Qualtrics Modern Slavery Statement 

This statement is made by Qualtrics, LLC (“Qualtrics”) on behalf of itself and its affiliates, for the financial year ended January 31, 2025 under s.54 Modern Slavery Act 2015.  It sets out the steps taken during that financial year to prevent modern slavery and human trafficking in our business and supply chains.

Qualtrics is committed to conducting its business with the highest ethical standards and integrity. We have a zero-tolerance approach to all forms of modern slavery, which include forced or compulsory labor, debt bondage, human trafficking, and child labor. We are dedicated to ensuring that modern slavery and human trafficking are not present in any part of our business operations or supply chains. 

Our Business, Structure and Supply Chains

Qualtrics is a global software-as-a-service company providing experience management solutions. Our primary operations include software development, hosting and support services, and professional services. We operate globally with UK operations carried on by QUL Technologies Limited. Our supply chains include:

  • Cloud and data center hosting and other IT infrastructure and managed services. 
  • Software vendors and professional services. 
  • Hardware and peripherals procurement, logistics and distribution. 
  • Facilities management, including cleaning, catering, security and office services. 
  • Recruitment and labor providers, and contingent workforce suppliers. We recognize heightened risks in facilities services, recruitment and labor provision (including migrant worker recruitment), certain construction/fit-out and logistics activities, and hardware supply chains in higher risk geographies.

Policies and Governance

Our approach is underpinned by policies that promote ethical behavior, including:

  • Qualtrics Code of Ethics and Business Conduct
  • Supplier Code of Conduct
  • Partner Code of Conduct 

Overall accountability, and day-to-day implementation, sits with the Qualtrics Compliance team, with oversight from the Audit Committee of the Qualtrics Board of Directors. 

Due Diligence & Prevention

To mitigate risks related to modern slavery, Qualtrics will:

  • Supplier Vetting: Implement robust vetting processes for new suppliers and business partners, including questionnaires, audits, and third-party assessments where appropriate, to evaluate their commitment to combating modern slavery.
  • Contractual Clauses: Include specific clauses in our contracts requiring suppliers and partners to comply with all applicable laws and Qualtrics policies.

Reporting Mechanisms & Remediation

We encourage all personnel and external stakeholders to report any concerns or suspicions of modern slavery or human trafficking without fear of retaliation.

  • Internal and External Reporting: Personnel and external parties can report concerns to the Qualtrics Compliance team at compliance@qualtics.com or via our whistleblower hotline at ethics.qualtrics.com 
  • Confidentiality and Non-Retaliation: All reports will be treated confidentially, and no individual will suffer any detrimental treatment as a result of reporting a genuine concern in good faith.

Any breach of Qualtrics’ policies will be taken seriously and may result in disciplinary action, up to and including termination of employment or contract. Supplier breaches may result in corrective action requirements, enhanced oversight, suspension of new business, and where necessary, responsible disengagement Qualtrics will investigate any allegations of modern slavery and determine if remedial actions are necessary.

Dated: May 14, 2026