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Canadian Statement Against Forced Labour and Child Labour in Supply Chains

pursuant to an Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff, referred to as Canada’s “Modern Slavery Act” (the “Act”) for January 1, 2025 to December 31, 2025

1. INTRODUCTION

This is a statement made by Hootsuite Inc. in respect of the Act, as referenced above. Hootsuite Inc. is a corporation incorporated pursuant to the laws of Canada.

2. REPORTING ENTITY

This report is being filed on behalf of Hootsuite Inc.

3. STRUCTURE, ACTIVITIES AND SUPPLY CHAINS

Hootsuite is the leading enterprise solution for social intelligence. Hootsuite unifies social listening, publishing, engagement, and analytics to help organizations connect social strategy to business impact.

Hootsuite Inc. is the ultimate parent company of Hootsuite and is headquartered in Vancouver, Canada. We operate and have subsidiaries all over the world.

Hootsuite remains vigilant and monitors the level of risk involved through any of our supply chains and will take appropriate measures if a higher risk of modern slavery is deemed to exist.

  • Hootsuite’s business focuses on the provision of a software-as-a-service platform and professional services. There is no traditional manufacturing of products or “goods”.

  • Hootsuite uses a limited number of outside consultants and contractors. Any such use is limited to the provision of professional services (e.g., software development).

  • Our vendors are typically hosting or other cloud service providers, as is usually the case for software-as-a-service businesses.

  • We import a limited number of goods into Canada from one supplier: Apple. This supplier holds its suppliers accountable, reports transparently, and regularly engages experts.

  • Our vendors are generally located in jurisdictions where we do not consider there to be a high risk of modern slavery, such as the United States.

  • We ensure we have a robust recruitment process - our HR teams ensure that employees have the requisite authorisations to work in the applicable location.

Overall, and on the basis of the above, Hootsuite does not consider that there is a significant risk of modern slavery existing in our supply chain.

4. POLICIES AND DUE DILIGENCE PROCESSES IN RELATION TO FORCED LABOUR AND CHILD LABOUR

We have implemented policies as part of our commitment to ethical business practices. In addition to our Respectful Workplace Policy, we also have in place a Code of Ethics which requires employees of Hootsuite to conduct business in a way that is fair, ethical and honest and in compliance with all applicable laws and regulations. 

Our Respectful Workplace Policy provides that employees of Hootsuite must:

(i) treat co-workers with dignity and respect;

(ii) not engage in, and prevent workplace discrimination and harassment from occurring; and

(iii) report unresolved incidents of inappropriate workplace behaviour. 

In addition to requiring that all employees review and acknowledge our Respectful Workplace Policy on an annual basis, we also ensure compliance with all applicable employment legislation relating to employee recruitment and terms and conditions, including obtaining right to work evidence and ensuring that no staff in our global offices are paid less than the applicable national minimum or living wage.

We also expect all of our contractors, suppliers and other business partners to uphold the same high standards that we do, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment. We endeavour to review potential areas of risk in relation to our business and, where applicable, consider the nature of what is being supplied and the location from where it is being supplied.

We also have a Vendor Code of Conduct (the "Code") which outlines our expectations regarding the practices and values that our vendors should comply with in order to engage with Hootsuite. The Code is not intended to limit or exclude any other legal or contractual obligations that vendors may owe to Hootsuite. The Code should be viewed as a set of minimum standards expected from the Hootsuite vendor community to ensure vendors share Hootsuite’s commitment to human rights and equal opportunity in the workplace.

5. PARTS OF BUSINESS AND SUPPLY CHAINS THAT CARRY A RISK OF FORCED LABOUR AND CHILD LABOUR AND STEPS TAKEN TO ASSESS AND MANAGE THAT RISK

As described under section 3, Hootsuite does not currently consider the business it carries on or its supply chains to carry a significant risk of forced labour or child labour. While our primary business is software-as-a-service, we do, however, recognize that latent risks may exist further down our supply chain in the production of hardware and electronics used in our global offices. Hootsuite remains vigilant and monitors the level of risk of our supply chains and will take appropriate measures if a higher risk of forced labour or child labour is deemed to exist.

6. MEASURES TAKEN TO REMEDIATE FORCED LABOUR AND CHILD LABOUR

This section is not applicable as Hootsuite has not identified any instances of forced labour or child labour in its supply chain.

7. MEASURES TAKEN TO REMEDIATE LOSS OF INCOME TO MOST VULNERABLE FAMILIES THAT RESULT FROM MEASURES TAKEN TO ELIMINATE USE OF FORCED LABOUR AND CHILD LABOUR

This section is not applicable at this time.

8. TRAINING PROVIDED TO EMPLOYEES ON FORCED LABOUR AND CHILD LABOUR

It is important to us that our employees are aware of the issues surrounding modern slavery and support our values. We address these values in our Code of Ethics, which all employees review and sign. We are also working with relevant employees to reinforce any steps that should be taken and to remind them of the channels through which any concerns can be reported.

9. HOW ENTITY ASSESSES ITS EFFECTIVENESS IN ENSURING THAT FORCED LABOUR AND CHILD LABOUR IS NOT BEING USED IN ITS BUSINESS AND SUPPLY CHAINS

While we continue to refine our assessment frameworks, we currently ensure effectiveness through several key mechanisms, including:

  • Our Legal team regularly reviews our Vendor Code of Conduct and other pertinent policies to ensure they remain current with applicable Canadian and international employment legislation.

  • Our Procurement and Legal teams conduct reviews of all new high-value vendor contracts and are aware of our internal standards and Code of Ethics.

  • We maintain ongoing visibility into our primary suppliers, such as Apple and AWS, who maintain their own transparent reporting and supplier accountability programs.

ATTESTATION 

This report was approved by the Board of Directors of Hootsuite Inc. pursuant to Section 11(4)(a) of the Act.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above. For clarity, I am providing this attestation in my capacity as a director and officer of Hootsuite Inc., and not in my personal capacity.

HOOTSUITE INC.

_________________________________

Full Name: Ryan Holmes

Title: Interim Chief Executive Officer

Date: April 10, 2026

Authorization: I have the authority to bind Hootsuite Inc.

Click here to consult our UK and Australia Modern Slavery Act Transparency Statement