Introduction from Primer

Modern slavery is a crime and a violation of fundamental human rights. Modern slavery takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which deprive victims of their liberty and exploit them for personal or commercial gain. Primer Technologies, Inc. and its affiliates (together, “Primer”) does not tolerate modern slavery or human trafficking. This Modern Slavery and Human Trafficking statement reflects Primer’s ongoing efforts and commitment to fully comply with all applicable laws and regulations to mitigate any risk of human trafficking in our business operations or in those of our suppliers.

Organizational Structure

Primer provides industrial-grade Natural Language Processing (NLP) applications to customers across public and private sectors seeking machine intelligence solutions with human-level precision. Our 200+ employees work with clients in law enforcement, military, intelligence, manufacturing, tech, and consumer organizations around the globe, from our headquarters in San Francisco, CA, USA and offices in New York, NY, USA; Washington, DC, USA; London, UK; Abu Dhabi, UAE; Singapore; and Melbourne, Australia.

Our Supply Chains

Our supply chain consists primarily of professional and office services and office goods. Professional service suppliers include consultants in various fields, travel agents, and outside legal counsel. Office services suppliers include, for example, delivery services, catering, maintenance, repair, and cleaning services. Office goods suppliers include, for example, computer hardware and software, copiers, telephone, office furniture and fixtures, office supplies, and related goods.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. At Primer, personnel are required to comply with our five core values which set out our commitment to ethical business practices and regulatory compliance.

Our business is advanced application development that does not involve the type of labor often associated with slavery or human trafficking. Our office services suppliers are engaged in a range of activities, from higher skilled to lower skilled, but almost all are engaged in services conducted in close proximity to or in close cooperation with Primer personnel. Consequently, these services are conducted in professional environments where exploitative practices would be difficult, if not impossible, to hide. Our suppliers of office goods are reputable retailers and wholesalers. We do not contract with source suppliers based in industries or regions of the world where the risks of modern slavery and human trafficking are relatively high. We believe the risks of slavery and human trafficking practices directly within our business are extremely low.

Our workplace policies demonstrate our commitment to act ethically and with integrity in all our business relationships. Our procedures implement and enforce effective systems and controls to ensure our supply chains are completely free from slavery and human trafficking. To meet the obligation to report on measures that ensure that our entire business and supply chain are slavery free, we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and addressing potential modern slavery issues.

Supplier Adherence to our Values

Within our workplace, we enforce policies and procedures to ensure that we act ethically and with integrity in all our business relationships. We also implement and enforce effective systems and controls to ensure our supply chains are entirely free from slavery and human trafficking.

Reporting and Training

All personnel have access to internal channels for reporting suspected incidents of modern slavery and human trafficking, including in-person access to Primer’s compliance team and mechanisms for submitting anonymous reports. This ensures that Primer personnel engaged in sales or procuring goods and services from third parties understand the risks of modern slavery and human trafficking in our supply chains and our business.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes Primer’s slavery and human trafficking statement for the 2020 financial year (FY20). For the purposes of the UK Modern Slavery Act, the United Kingdom subsidiary covered by this statement includes Primer Technologies UK, Ltd.