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Modern Slavery
Statement 2021
Avast plc

Avast Modern Slavery Statement

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Table of Contents............................................................................................................................................ 1
Introduction ................................................................................................................................................... 3
1.

Reporting Entities, Business & Supply Chain ........................................................................................ 4

1.1.

Reporting Entities ............................................................................................................................ 4

1.2.

Our Business ................................................................................................................................... 4

1.3.

Our Supply Chain ............................................................................................................................ 4

2.

Policies .................................................................................................................................................. 5

3.

Risk Assessment, Prevention and Mitigation ......................................................................................... 6

3.1.

Operations ....................................................................................................................................... 6

3.2.

Supply Chain ................................................................................................................................... 7

4.

Due Diligence Processes ....................................................................................................................... 7

4.1.

Due Diligence Approach .................................................................................................................. 7

4.2.

Audit and Investigation .................................................................................................................... 8

5.

Training and Capacity Building .............................................................................................................. 8

6.

Measuring Effectiveness and Consultation ............................................................................................ 8

7.

Close ...................................................................................................................................................... 9

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Introduction
Avast is in the business of protection. This extends beyond protecting the digital lives of our customers andapplies to our employees and those we interact with as part of our wider value chain. Through our suite ofpolicies, including our Modern Slavery policy and Code of Conduct, we commit to a high standard of
behaviour towards all employees and other personnel, as well to respect human rights in all our operations
and business dealings.
This commitment extends to our supply chain, and a large part of our focus on modern slavery this year has
been to engage with our new and existing suppliers in the continued roll-out of our Supplier Compliance
Document, which asks suppliers to comply with either the Avast Supplier Guidelines or their own policies,
which have to be in line with international standards of conduct and principles. The Avast Supplier
Guidelines set out the social and environmental standards we expect from our suppliers.
2021 saw Avast experience continued disruption to our business with a period of uncertainty regarding ourpotential merger activity, along with the ongoing impacts of the Covid-19 pandemic. We recognise theincreased vulnerability of many individuals to modern slavery and human trafficking due to the economic
and social disruption caused by the pandemic, making this issue more pressing than ever. Whilst notoccurring within this reporting period, we also acknowledge the significant impact of the conflict in Ukraine.
Please refer to our blog for details of Avast’s response: Avast Response To War In Ukraine | Avast
This is our fourth Modern Slavery Statement pursuant to section 54(1) of the UK Modern Slavery Act 2015
and section 13 of the Australian Modern Slavery Act 2018. The Statement provides a summary of the steps
Avast has taken, and is continuing to take, to prevent modern slavery and human trafficking within ourbusiness and supply chain. The table below illustrates how the different sections of this Statement align withthe reporting criteria under both the UK and Australian Modern Slavery Acts.

UK Modern Slavery Act

Australian Modern Slavery Act

Organisation structure and supply
chainsIdentify the reporting entity
Describe the structure, operations
and supply chains of the reporting
entityDescribe the process of
consultation with any entities thatthe reporting entity owns orcontrols

Policies in relation to slavery andhuman trafficking
Risk assessment and management

Due diligence processes

Training on modern slavery andtrafficking
Key performance indicators tomeasure effectiveness of steps
being taken

Avast Modern Slavery Statement

Relevant Section within thisStatement
1. Reporting Entities, Business &Supply Chain

2. Policies
Describe the risks of modern
slavery practices in the operations
and supply chains of the reporting
entity, and any entities that thereporting entity owns or controls
Describe the actions taken by thereporting entity and any entity thatthe reporting entity owns orcontrols, to assess and address
those risks, including due diligenceand remediation processes

3. Risk Assessment, Prevention
and Mitigation

4. Due Diligence Processes

5. Training and Capacity Building
Describe how the reporting entity
assesses the effectiveness of suchactions
Include any other information thatthe reporting entity, or the entity
giving the statement, considers
relevant

6. Measuring Effectiveness andConsultation
7. Close

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1. Reporting Entities, Business & Supply Chain
1.1.

Reporting Entities

This statement on modern slavery and human trafficking is published on behalf of Avast plc and its wholly
owned subsidiaries, including Avast Software s.r.o., and Piriform Software Limited (trading as CCleaner),
pursuant to section 54(1) of the UK Modern Slavery Act 2015 and section 13 of the Australian Modern
Slavery Act 2018. References to “we”, “us”, “our”, and “Avast” refer to all of these companies. This
statement applies to the financial year ending 31 December 2021.
Avast plc, as the parent company, sets the approach and policy for modern slavery across all wholly
owned subsidiaries. This statement has been approved by the Board of Avast plc on behalf of itself and
its relevant subsidiaries This statement was shared with all reporting entities prior to approval by the Boardof Avast plc. We plan to review our consultation process on modern slavery across the business to ensure
it is proportionate for Avast as we continue to grow.

1.2.

Our Business

Avast is a global leader in consumer cybersecurity with 400+ million users of our products worldwide.
Avast combines artificial intelligence with human ingenuity to create the world’s largest consumer
cybersecurity network protecting people from attacks online.
Avast offers products under the Avast and AVG brands that protect people from cybersecurity and privacy
risks on the internet and the evolving Internet of Things (IoT) threat landscape. Avast also offers products
which allow users to optimise their devices and online experience. Avast believes that every online user
deserves a safe online experience and therefore provides its core antivirus products, Avast Free Antivirus
and AVG Antivirus Free, for free, while offering additional security features in premium product versions.
Avast’s portfolio also includes virtual private network (VPN), anti-track and device optimization solutions. In
2021 we acquired Evernym, which build and deploy self-sovereign identity solutions which aim to put
consumers in control of their data and enable people and organizations to benefit from a safer and moretrusted internet.
In 2018, Avast plc became a publicly listed company on the London Stock Exchange and was admitted to
the FTSE 100 index in June 2020. As of June 2022, we have more than 1,900 employees in 26 offices in
16 countries ((Australia, Czech Republic, Germany, Hong Kong, Italy, Japan, Netherlands, Romania,
Russian Federation, Serbia, Slovakia, Switzerland, Taiwan, United Kingdom, the United States, andCanada). When contingent workers and contractors are taken into account, the number of people working
with Avast is in excess of 2,000.
Our culture at Avast can be described based on the 5 A’s Principles: Adult relationships based on mutual
trust, transparency and maturity), Accountability, Achievement focused, Autonomy and Asynchronousworking. We offer high levels of flexibility, with many staff on work from anywhere contracts.
More information about our company structure, subsidiaries and the locations where we operate can befound in our Annual Report available at: Results, reports and presentations | Avast

1.3.

Our Supply Chain

Our supply chain includes our business partners, third party suppliers, manufacturers, resellers anddistributors (“supply chain”). The global nature of our operations mean our supply chain operates across
many markets and continents including Asia, Europe, South America, Central America, North America andAfrica. Whilst Avast operates in an industry where the risk of modern slavery and human trafficking is
generally considered to be low, we recognise the inherent modern slavery risks that can exist within supply
chains, particularly in geographies that have limited modern slavery and human trafficking regulations inplace. Our top five highest spend supplier categories in 2021 were Sales Commissions and Fees, Paid
Search, Marketing, Consultancy and Professional Services, and Distribution of Digital Content.

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2. Policies
We have developed various policies to support Avast conduct its business in an ethical and transparent
manner and identify and mitigate the risk of slavery or human trafficking within our business and supply
chain. Our policies are available to staff through our intranet, and some of our ethical or external facing
policies are also published on our website.
During 2021 we circulated key policies amongst all Avast staff, including our Modern Slavery Policy,
Whistleblowing Policy, Code of Conduct, and Sanctions and Anti-Money Laundering policy, amongst
others. More details are provided in Section 5 of this Statement.

PolicyAvast Supplier Guidelines

Summary
The Avast Supplier Guidelines set out the social, ethical andenvironmental standards and expectations for our supply
chain. These guidelines encapsulate the principles which we
abide by and uphold. We expect our partners, suppliers andcontractors to uphold the standards along with the laws, rules
and regulations of the countries in which they operate. By
abiding by the guidelines, our suppliers take responsibility forwhomever they subcontract with to ensure that all of our
supply chain is covered.
The guidelines are based on international standards including
the United Nations Guiding Principles on Business andHuman Rights (UNGP), the Ethical Trading Initiative Base
Code (ETI), the Responsible Business Alliance Code of
Conduct (RBA), the Universal Declaration of Human Rights(UDHR) and International Labour Organization Declaration on
Fundamental Principles and Rights at Work (ILO Declaration).
We expect our suppliers to take reasonable steps to monitor
their business and supply chains to ensure compliance withall applicable laws and regulations.

Modern Slavery Policy

Code of Conduct

Grievance Procedure

Avast Modern Slavery Statement

Our Supplier Guidelines are available on our website and canbe accessed in over 30 languages: Avast Supplier Guidelines
We have an internal modern slavery policy which states ourcommitment to respect human rights in all our operations andbusiness dealings and is designed to ensure that Avast
complies with the applicable laws in the jurisdictions in which
Avast operates, and with relevant international standards.
Our Modern Slavery policy is posted on the Avast website,
accessed here: Modern slavery policy | Avast
We have a Code of Conduct which lays out the principles all
our staff must follow and sets the foundation for how we work
together, treat our customers and operate responsibly within
a set of diverse markets and constraints. In particular, it
outlines our business ethics as well as how to select and workwith our suppliers. We have procedures in place foraddressing breaches of the Code of Conduct in a timely andconsistent manner.
We have a Grievance Procedure in place which outlines theprocess for raising a grievance within Avast. All Avast
employees can use the process described in this document toraise concerns or problems with Avast management. This
includes concerns about work, working conditions or amanagement decision or action affecting employees’ work or
employment rights, and could be used to raise concerns
regarding modern slavery. The guidelines aim to ensure thefair and consistent treatment of employees worldwide
irrespective of the issue raised.
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Recruitment Policy

Avast adopts international standards in its recruitment of staff,
including the Employer Pays Principle and requires its
business partners to adhere to labour, health, safety andemployment laws in the countries in which they operate, andto ensure that they have or put in place measures to prevent
and address modern slavery.
Our Recruitment Policy sets out responsibilities forrecruitment within Avast, and our commitment to fairness andconsistency of application, clarity and transparency ofprocesses, and equitable treatment.

Sanctions and Anti-Money
Laundering Policy

Whistleblowing Policy

Purchase to Pay (P2P) Policy

Our Sanctions and Anti-Money Laundering Policy is designed
to ensure that Avast has risk-based policies, procedures andinternal controls in place to detect and prevent the use of
Avast to facilitate money laundering, terrorist financing andother illegal activities.
We encourage all of our employees, customers and otherbusiness partners to report any concerns related to theactivities or the supply chains of Avast. This includes any
circumstances that may give rise to an enhanced risk ofslavery or human trafficking. One of the principles
underpinning our procedure is rights-compatible, whichmeans ensuring that outcomes and remedies are in line withinternationally recognised human rights.
Our whistleblowing procedure is designed to make it easy for
employees to make disclosures, without fear of retaliation. In
addition to internal channels we also have an externalreporting hotline.
Our Purchase to Pay policy sets out the roles andresponsibilities for end-to-end purchase to pay processes
within Avast, along with our supplier selection criteria andcontract management requirements.

3. Risk Assessment, Prevention and Mitigation
In 2019 we commissioned an external provider to conduct a risk assessment of our business activities andbusiness relationships to identify our modern slavery risks and to understand how existing policies andprocesses for preventing, addressing, and managing modern slavery compares to international bestpractice. This assessment was guided by the Global Slavery Index which categorize vulnerabilities tomodern slavery by looking at governance issues, lack of basic needs, inequality, disenfranchised groups
and effects of conflict.
The assessment generally found that Avast has a governance foundation for addressing risks of modern
slavery that can be improved by aligning with international good practices. The profile of business activities
and relationships indicates a low likelihood of modern slavery occurring but relationships in higher-riskcountries performing higher-risk activities exist. The findings from this review informed the development ofa risk-based due diligence and supplier engagement methodology, which is outlined in Section 4 of thisStatement.
We have outlined what we consider to be some of the key modern slavery risk areas for our businessbelow, both in our supply chains and operations.

3.1.

Operations

Avast employs people in different countries around the world, many of whom are on work from anywherecontracts. We offer a flexible workplace and trust our people to deliver. Whilst this brings many benefits forour staff and organization, we recognize the risks that come with having decreased visibility of our people.
For example, it can be harder to support staff wellbeing when working remotely, and people may feel lessable to speak up if they have any concerns. To mitigate this, we require all new staff to read our key
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organizational policies when they join Avast, including our Code of Conduct and Whistleblowing policy
which provides different mechanisms for staff to raise any concerns.
We recognize that recruitment and human resources practices can expose Avast to increased modern
slavery risk. This includes the use of contingent workers, where modern slavery risk can occur due to
Avast not having direct oversight of employment conditions within the labour agency, as well as use ofrecruitment agents, which pose a particular risk for the recruitment of migrant workers who may be subject
to debt bondage. To mitigate these risks, we require all suppliers, including labour and recruitment
agencies, to sign up to our Supplier Guidelines which set our expectations around labour and working
conditions. In 2022 we will be conducting an audit of our Human Resources and Payroll practices.

3.2.

Supply Chain

The risk assessment identified that 91% of Avast’s business relationships are likely lower risk based on
headquarter locations in countries with strong performance in the Global Slavery Index. The assessment
also found that relationships in business operations such as office facilities management, catering, travel,
and hospitality are potential sources of directly linked risks based on the types of activities and sectors
involved.
Laptops, computers and mobile phones have been identified by the Global Slavery Index as one of the top
five products at risk of modern slavery by value imported to G20 countries, with China and Malaysia
identified as two higher risk source countries1. We are cognizant that not only is the sourcing of theseproducts a material area of risk for Avast, but that as part of the global supply chain ourselves, ourproducts may be integrated into a supply chain which is at risk of modern slavery or human trafficking. We
have included these products and sourcing countries in our list of those posing a higher risk within our due
diligence methodology, which informs how Avast might engage with relevant suppliers.
We recognise that Avast may also be exposed to risks of modern slavery further down our supply chain,including through the raw materials that go into the products we buy. Conflict minerals, defined by US
legislation as tantalum, tin, tungsten and gold or their ores, pose an additional risk for the technology
sector due to their usage as raw materials for a number of electronic products2. Through our Supplier
Guidelines we require all suppliers to comply with all applicable conflict minerals regulations and to source
responsibly.

4. Due Diligence Processes
4.1.

Due Diligence Approach

Our due diligence approach has been developed by our Legal and Procurement functions and aims toembed controls for modern slavery risks within our purchasing activity. Our process includes the following
activities:

1
2•

Supplier onboarding: we require all new suppliers to sign our Supplier Compliance Document,
which requires our suppliers to uphold the principles in the Avast Supplier Guidelines or have inplace their own codes of conduct and modern slavery policy that are aligned with international
standards. Our Legal Team assesses all signed Documents and reviews our suppliers’ policies, if
needed, to ensure that these conditions are met.

•

Existing suppliers: over the last year, a large part of our focus has been to engage with existing
suppliers through rolling out our Supplier Compliance Document. By the end of 2021,
approximately 50% of our active vendors had signed the Supplier Compliance Document. Where
suppliers had queries regarding these documents representatives from either our Legal,
Procurement or Sales Operations functions engaged with them directly to work through any
concerns and ensure a mutual understanding. Our target is for all suppliers to go through thisprocess.

•

Higher-risk suppliers: we have developed a Supplier Questionnaire to issue to higher-risk suppliers
that must be answered within 10 working days. This includes questions around employment

6_Importing-Risk-1653664593.pdf (globalslaveryindex.org)
Technology and conflict minerals | Ethical Consumer
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practices, recruitment practices and working locations. Our criteria for issuing this questionnaire isthat a supplier must fall within a pre-determined list of both high risk category (sector or product),and high risk country. At present we do not have any suppliers that meet this criteria.

4.2.

Audit and Investigation

We recognise that monitoring our suppliers is crucial in our efforts to identify and address modern slavery
risks. Through contractual reporting obligations, we require our suppliers to inform us of modern slavery
incidents which have occurred in their business, and which affect us, so we can work with them to remedy
the issue and prevent the situation from occurring again.
We may audit our supply chain as part of our due diligence process and where we reasonably suspect thatmodern slavery, human trafficking or other breaches are or may be occurring within our business or supply
chain, we reserve the right to investigate such concerns. This may include announced or unannounced
onsite visits to Company’s facilities by our employees or agents, including but not limited to third-party
auditors, to monitor and verify compliance with these Guidelines. We may ask for access to information
relevant to monitoring modern slavery, human trafficking and other risks, including but not limited to,employment contracts, recruitment agency contracts, records of wages, time worked, and confirmation of
payment. We have not had the need to conduct such audits in the reporting year.
If necessary, we may work with the supply chain partner to implement corrective action plans incollaboration with top-level management to address and resolve any identified issues. However, in caseany single serious or persistent breaches of the applicable laws, statutes and regulations in force may
result in termination of the contractual relationship and/or reporting to the relevant authorities by Avast.
We also recognise the importance of providing reporting mechanisms where any concerns relating tomodern slavery or human trafficking in our supply chain or operations can be raised discreetly and without
fear of retaliation. Our whistleblowing policy provides details of how all Avast employees, or any otherperson associated with Avast, can raise concerns regarding illegal or unethical behaviour. We have anumber of reporting mechanisms in place, including a 24-hour Avast Ethics & Reporting Line and a
Whistleblowers’ Hotline. We remind our employees that they can also report any concerns outside of thecompany by contacting the UK Modern Slavery Helpline on 0800 0121 700, accessible athttps://www.modernslaveryhelpline.org/. We have not had any reports of modern slavery incidents in our
supply chain during the reporting period. In 2022 we will be reviewing and updating our Whistleblowing
policy to ensure it aligns with best practice.

5. Training and Capacity Building
Training our staff on modern slavery is crucial to ensuring that they are aware of higher risk areas for ourbusiness, how these might relate to their role, and to increase awareness on the issue more widely.
In 2021, as in the previous year, we conducted a campaign to raise awareness of our key policy
documents, including our Modern Slavery Policy, amongst all Avast staff. All new joiners, as part of theirinduction, are directed to our intranet which outlines our policies and approach to tackling modern slavery.
Our Procurement and Sales Operations teams, who have been engaging with suppliers on modern slavery
as part of the Supplier Compliance Document rollout, were provided with more in-depth training. This wasdelivered by our Legal team and provided attendees with an overview of modern slavery, information onrisks and red flags, and details on how participants can manage risk. Our Legal team have also provided
training to our Procurement function to enable them to train staff called Requestors across the business
who have the ability to procure goods or services for their teams. These staff were also provided withcopies of relevant documents and content relating to Avast’s approach to modern slavery. This ensuresthat our people are cognisant of modern slavery risks when conducting procurement activities.

6. Measuring Effectiveness and Consultation
The General Counsel together with the Internal Audit team has overall responsibility for ensuring ourModern Slavery policy complies with our legal obligations, and that Avast staff and others under ourcontrol comply with it.
We have tracked engagement with our key policy documents for modern slavery, both amongst our staff
as well as our supply chain:
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For our staff, our policy campaign has allowed us to monitor how many employees havecompleted a review of key policies, including modern slavery. Moving forwards, this information
will be collected for new joiners.

•

For our supply chain, we have continued the rollout of our Supplier Compliance Document and aretracking progress to ensure we have a complete record of all suppliers that have signed up to thisprocess, and those where engagement remains ongoing.

7. Close
As a global business, we recognise the importance of not only complying with applicable regulations andcustoms everywhere we operate, but also considering our opportunities to have a positive impact. This
includes the work of the Avast Foundation, which aims to work with people and communities across theglobe to remove barriers to digital freedom. More information is available on the website: Avast Foundation
News & Media.
We are pleased with the progress we have made to mitigate the risks of modern slavery with our businessand supply chain but recognise, like many other organisations, we can and must do more. Looking ahead,our priorities for next year include a refresh of our risk management process. This will involve the design
and implementation of a new risk and compliance framework, along with development of a third-party risk
management framework. We plan to take this opportunity to review our current governance and approach
to modern slavery to ensure we are able to embed this within our revised risk management approach,enhancing our ability to monitor effectiveness of actions taken both to assess and address our risks.
This statement has been approved by the Board of Avast plc on behalf of itself and its relevant
subsidiaries Avast Software s.r.o., and Piriform Software Limited.

Ondrej Vlcek
CEO
June 2022

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