GoDaddy EMEA Modern Slavery Act Statement

1. Introduction

Slavery and human trafficking remain an affliction on global society. GoDaddy EMEA is committed to preventing acts of modern slavery and human trafficking from occurring, within both our business and supply chains. GoDaddy EMEA takes seriously the responsibility to be alert and vigilant to the risk of modern slavery within our supply chain. We are committed to ensuring that our employees and our wider supply chain are aware of these risks and understand how to report them. A key value of our business is an open culture where staff should feel comfortable to report any concerns they may have regarding slavery and human trafficking. To ensure our employees feel at ease when dealing with issues that may arise, we provide training on modern slavery and human trafficking, as well as compliance with the Modern Slavery Act 2015 (the "Act")

2. Structure and Business

GoDaddy Inc. ("GoDaddy") is a global leader in serving a large market of everyday entrepreneurs, delivering simple, easy-to-use products, and outcome-driven, personalized guidance to small businesses, individuals, organizations, developers, designers and domain investors. Our vision is to radically shift the global economy toward independent entrepreneurial ventures. Our mission is to empower entrepreneurs everywhere, making opportunity more inclusive for all. We are passionate about our mission, and we recognize that the opportunity for entrepreneurs is changing. When GoDaddy began, the entrepreneurial journey was simpler: entrepreneurs needed our help to name, create, grow and manage their ventures online. Over time, the evolution of e-commerce, social media and consumer expectations of their online and in-person experiences has changed the entrepreneur's journey. GoDaddy is uniquely positioned to help our customers navigate this complexity. We champion everyday entrepreneurs by empowering them with sage guidance set in seamlessly intuitive experiences to create and protect their digital identity, establish and maintain a ubiquitous presence online and participate in the world of connected commerce. We do all of this while activating the exponential power of our community at a global scale to deliver profitable revenue growth. As of December 31, 2021, we had more than 21 million customers globally and provided localized solutions in over 50 markets. Approximately 33% of our total bookings were attributable to customers outside of the U.S.

As of December 31, 2021, we had 6,611 employees worldwide, including 3,073 in our Customer Care team, 2,098 in technology and development, 597 in marketing and advertising and 843 in general and administrative. Excluded from our employee figures are nearly 2,900 Customer Care specialists located in Colombia, India, Mexico, Philippines, and Spain who are directly employed by third-party partners, but who are dedicated to GoDaddy on a full-time basis. A majority of our employees are based in the U.S. and Europe.

Our people and unique culture have been integral to our success. We live by the same principles that enable new ventures to survive and thrive: hard work, perseverance, conviction, an obsession with customer satisfaction, and a belief that no one can do it better. We take responsibility for driving successful outcomes and are accountable to our customers, which we believe has been a key factor in enabling our customer and revenue growth.

3. Commitment to Sustainable Actions

In 2022, we went a step further to demonstrate our commitment of supporting people, the planet, and our communities through the Sustainable Development Goals (SDGs) by joining the United Nations Global Compact. Through this membership, we commit to supporting the Ten Principles of the UN Global Compact on human rights, anti-corruption, labor and environment, and to disclosing our progress on each of the principles annually.

We identified six SDGs that we believe our business has the greatest opportunity to impact:

  • Gender equality

  • Affordable and clean energy

  • Decent work and economic growth

  • Industry, innovation and infrastructure

  • Reduced inequalities

  • Peace, justice and strong institutions

We believe we have one of the most recognized technology brands in the U.S. To find out more about the nature of our business, please visit our websites:

GoDaddy Inc. is headquartered in Tempe, Arizona and sells its products and services throughout Europe, including the United Kingdom, through LLC and GoDaddy EMEA subsidiaries, including Europe Domains/Hosting Services, Ltd., and 123 Reg Limited; all of which are covered by this Group Statement.

4. Update to relevant policies

We do not consider that we work in high-risk sectors or locations because the majority of our products and services are online, and our offices and support services are not located in high-risk locations with respect to slavery and human trafficking. The substantial majority of our suppliers are IT, software, financial and professional services organizations, including banks, lawyers, accountants, consultants, insurers, and recruitment agencies. Other suppliers include providers of office supplies, catering, office cleaning, point-of-sale hardware device manufacturers, and facilities management providers. Notwithstanding the relatively low risk, we understand the importance of combatting slavery and human trafficking and are committed to ensuring that modern slavery is not taking place in our business or our supply chains.

As such, our Global Master Services Agreement - Supplier Code of Conduct ("Supplier Code" includes the following language:Labor: GoDaddy will not tolerate Service Providers that use child labor or forced labor such as slave, prison, indentured, bonded, or otherwise. GoDaddy will not tolerate any Service Providers that engage in the trafficking or exploitation of workers in any manner. GoDaddy Service Providers must at a minimum comply with all applicable laws for the issues identified below:

  • Freely Chosen Employment; Anti-Human Trafficking

  • Humane Treatment

  • Child Labor Avoidance; Student Interns

  • Non-Discrimination

  • Working Hours

  • Freedom of Association and Collective Bargaining

  • Wages and Benefits

  • Immigration Law and Compliance

In addition, the Supplier Code gives us the right to audit and/or inspect service providers to ensure compliance. The Supplier Code also gives us the right to terminate contractual relationships with suppliers if the audits demonstrate that the supplier has failed to follow the Supplier Code. In addition to the Supplier Code, GoDaddy has its own Code of Business Conduct & Ethics, which includes policies and procedures to combat discrimination and harassment and sets forth workplace expectations for employee behavior and conduct. Lastly, GoDaddy has a dedicated and confidential Ethics Helpline through which an employee may ask a question or report a potential violation regarding an ethics or compliance issue. The Ethics Helpline is administered by a third party to maintain confidentiality and when requested and permitted by local law, anonymity.

5. Identifying and assessing risk

We onboarded a Third-Party Risk Management Program Manager who is leading our Third-Party Risk Management program. The program includes conducting supplier diligence on and monitoring compliance with applicable laws, including human trafficking and slavery laws

6. Key performance indicators

To assess the effectiveness of our anti-slavery and human trafficking measures, we review the following key performance indicators:

  • Number of slavery and human trafficking issues reported in violation of the Supplier Code

  • Staff training levels

7. Training

A key part of our anti-slavery and human trafficking strategy is to promote cultural change through training. This last financial year we continued training that focused on: (i) learning about modern slavery and human trafficking; and (ii) understanding how to report any issues in the workplace.

8. Our statement

This statement is made in accordance with:

  • Section 54(1) of the Act and constitutes GoDaddy EMEA's (inclusive of the relevant subsidiaries to which the Act applies) slavery and human trafficking statement for the financial year commencing 1 January 2021 and ending 31 December 2021.

This statement was approved by the board of:

  • LLC on September 1, 2022;

  • Europe Domains/Hosting Services, Ltd. on September 1, 2022;

  • Go Daddy Europe Limited on September 1, 2022;

  • and123-Reg Limited on September 1, 2022.

Signed by:

Nick Daddario

GoDaddy Inc. – Chief Accounting Officer LLC – Chief Accounting Officer

Europe Domains/Hosting Services, Ltd. - Director

GoDaddy Europe Limited – Director

123 Reg Limited - Director

Date: September 1, 2022