Modern Slavery Statement
Introduction
This Modern Slavery Statement (“Statement”) has been prepared for Klaviyo, Inc., and its foreign subsidiaries including Klaviyo Australia Pty Ltd (ABN 19 654 057 495) in Australia and Klaviyo Ltd. (Company number 12059202) in the United Kingdom (collectively referred to as “Klaviyo”). This Statement has been prepared in compliance with global modern slavery legislation including the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018 and the California Transparency in Supply Chains Act 2010. This Statement sets out the steps Klaviyo has taken in its fiscal year ended December 31, 2023 to ensure that its supply chain and operations are free from modern slavery.
Our Business
Klaviyo was founded in 2012 and is headquartered in Boston, Massachusetts. Klaviyo powers smarter digital relationships, making it easy for businesses to capture, store, analyse, and predictively use their own data to drive measurable, high-value outcomes. Klaviyo’s SaaS platform enables business users to harness their first-party data to send the right message at the right time across email, SMS, and push notifications. More than 146,000 paying customers leverage Klaviyo to acquire, engage, and retain customers—and grow on their own terms.
Based on our SaaS business model, Klaviyo believes that the risk of modern slavery in our supply chain and operations is limited.
Klaviyo’s Mission and Commitment to Equity
Klaviyo’s mission is to empower creators to own their destiny. We treat people both inside and outside of Klaviyo with equity, respect, honesty, and kindness. We strive to build a diverse company, and prioritise the inclusion of varied opinions and experiences throughout Klaviyo.
2023 Highlights
Engaging Suppliers
We conduct due diligence when engaging vendors, service providers, suppliers or other parties providing goods or services (“Suppliers”) to Klaviyo. Klaviyo’s compliance team screens all new Suppliers using Diligent’s Risk Intelligence Data Software, which performs screening against global sanctions, watchlists as well as adverse media. Furthermore, Klaviyo’s compliance team conducts annual screenings on all existing Suppliers.
Our Code of Conduct
Our Code of Conduct (“Code”), which all employees, officers, directors and independent contractors are required to attest to, provides guidance to our employees, officers, directors and independent contractors on the policies, laws, rules, and regulations they are expected to follow. Furthermore, all employees and independent contractors complete mandatory training on our Code during their onboarding.
Our Code also outlines how an individual can submit a question or raise a concern of a suspected violation of our Code or any other Klaviyo policy through our independent Ethics & Compliance Helpline. Reports to the Helpline are received by an independent third-party service specifically retained by Klaviyo to handle such reports.
Annual Ethics Week
An ethics-focused week reinforces our commitment to ethics, and reminds our employees of our values and expected behaviours.
- Raising Awareness – When employees are aware of our ethical standards and reporting mechanisms, they are more likely to take the appropriate action when they encounter potential issues.
- Education and Training – This week is used to provide training to educate employees on ethical issues relevant to their roles. Topics include data privacy, anti-discrimination policies and conflicts of interest.
- Culture Building – Emphasising ethics strengthens our commitment to doing things the right way. This focus reinforces our values and ingrains ethical behaviour as a cornerstone of our culture.
- Risk Management – Ethical lapses can be costly and damaging to a company’s reputation. By actively promoting ethical behaviour, we aim to prevent such issues and maintain a strong public image.
Related Policies
Klaviyo has a number of related policies that underpin our commitment to ethical business practices as well as emphasising accountability and transparency within the organisation.
- Whistleblower Policy – Klaviyo’s whistleblower policy encourages the highest levels of ethical and business standards by providing a mechanism for any employee or interested persons to speak up and report actual or suspected wrongdoing. This policy identifies how an individual can report a concern, the safeguards Klaviyo has in place regarding reports and Klaviyo’s commitment to non-retaliation and how Klaviyo will investigate concerns raised under this policy.
- Anti-Corruption, Anti-Bribery and Anti-Money Laundering Policy – Klaviyo recognises that a robust policy against corruption, bribery and anti-money laundering is a vital component in ensuring our supply chain and operations are free from modern slavery.
Looking to 2024
Klaviyo is committed to promoting ethical business practices and continuously reviewing and assessing the risk of modern slavery in both our operations as well as our supply chain.
In Klaviyo’s fiscal year ending December 31, 2024, we will focus on the following goals:
Supplier Code of Conduct
- In an effort to mitigate the risk of modern slavery in our supply chain and operations, Klaviyo will implement a Supplier Code of Conduct that sets out the expectations we have of our suppliers with respect to the Human Rights of Workers, Health and Safety and Improper Conduct Reporting, amongst other topics.
Modern Slavery Guidance and Training
- Our Legal and Compliance team will provide training targeted at key personnel, with a particular focus on the procurement, legal and contract management teams, to educate them about the causes and impacts of modern slavery.
Contractual Obligations
- Klaviyo will review and update the contractual obligations in its Supplier Services Agreements to include specific reference to compliance with applicable modern slavery laws.
Klaviyo will monitor and report on our progress in achieving these goals in our next Modern Slavery Statement.
Approval and Signature
In accordance with applicable legislation, this Statement is made by Klaviyo, Inc. on behalf of itself and its consolidated subsidiaries.
This Statement was approved by the Klaviyo, Inc. Board of Directors on June 27, 2024, and signed by:
Landon Edmond
Chief Legal Officer, General Counsel, and Secretary
June 27, 2024