###### Trust and Ethics
Upwork's corporate codes, policies, and guidelines are anchored by our commitment to uphold integrity, transparency, and ethical business practices. We maintain the highest standards of ethical conduct and accountability in all areas of Upwork's business. We regularly review and update our policies to align with best practices and applicable laws. In 2024, we fine-tuned our Code of Business Conduct and Ethics as well as other policies to ensure compliance with evolving regulations.
Key Trust and Ethics Policies
• Code of Business Conduct and Ethics
• Anti-Corruption Policy
• Whistleblower Policy
• Privacy Policy
• Mindful AI Principles
• Human Rights Commitment
• Global Environmental Policy
• Supplier Code of Conduct
• Corporate Governance Guidelines
• Upwork Terms of Service
• Insider Trading Policy
###### Ethics and Compliance
We offer an annual voluntary training program, Speak Up, that complements our Code of Business Conduct and Ethics. The training guides team members in embodying Upwork's core values and defines expectations for behavior and our responsibility to the platform's community. We updated the format of the Speak Up Training in 2024 to encourage open discussion, questions, and comments from attendees.
Upwork requires mandatory annual trainings for all team members, including full-time employees and independent team members, on critical areas such as Cybersecurity Awareness, Data and Privacy Protection, and Anti-Money Laundering (AML). Employees are also required to take Sexual Harassment Compliance training. New team members are assigned these trainings on their first day and have 30 days to complete them, after which they remain compliant for the rest of the calendar year. In 2024, we enhanced tracking to ensure we achieved a 100% completion rate across all mandatory training programs, with our employees completing approximately two and a half hours of mandatory compliance training per year.
###### Ethics Governance and Reporting
Upwork's Compliance Officer and the Ethics Task Force, are responsible for ensuring that all team members are well-informed about our Code of Business Conduct and Ethics, keeping it up-to-date and integrated across our operations. The Compliance Officer also serves as an Ethics Advisor (EA) and can be reached, along with the other members of the Ethics Task Force, via email at ethics@upwork.com.
The Audit, Risk, and Compliance Committee of the Board of Directors oversees matters related to business ethics. The Compliance Officer updates the Audit Committee and greater Board on a regular basis. The Nomination and Governance Committee oversees any waivers of the Code for officers and directors.
Upwork's workforce and other community stakeholders can report ethics concerns through Vault's Open Reporting platform. All reports can be made anonymously. Employees can also submit reports via the mobile app or report their concerns directly to a manager, member of leadership, legal, human resources, or one of Upwork's EAs. Once reports are submitted, Upwork conducts a thorough investigation and takes appropriate action.
--NEW-PAGE--
###### We track the number of reports annually and report this information to our Board to ensure we are effectively addressing ethics reports and other HR-related issues. This helps decrease non-compliance with our Code, Anti-Corruption Policy, and other ethics policies.
Anti-Corruption
Upwork adheres to the most stringent ethics standards, conducting and complying with global anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. In 2024, we updated our Anti-Corruption Policy to reinforce our zero-tolerance approach towards bribery and improper payments, prohibiting any actions that could influence business or policy decisions. This policy applies to and is shared with all employees, contractors, and third-party representatives. It details prohibited conduct, such as bribery of government officials and other third parties. To ensure compliance, we provide annual training on anti- corruption that is integrated into our Speak Up and Anti-Money Laundering programs.
We continually assess and manage bribery and corruption risks. In 2024, we enhanced our due diligence processes for third- party relationships to prevent
unethical conduct. This bolstered our ability to track and document all transactions more thoroughly. Our Payment Risk team plays a crucial role in preventing payment fraud, including fraud chargebacks and payment protection fraud. Upwork also monitors suspicious activities to detect scams and account takeovers. Employees can report concerns through Vault or directly to the Compliance Officer. These efforts are aligned with our ongoing focus on anti-money laundering, with all suspicious activities reported via the internal AML Suspicious Activity Referral form. Suspicious activity can include transactions that serve no business or apparent lawful purpose, transactions that are unusual for the customer with no reasonable explanation, customers presenting altered or false identification, and any other transaction that may involve possible criminal activity.
###### Public Policy and Advocacy
Upwork champions the interests of small businesses, including freelancers as business owners, on both sides of our marketplace
###### We strive to make work more inclusive, advocating for policies that empower freelancers and small businesses to thrive. Rather than investing significant resources in lobbying efforts, Upwork's public policy and government relations team focuses on educating policy leaders about our business model and advocating for regulations that support small business and freelance job growth.
Our policy work often connects us with other impact-driven companies. In 2024, as part of our ongoing commitment to responsible business practices, we partnered with Responsible Business Alliance (RBA) member companies on a RBA Pilot of Responsible Sourcing of AI Data Enrichment Work. This collaboration focuses on building and testing the feasibility of a supplier survey to evaluate human rights risks tied to data enrichment work. The project helps the RBA strengthen its tools to ensure that workers across the data enrichment industry are treated with respect and dignity.