Inc.
Chief Financial Officer, New Relic, Inc.
Director, New Relic UK Ltd.
Director, New Relic Australia Pty Ltd.
SVP, Finance & Administration and
Chief Accounting Officer, New Relic, Inc.
Director, New Relic UK Ltd.
Director, New Relic Australia Pty Ltd.
GVP, Finance and Administration, Global Controller, New Relic, Inc.
Director, New Relic UK Ltd.
Director, New Relic Australia Pty Ltd.