Statement on Anti-Modern Slavery and Human Trafficking

INTRODUCTION

This statement on Modern Slavery and Human Trafficking (the “Statement”) describes the actions taken by Lightspeed Commerce Inc. (“we”, “our”, “Lightspeed” or the “Company”) and, as defined below in the section “Our Structure”, its Reporting Subsidiaries (together with Lightspeed, the “Lightspeed Group”) during the fiscal year ended March 31, 2022 (“FY22”) to prevent modern slavery and human trafficking in our operations and our supply chains pursuant to the Modern Slavery Act 2015 (United Kingdom) and the Modern Slavery Act 2018 (Cth) (Australia).

Lightspeed, as the principal governing body of the Lightspeed Group, is submitting this joint Statement on behalf of its Reporting Subsidiaries. This Statement has been prepared by Lightspeed in consultation with the senior management of the Reporting Subsidiaries. The Lightspeed Board of Directors approved this Statement at its meeting held on May 18, 2022.

WHO WE ARE, OUR STRUCTURE, BUSINESS OPERATIONS AND SUPPLY CHAINS

About Lightspeed
Founded in Montréal, Canada, in 2005, Lightspeed is dual-listed on the New York Stock Exchange and Toronto Stock Exchange (NYSE: LSPD) (TSX: LSPD). Lightspeed offers a cloud-based commerce platform that connects suppliers, merchants and consumers while enabling omnichannel experiences for small and medium-sized businesses around the world. With the mission to ignite business everywhere and with teams across North America, Europe and Asia-Pacific, the Company serves retail, hospitality and golf businesses in over 100 countries. More information about our business and operating entities can be found in our latest Annual Report.

Our Structure
Lightspeed is a corporation incorporated under the laws of Canada and the principal governing body of the Reporting Subsidiaries, which include the following entities:

In the United Kingdom and Northern Ireland:

● Lightspeed POS UK Ltd., a private limited company incorporated in England and Wales and a wholly owned subsidiary of Lightspeed.

● Vend Software UK Ltd., a private limited company incorporated in England and Wales and a wholly owned subsidiary of Lightspeed POS UK Ltd.

● NuOrder Software, Ltd., a private limited company incorporated in England and Wales and a wholly owned subsidiary of Lightspeed.

● ShopKeep.com LTD, a private company limited by shares incorporated in Northern Ireland and a wholly owned subsidiary of Lightspeed.

In Australia:

● NuORDER Pty Ltd, a proprietary company limited by shares incorporated in Australia and a wholly owned subsidiary of Lightspeed.

● Lightspeed POS Holding Pty Ltd, a proprietary company limited by shares incorporated in Australia and a wholly owned subsidiary of Lightspeed.

● Lightspeed POS Australia Pty Ltd, a proprietary company limited by shares incorporated in Australia and a wholly owned subsidiary of Lightspeed POS Holding Pty Ltd.

● Vend Pty Limited, a proprietary company limited by shares incorporated in Australia and a wholly owned subsidiary of Lightspeed POS Holding Pty Ltd.

● Kounta Holdings Pty Ltd, a proprietary company limited by shares incorporated in Australia and a wholly owned subsidiary of Lightspeed POS Australia Pty Ltd.

● Kounta IP Pty Ltd, a proprietary company limited by shares incorporated in Australia and a wholly owned subsidiary of Kounta Holdings Pty Ltd.

● Kounta Pty Ltd., a proprietary company limited by shares incorporated in Australia and a wholly owned subsidiary of Kounta Holdings Pty Ltd.

Lightspeed also has wholly owned subsidiaries outside the United Kingdom and Australia in North America, Europe and Asia-Pacific.

Our Supply Chain
We are committed to making responsible business decisions which take into consideration the prevention of modern slavery and human trafficking in our operations and supply chain. Lightspeed’s supply chains mainly consist of:

● Hardware and software, including computer equipment, barcode scanners, servers, stands, tablets, receipt printers, networking hardware, cash drawers, payment terminals and an assortment of accessories, software licenses and subscriptions, and cloud-based software and related components (i.e. semiconductor chips);

● Data storage services;

● Sponsorships, marketing events and trade show services; and

● Professional services from our advisors including background check services, law firms, consulting, staffing, financial advisory, accounting and other professional services firms.

The majority of our suppliers and vendors are based in North America (mostly the United States) where the labor environment is well-regulated. A small minority of sub-components hardware suppliers are operating in regions with a history of less robust regulation. As a software-as-a-service business, with the majority of our suppliers being software and professional services providers, Lightspeed operates in a sector that is considered relatively low risk for modern slavery and human trafficking.

LIGHTSPEED’S RISKS OF MODERN SLAVERY PRACTICES IN ITS OPERATIONS AND SUPPLY CHAINS

Taking into account the nature of our business activities and our industry, we have determined that our supply chain is low risk with respect to instances of modern slavery and human trafficking. Lightspeed’s supply chain is composed mainly of businesses in North America, Europe, Australia and New Zealand who hire qualified personnel and abide by applicable labor standards. As such, we do not generally conduct formal audits of our suppliers, beyond verifying compliance with applicable laws and jurisdictions, having our suppliers review and sign our Supplier Code of Conduct, conducting our standard security, privacy and technology assessments and occasional referral calls with their clients. When we occasionally choose to partner with businesses operating in countries or industries which we consider to be high risk, we implement appropriate diligence measures during the onboarding process to assess actual risk of human rights violations, such as obtaining reports from Lightspeed employees who work closely with such suppliers. To the extent possible, we privilege local sourcing to foster a more streamlined supply chain and reduce our dealings with unknown sub-contractors.

ASSESSMENT EFFECTIVENESS AND CONSULTATION PROCESS

We understand the impact and prevalence of modern slavery in the global supply chain. With a view to doing our part to address these issues, we have implemented the measures described above into our business processes. On an annual basis, we review the effectiveness of these measures through active discussion and consultation with stakeholders and management. We will continue to scrutinize our supply chain in order to better detect the risks of modern slavery, adequately assess their importance, and identify the appropriate response.

LIGHTSPEED ONGOING COMMITMENT TO RESPECT HUMAN RIGHTS

Lightspeed takes its role in ending modern slavery and human trafficking very seriously. We believe that slavery, servitude, compulsory labour, human trafficking, and any similar or related practice have no place in our global society. Accordingly, this Statement and our associated initiatives will be scrutinized and re-evaluated on a regular basis, so as to ensure a transparent, ethical, and efficient supply chain.

This joint Statement has been prepared by Lightspeed in consultation with the senior management of each Reporting Subsidiaries. The Lightspeed Board of Directors approved this Statement on May 18, 2022.

Jean Paul Chauvet
Chief Executive Officer