Modern slavery statement

MODERN SLAVERY STATEMENT

Introduction This Modern Slavery Statement (“Statement”) is prepared in accordance with the requirements of both the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 (Cth) (together referred to as the “Acts”). The Acts create offences in respect of slavery, servitude, forced or compulsory labor, and human trafficking (“Modern Slavery”). ON24, Inc. and its subsidiaries (“ON24,” “Group” or “we”) are committed to improving our practices to combat Modern Slavery and to ensuring that our business and supply chains are free from the same. This Statement highlights our activities to combat Modern Slavery in our organization and supply chain during the financial year ending on December 31, 2024.

Reporting entity

The reporting entity for this statement is:

ON24, Inc.
50 Beale Street, 8th Floor
San Francisco, CA 94105

Other entities of the Group currently do not meet the reporting requirements.

Organization’s structure

ON24, Inc. is the parent company of the Group and is incorporated under the laws of the State of Delaware and headquartered in San Francisco, California in the United States of America. The Group has over 400 employees worldwide.

Other entities of the Group include the following:

Our business

ON24 is a leading intelligent engagement platform that automates continuous engagement. We enable customers to combine best-in-class experiences with personalization and content, to capture and act on connected insights at scale. We provide data-rich digital experiences through a range of mediums, including hosting live or on-demand virtual events, developing personalized webinars, and creating AI-generated reports, videos and blogs. Our technology captures audience interaction in real-time, analyses it and feeds it back to customers, helping businesses bring their go-to-market strategy into the AI era and drive cost-effective revenue growth. To learn more about ON24, click here.

Our customers vary in size, from small businesses to global Fortune 500 organizations. They also span numerous sectors, including software, asset management, healthcare and manufacturing,

Our business focuses on the provision of software (SaaS) and professional services. We do not “manufacture” our products and solutions, at least not in the traditional meaning of that word (i.e., with workers and machines in factories), nor do we directly engage third parties to perform any such manufacturing on our behalf.

Given the nature and location of ON24’s business and operations, along with our globally applicable compliance policies described below, we consider the risk of Modern Slavery arising in our operations to be low.

Our supply chain and Modern Slavery risks

ON24 has active relationships with hundreds of suppliers globally, including in Europe and APAC, however the vast majority are based in the United States. As a SaaS company, our largest vendors are software and service providers, which supply marketing, technology, and other professional services. We have limited exposure to high-risk industries such as manufacturing or construction. We use equipment that is sourced from highly respected and established companies who themselves have high standards with respect to preventing Modern Slavery.

We expect suppliers and other third parties to comply with all applicable laws and are committed to ensuring that our business and supply chains remain free of Modern Slavery. We do not operate directly in environments where there is a high risk of human rights violations or of forced or compulsory labor.

Given the nature of our supply chain, along with our vendor policies and due diligence described below, we consider the risk of Modern Slavery arising in it to be low.

Relevant policies and procedures

Code of Business Conduct and Ethics

Our Code of Business Conduct and Ethics (“ON24 Code”) reflects our commitment to conducting business with honesty and integrity wherever we operate and requires employees to act fairly and ethically in all that they do. Should we be made aware of any policy violations or issues related to a violation of the ON24 Code, we will immediately assess and determine what further action is needed. Click here to read the ON24 Code.

Human Rights Policy

Our Human Rights Policy explains our commitment to human rights and the steps we take to help realize this vision. If we were to identify adverse human rights impacts resulting from or caused by our business activities, we are committed to providing for, or assisting in providing for, equitable remediation. We also expect our partners, vendors and suppliers to honor these principles in their business operations. Click here to read the ON24 Human Rights Policy.

Independent whistleblowing hotline

We have an independent system in place to encourage any reporting of concerns and the protection of whistleblowers. ON24 employees, partners and suppliers may access the anonymous and confidential reporting system online or by calling the toll-free numbers as listed in the ON24 Code. All reports are notified immediately to the heads of Finance, HR, and Legal (the “Compliance Team”), who ensure that reports are followed up and appropriate actions are taken. Our Audit Committee is provided with the details of reports made and reviews how those reports are handled.

Vendor Code of Conduct

Our Vendor Code of Conduct (“Vendor Code”) sets out details of the behaviors and principles we expect our suppliers and partners to follow including in respect of ethics and integrity, compliance with laws, anti-bribery and corruption, hospitality and gifts, health and safety, environmental matters, and human rights and slavery. Should we be made aware of any policy violations or issues related to Modern Slavery, we will immediately assess and determine what further action is needed. Click here to read the ON24 Vendor Code.

Anti-Bribery & Anti-Corruption Policy

We have an Anti-Bribery & Anti-Corruption Policy (“ABAC Policy”) that states third-party representatives of ON24 are responsible for the prevention, detection, and reporting of bribery in any part of our business or supply chain. The ABAC Policy requires adherence to high ethical standards and compliance with applicable laws, and it expressly prohibits the use of third parties to effect bribery and corruption violations. Click here to read the ABAC Policy.

Due diligence processes for Modern Slavery

We are committed to engaging in business practices to combat Modern Slavery and ensuring transparency within our business. ON24 has a Company-wide procurement policy in place and undertakes due diligence when evaluating new suppliers, including restricted party screenings for prospective suppliers. New suppliers onboarded by the Procurement Team are required to comply with the Vendor Code.

Recruitment practice

All prospective employees and contractors undergo a background check and screening process. Our human resources processes ensure that those recruited have appropriate authorizations to work. Our employees and contractors consist primarily of office-based professionals who are generally not at high risk of being subject to Modern Slavery.

Training

We are committed to conducting all business transactions in an ethical and transparent manner. Employees and contractors receive periodic training on a range of topics, including the ON24 Code, anti-corruption, and harassment prevention. In addition, on an annual basis, they are required to confirm their agreement to adhere to our Code. The Procurement Team receives periodic training on how to identify issues that are specific to labor and human rights.

Remediation

Any reports received by the independent whistleblower system will be investigated by ON24’s Compliance Team. If the concern is substantiated, appropriate remediation will be taken.

Next steps

During the 2025 financial year, Modern Slavery risks and anti-slavery measures will continue to be reviewed and developed. The Procurement Team will continue to enhance the due diligence carried out on ON24’s supply chains.

Consultation process

Risks of Modern Slavery are assessed at a global level, taking into consideration the local operations of our subsidiaries. We have acted in consultation with the entities within the Group in preparing this Statement. Each of the entities have reviewed this Statement.

Conclusion

This Statement was approved by the Board of Directors of ON24, Inc. on March 31, 2025, and endorsed by Sharat Sharan, President and CEO.

/s/ Sharat Sharan
President and CEO

*This 2025 Modern Slavery Statement has been prepared to comply with the requirements of the Australia Modern Slavery Act of 2018 and is currently under consideration for publication by the Attorney-General’s Department.