Lightcast

The UK Modern Slavery Act 2015 (“MSA”) requires large organizations doing business in the United Kingdom to publish a disclosure statement (this “Statement”) detailing the steps being taken to monitor and address the risks of “slavery and human trafficking” in its business and supply chains. In this Statement, we use the term “modern slavery,” which includes slavery, servitude and forced or compulsory labor and human trafficking, all of which are abuses of a person’s freedoms and rights.

Burning Glass Intermediate Holdings Inc. (“Lightcast”) carries out business in the United Kingdom through Economic Modeling LLC, along with other affiliated companies (collectively, “Lightcast” or “we”).

This Statement is made in accordance with Section 54 of the MSA. Lightcast is committed to ensuring that as far as we can be aware modern slavery does not take place in any part of our business or our supply chains in line with the principles and goals advocated in the MSA and related guidance. The same policies and procedures, due diligence, risk assessment, monitoring and training pertaining to modern slavery are employed across Lightcast. The statement has been prepared for the most recent financial year, ending 31 December 2022.

We provide consulting and  labor market data via our SaaS solutions to customers in government, higher education, and private industry. We employ over 600 professionals who do business across the globe, including Europe. 

Though we are very serious about the subject, we believe that the risk of modern slavery in our workforce is remote. Our workforce consists almost entirely of skilled professional employees. We maintain rigorous hiring practices and we have full transparency with respect to employment practices due to the size of our workforce.

As discussed further below, we also believe that the risk of modern slavery at our vendors and suppliers is minimal. Given the nature of our business, we do not sell physical goods for which components or raw materials are sourced.

Lightcast dedicates resources to ensure that it operates according to best practices for environmental, social, and governance (“ESG”) matters, including human rights broadly and modern slavery specifically. We believe that careful attention to these factors makes good business sense. 

We have general policies that provide for fair treatment of workers and compliance with law and set forth the business standards by which all Lightcast personnel are expected to conduct business. We have incorporated specific modern slavery policies into our general policies for personnel, which are distributed internally to all employees. We review our policies regularly to ensure they reflect legal and regulatory requirements, while containing appropriate standards for all Lightcast personnel.

The Lightcast Employee Handbook (the “Handbook”), which is updated annually, summarizes policies and procedures established for the benefit of Lightcast employees. The Handbook affirms that Lightcast has a zero-tolerance policy towards the use of modern slavery in its business. The Handbook encourages Lightcast personnel, with any suspicion that any improper conduct related to Lightcast or its supply chain has occurred or is occurring, to notify a manager or report it in accordance with the Whistleblowing Policy. 

We have a grievance mechanism, including a whistleblowing policy, for personnel to report violations of law or our policies. Third-parties are encouraged to contact us using the contact information on our website. It is important that individuals working for us and our suppliers feel comfortable and supported when reporting suspected legal violations or breaches of our policies. Lightcast’s Whistleblowing Policy offers protection to personnel who report suspected wrongdoing.

We may terminate relationships with individuals and organizations working on our behalf if they breach policies with respect to anti-slavery.

To assess the risk of modern slavery in our business and our supply chains, we have considered the type of business we undertake and our supply chains, including our employment practices and our procedures for the selection and approval of third-party vendors.

In addition, Lightcast reviews supply chains for areas of risk or concern, including vendors in higher risk geographies or offering higher risk types of services. Lightcast ensures that diligence questionnaires for critical vendors are completed, reviewed, and approved. 

Our key vendors include professional services firms, such as legal, investment banking, accounting and other consulting firms, and providers of research and data, software and information technology services. Given the nature of the services provided, we believe that the risk of modern slavery at these vendors is minimal.

To a lesser extent, we utilize other services such as food, cleaning and car services, and purchase off-the-shelf goods such as technology equipment, stationery, office furniture and certain merchandise branded with the Lightcast name or logo. With respect to the services that they provide to us, we believe that the risk of modern slavery at these vendors is low in part due to the geographic location of performance. Given the limited nature of our business relationships with these vendors, we do not have the practical ability to assess each of their employment practices or supply chains.

To help ensure that vendors are aware of our policies and expectations relating to modern slavery, this Statement is available to our vendors on Lightcast’s website. In turn, when negotiating terms of vendor agreements, we request the addition of anti-slavery warranty wording that states that all goods and services furnished are free of slavery, forced, prison or compulsory labor, human trafficking and child labor. We also have the grievance mechanisms described earlier in this Statement.

We are not aware of any incidents of modern slavery in our supply chains. If cases of non- compliance are uncovered, Lightcast will determine the appropriate course of action on a case-by- case basis. In cases where non-compliance cannot be resolved to Lightcast satisfaction, it may terminate the arrangement with the vendor.

Lightcast will monitor progress of its efforts in complying with applicable laws and regulations relating to modern slavery, and issues, should they arise, which may include key performance indicators (“KPIs”) reported annually to Lightcast’s Board of Directors.

As noted in section 4, Lightcast personnel are required to report known incidents of modern slavery. We continue to raise awareness and educate personnel and suppliers about our policies and procedures relating to modern slavery. Lightcast personnel are encouraged to bring any questions or concerns pertaining to policies or compliance with them to designated internal personnel.

Through internal meetings and formal approval of this Statement and the relevant policies and procedures, we have educated personnel about modern slavery risk and our related policies and procedures.

This Statement has been approved by Lightcast, on the 4th of August 2023, and signed by the undersigned as an authorized representative.

Burning Glass Intermediate Holdings, Inc.

Approved: August 4, 2023

By: Ben Comin, General Counsel