Modern Slavery Statement
Overview
Sierra Technologies, Inc. (together with its direct and indirect subsidiaries, “Sierra”, “we,” or “our”) is committed to ensuring that our business and supply chain reflects our high ethical standards, values, and respect for human rights. We do not tolerate or condone human trafficking or slavery (“Modern Slavery”) in any part of our global organization or our supply chain.
This statement describes how we seek to ensure that our operations and supply chains are kept free of Modern Slavery, expresses our firm commitment to protect and advance human dignity and human rights in our global business practices, and describes the current practices and measures we have in place to demonstrate such commitment. Further, we are committed to continuously improving our practices relating thereto, each as further described in this statement.
This statement covers Sierra and its group companies, including Sierra Technologies Ltd, our UK subsidiary. This statement has been approved by the Board of Directors of Sierra Technologies, Inc., is made pursuant to section 54(1) of the UK Modern Slavery Act 2015, and constitutes Sierra’s Modern Slavery statement for the financial year ending January 31, 2026.
Sierra’s Business and Organizational Structure
Sierra helps businesses build better, more human customer experiences with AI. Our business includes the provision of a conversational AI platform where we and our customers can build AI agents that transform customer experience, push the boundaries of applied AI, and deliver measurable business impact at scale. For example, Sierra AI agents can provide customer support, enhance brand interaction, and streamline operations for companies and businesses in various industries, including but not limited to financial services, healthcare, insurance, telecommunications, retail, and technology.
Sierra Technologies, Inc. is a Delaware corporation, is headquartered in San Francisco, California, USA, and operates globally.
Sierra’s Supply Chains and Modern Slavery Risks
Our major supply chains include the purchase of AI technologies and access to large language models (LLMs) from AI vendors, third-party consultants (including subcontractors) that we engage for services from time to time related to various work (including financial work, legal counsel, IT applications, security, and other professional services), service providers providing a range of services (including relating to IT, travel, employee payroll, and maintenance), and partners who may co-sell our products and/or provide implementation services to customers.
While Sierra does not engage in manufacturing of physical goods, we take steps to ensure our employees, contractors, partners, and vendors engaged in connection with the delivery of our products and services do not engage in or otherwise promote Modern Slavery.
We have considered various factors in assessing Modern Slavery risk in our business operations, including industry, work type, geography, the terms and conditions in place with third parties, and more. Taking into account such factors and the nature of our operations and supply chains, we believe the risk of Modern Slavery in our operations or supply chains to be low.
Nevertheless, we regularly take action to identify the areas of our business and supply chains that are most at risk in relation to Modern Slavery. To manage these risks, we endeavor to ensure compliance by our employees and service providers with the policies described below, and undertake the actions noted below in relation to due diligence of certain third parties.
Our policies in relation to slavery and human trafficking
As part of Sierra’s commitment to combatting Modern Slavery, we have implemented the following policies:
Employee Code of Conduct
Sierra’s Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships, including that: (i) all employees and contractors of Sierra are expected to know and comply with the Code of Conduct, to act with honesty and integrity, and to report any concerning situations or violations to Sierra leadership, (ii) violations of the Code of Conduct can result in disciplinary action, up to and including termination, and (iii) Sierra is committed to providing a safe, violence-free work environment.
Certified Partner Code of Conduct
Sierra’s Certified Partner Code of Conduct requires participants in Sierra’s Certified Partner Program to comply therewith, and requires such partners to comply with applicable law and regulation, including trade regulation, labor and employment laws, to conduct business ethically, and to adhere to high standards regarding labor and human rights, such as prohibitions on the use of forced, bonded, or indentured labor, and child labor. The Certified Partner Code of Conduct provides a mechanism for reporting violations to Sierra’s Legal department.
Policy and Compliance Plan for Combatting Human Trafficking
Sierra has developed a Policy and Compliance Plan for combatting Human Trafficking in accordance with its requirements under U.S. Federal Acquisition Regulation 52.222-50 ("FAR 52.222-50") as a U.S. federal government contractor.
The Policy and Compliance Plan requires Sierra not to engage in any form of human trafficking, and not to take actions that may increase the risk of human trafficking. Sierra is required to comply, and requires its directors, officers, employees, and service providers to comply with the terms of the policy, and to include the substance of FAR 52.222-50 in all subcontracts and in all contracts with agents.
The Policy and Compliance Plan provides a mechanism for any activity inconsistent with such policy to be reported to Sierra’s Legal or Human Resources departments, with assurances that retaliation is prohibited against anyone making a report in good faith.
The Policy and Compliance Plan also states that Sierra will take disciplinary appropriate action, up to and including termination, against individuals who violate such policy, and further provides that Sierra will take appropriate action against contractors or third parties who violate the Policy and Compliance Plan, up to and including the termination of contracts with subcontractors, agents, and external recruitment agencies who fail to comply with FAR 52.222-50.
Whistleblowing Policy
Sierra has a Whistleblowing Policy in place which sets out the process for Sierra employees and service providers to anonymously raise any concerns they may have regarding our compliance with our legal obligations, including in relation to Modern Slavery, and to ensure that there is adequate protection for individuals who make protected disclosures. Sierra will not and does not tolerate retaliation against those who whistleblow in good faith to identify concerns with its business practices, or the business practices of its suppliers and partners.
Our due diligence processes
We have taken steps to identify, assess, and monitor potential areas of risk in relation to our supply chains, which includes contracts with Sierra’s third-party suppliers or vendors needing to go through several review stages before a contract is entered into (e.g., financial, information security, legal, and privacy approvals). Once reviewed, our suppliers contractually commit to us to comply with applicable laws in the performance of their obligations.
If Sierra establishes or suspects that Modern Slavery is taking place in our business or supply chains, we will take all appropriate action, including termination of the relevant relationship, reporting the activity to law enforcement, and cooperating with any resulting investigation, as applicable.
Ongoing improvement
Following a review of the effectiveness of the steps we have taken this year to ensure that there is no Modern Slavery or supply chains, we intend to take the following further steps to combat Modern Slavery:
- Continuing to update our personnel training programs in line with best practices;
- Introducing a Modern Slavery policy for Sierra so that our employees, workers, contractors and service providers are given guidance on Modern Slavery and preventing Modern Slavery in our business and supply chains; and
- Improving our internal due diligence in respect of suppliers and potential Modern Slavery in their supply chains through the introduction of a Supplier's Code of Conduct.
/s/ Clay Bavor
Clay Bavor, Co-Founder and Director of Sierra Technologies, Inc.
For and on behalf of Sierra
Date: February 4, 2026
Last updated: February 4, 2026