Modern Slavery Policy Statement
ElevenLabs Modern Slavery Policy Statement
I. OVERVIEW
This Modern Slavery Policy Statement (“Policy”) is made by Eleven Labs Inc., for and on behalf of itself and its Affiliates (together, “ElevenLabs”) and has been approved by Eleven Labs Inc.’s Board of Directors as of the date provided in Section XII hereof.
This Policy is made in accordance with the s. 54 of the UK Modern Slavery Act, Australia Modern Slavery Act, the California Transparency in Supply Chains Act, and similar legislation (together, the “Acts”) which, to the extent applicable, may require ElevenLabs to disclose information pertaining to its commitments to ensuring Modern Slavery does not exist within its organization or supply chain. ElevenLabs endorses the principles of these Acts and does not support Modern Slavery in any form. This Policy includes a summary of steps that have been taken during the financial year ending 31 December 2024 (“FY24”) to prevent modern slavery from taking place in ElevenLabs’ supply chains or in any part of the ElevenLabs business.
II. DEFINITIONS
For purposes of this Policy:
“Affiliates” means Eleven Labs Ltd (“ElevenLabs UK”), Eleven Labs Poland Sp. z o.o. (“ElevenLabs Poland”), Eleven Labs Japan Godo Kaisha (“ElevenLabs Japan”), and any other entities which Eleven Labs Inc. may control or come under common control with while this Policy remains in effect. For purposes of the foregoing, “control” means the direct or indirect ownership of more than 50% of the voting securities of an entity or possession of the right to control the management and affairs of an entity, through ownership of securities, by contract, or otherwise.
“Modern Slavery” means human trafficking, forced or compulsory labor, servitude, slavery, child labor (i.e. work performed by individuals below the legal minimum age in such jurisdiction), and other forms of exploitation, including any other acts which constitute “modern slavery”, “slavery”, “human trafficking”, or the like under applicable laws.
III. ELEVENLABS' COMMITMENT
ElevenLabs’ leadership and global teams are committed to upholding the highest ethical standards in carrying out its business operations, including ensuring its workplace and supply chain remains free from all forms of Modern Slavery and that human rights are respected.
ElevenLabs has a zero-tolerance approach to Modern Slavery and does not enter into business with any organization which it knows to tolerate or engage in any form of Modern Slavery. All employees, contractors, vendors, partners, and suppliers of ElevenLabs are expected to align with the foregoing and promptly report any actual or suspected instances of Modern Slavery to ElevenLabs.
IV. ELEVENLABS’ BUSINESS & RISK ASSESSMENT
Organizational Structure
The Affiliates of Eleven Labs Inc., as expressly identified in this Policy, are wholly owned by Eleven Labs Inc. ElevenLabs’ operations are carried out globally through such Affiliates and ElevenLabs’ contractors, however all activities are carried out for the benefit of Eleven Labs Inc., which serves as the transacting entity for the sale of the ElevenLabs’ Services (as defined below). ElevenLabs may, on a case-by-case basis, elect to transact through its Affiliates. ElevenLabs currently maintains offices in London, New York, San Francisco and Warsaw.
Business Overview
ElevenLabs’ business includes the provision of a web-based, artificial intelligence audio solutions platform (“Services”) which includes Text to Speech, Speech to Speech, Dubbing, Conversational AI, VoiceLibrary, and its ElevenReader mobile application. Activities carried out by employees and/or contractors include, without limitation, product development activities, the provision of technical support, and professional services (ex. In connection with ElevenLabs’ Dubbing offering(s)).
While ElevenLabs does not engage in manufacturing of physical goods, ElevenLabs takes steps to ensure its employees, independent contractors, contracting agencies, partners, and vendors engaged in connection with the delivery of the Services (together, “Third Parties”) do not engage in or otherwise promote Modern Slavery.
Risk Assessment & Management
ElevenLabs has taken into consideration various factors in considering Modern Slavery risk in its business operations. Such factors include industry, work type, geography, the terms and conditions in place with third parties, and more.
Taking into account such factors, ElevenLabs believes the risk of Modern Slavery in its operations, or those of its partners and vendors supporting the provision of the Services, is low. As a provider of advanced technology, the individuals engaged to support the delivery of the Services are predominantly required to be professionally qualified and highly educated and skilled, thus minimizing the risk of vulnerable individuals being exploited for purposes of supporting ElevenLabs’ operations. As provided in Section V hereof, ElevenLabs maintains written agreements with Third Parties. While ElevenLabs maintains a global presence, ElevenLabs does not carry out a material portion of its operations in any location which it would deem high risk for purposes of this assessment.
Potential risks identified and measures to mitigate such risks include:
Potential Risks Mitigation
Reduced visibility into contractor agency operations
● Ensuring appropriate contractual controls are in place.
● Evaluating the risk of Modern Slavery based on contractor skill level, location, work type, and the like.
● Partnering only with reputable companies.
Excessive working hours
● Ensuring appropriate contractual controls are in place to ensure compliance with all applicable laws, including laws governing overtime.
● Monitoring of employee working time.
● Ensuring mechanisms are available to report concerns.
Forced labor (deemed unlikely)
● Development of policies, such as the Code of Conduct (defined below).
● Ensuring employees affirmatively acknowledge such Code of Conduct.
● Ensuring mechanisms are available to report concerns.
The process for identifying, evaluating and managing more significant risks faced by ElevenLabs is overseen by the Board working with the Finance, Legal, Security and Safety Teams. These Teams provide ElevenLabs with risk management oversight, including reporting on significant risks if they arise, as well as policies and operating procedures.
V. SUPPLY CHAIN DUE DILIGENCE
The ElevenLabs supply chain includes cloud infrastructure providers, software and technology service providers, professional service contractors (including for data labelling and voice talent), marketing and business support services and workplace equipment suppliers. The majority of Third Parties are located in regions with established legal and regulatory frameworks, including the UK, EU and the United States. ElevenLabs believes the overall risk of exposure to modern slavery in its supply chain as low, but continues to monitor for any areas of higher risk, especially if subcontracting or offshore labor may be involved.
Third Parties are subject to both a Legal and Security review prior to engagement. Our Legal review includes verification of the Third Party’s compliance with applicable laws and regulatory requirements. For higher-risk suppliers or services, we conduct enhanced due diligence, including reviewing their modern slavery statements and ethical sourcing policies.
Any obligations imposed upon such vendors vary depending on the nature of the engagement, however contractual obligations may include obligations to comply with applicable laws, obligations to carry out background checks on its personnel, assurances that the Third Party is not subject to sanctions, and unlimited liability for gross negligence, willful misconduct, and/or violations of applicable law.
To the extent ElevenLabs were to discover or suspect Modern Slavery in the operations of any such party, ElevenLabs would thoroughly investigate such claims and implement corrective measures, where necessary, up to and including termination of such relationships where Modern Slavery is confirmed.
ElevenLabs remains committed to responsible business practices and continues to assess its vendor selection and management processes to ensure ethical and compliant partnerships.
VI. ELEVENLABS’ BUSINESS
ElevenLabs takes steps internally to prevent Modern Slavery in its own business:
• All employees are paid a salary of at least the living wage in the UK or equivalent (or pro rata in the case of those that work part-time)
• All employees have a contract of employment or other employment documents in place that are compliant with applicable local laws (which includes any statutory required information on their rights and entitlements)
• ElevenLabs ensures that all employees have the required legal permissions to work in the country where they are hired
• ElevenLabs takes professional development, health and wellbeing of employees seriously and encourages employees to take annual leave
VII. KEY PERFORMANCE INDICATORS FOR MEASURING EFFECTIVENESS
ElevenLabs measures its effectiveness in preventing Modern Slavery in its business and supply chain in the following ways:
● Periodically reviewing relevant policies and updating them as necessary;
● Keeping a record of all suppliers that have completed the onboarding processes;
● Tracking the percentage of employees who have acknowledged the Code of Conduct;
● Monitoring and documenting any concerns raised through our reporting channels; and
● Reviewing our due diligence processes annually to ensure they remain effective.
VIII. POLICIES ADDRESSING ETHICAL CONDUCT
ElevenLabs maintains a Code of Conduct (“Code of Conduct”). Such Code of Conduct provides, without limitation:
● That all employees are expected to know and follow the Code of Conduct;
● That where applicable, ElevenLabs expects its contractors, consultants, and others who may be temporarily assigned to perform work or services for ElevenLabs to follow the Code of Conduct;
● Any violation of the Code of Conduct by an employee, contractor, consultant, or other service provider can result in disciplinary action, including termination of employment or the services relationship;
● That employees are expected to be honest, act ethically, and demonstrate integrity in all situations, including complying with all applicable laws;
● For ElevenLabs’ commitment to a quality work environment, free of harassment, intimidation, bias, discrimination, retaliation, and bullying, whether verbal, physical, or visual; and
● For ElevenLabs’ commitment to a safe, violence-free work environment, where any level of violence or threats of violence are not tolerated and must be reported immediately.
IX. ADDITIONAL INTERNAL PRACTICES
Recruiting
ElevenLabs recognizes that Modern Slavery can occur in many forms and may be present in recruitment and employment processes. As part of ElevenLabs’ commitment to creating a fair and inclusive workplace, ElevenLabs takes proactive steps to ensure that its hiring practices, as well as those of any third-party partners, are free from exploitation.
● Direct Hiring Practices: ElevenLabs conducts thorough vetting of all candidates and maintains transparent, fair, and voluntary recruitment processes. No employee is ever charged recruitment fees, and all employment is based on informed consent.
● Evaluation of Employment Partners: ElevenLabs assesses and monitors the labor practices of any Employer of Record (EOR), recruitment agency, or third-party staffing partner it works with. ElevenLabs requires all such partners to comply with applicable labor laws and ElevenLabs’ Code of Conduct, which explicitly prohibits any form of Modern Slavery or human rights abuse.
● Ongoing Due Diligence: ElevenLabs is committed to regular due diligence to evaluate ElevenLabs’ hiring channels and partners, which includes maintaining open lines of communication for reporting unethical practices. Concerns raised, whether internally or externally, are taken seriously and addressed promptly through clear investigatory procedures.
Employee Awareness / Training
Employees receive and are required to affirm acceptance of ElevenLabs’ Code of Conduct, among other policies, during onboarding. As of May 20, 2025, 100% of current employees have affirmed their acceptance of the ElevenLabs’ Code of Conduct.
Additionally, employees in procurement, human resources and management roles receive information about identifying and reporting potential modern slavery concerns as part of their role-specific training.
Related Safety Efforts
ElevenLabs’ promotes safety in all aspects of its business. Related safety efforts with respect to its Services are provided below.
ElevenLabs’ Prohibited Use Policy, to which all customers are bound to comply in their use of the ElevenLabs Services, prohibits:
● Uses of its Service that threaten child safety. Examples include:
○ The creation, distribution, or promotion of sexually explicit material involving minors or material otherwise facilitating, promoting, or exploiting the sexualization of children, including minor grooming, nudity, or use of any material designed to impersonate a minor;
○ The creation, distribution, or sharing of age-inappropriate material, including material that targets minors or promotes sexual material, graphic violence, obscenity, or other mature themes;
○ The facilitation or promotion of child abuse or exploitation in any form; and
○ The facilitation or contribution to cyberbullying or harassment of any minor, including, without limitation, the creation, distribution, or sharing of material that shames, humiliates, bullies, or celebrates the suffering of any minor, or material that threatens a minor with bullying or harassment.
● Engaging in illegal behavior, including use of the Services to create or facilitate in the exchange of illegal goods or services, including, without limitation, material that promotes or facilitates transactions in human trafficking or sexual services.
● Using the Services to facilitate activities that may significantly affect the wellbeing of others.
● Engaging in fraudulent, predatory, or abusive practices.
● Engaging in unauthorized, deceptive, or harmful impersonation.
● Creating any violent, hateful, or harassing material (outside of fictional contexts).
● Otherwise using the Services in any manner contrary to ElevenLabs’ policies, purpose, or mission.
ElevenLabs maintains a Safety team dedicated to ensuring compliance with the foregoing and ensuring safety standards and procedures, as it relates to the ElevenLabs Service, continue to improve over time.
X. REPORTING & INVESTIGATION
ElevenLabs maintains a confidential reporting mechanism for employees to report any concerns, including suspected incidents of Modern Slavery. This reporting mechanism is accessible to all employees and is described in our internal Whistleblowing Policy. Reports can be made anonymously and ElevenLabs strictly prohibits retaliation against anyone making a good-faith report. ElevenLabs thoroughly investigates all reports of Modern Slavery and takes appropriate action to address any issues that are identified (which may include termination of employment or third-party relationships).
No instances of Modern Slavery have been reported to ElevenLabs through such mechanism (or otherwise) to date.
The Code of Conduct further directs employees to contact their manager if there are questions or concerns regarding the Code of Conduct (including questions or concerns regarding suspected violations of the Code of Conduct or any other ElevenLabs policy).
ElevenLabs prohibits retaliation against anyone who reports, or participates in an investigation of, a possible violation of the Code of Conduct, ElevenLabs policies, or compliance with law.
XI. ONGOING POLICY REVIEW & IMPROVEMENT
This Policy will be regularly reviewed no less than annually and updated, as needed, to reflect changes in legislation, industry practices, and ElevenLabs’ business operations to ensure it remains relevant and effective in addressing Modern Slavery risks.
ElevenLabs’ goals for the fiscal year covered by this Policy include evaluating:
● Effective methods for ensuring employees and third-party contractors, consultants, vendors, and suppliers are aware of their obligations under this Policy and the Code of Conduct, as applicable, and are trained on their relevant responsibilities;
● The development of additional policies which may serve the goals of this Policy;
● The continued development of due diligence practices as it relates to ElevenLabs’ Third Parties;
● The potential establishment of a cross-functional committee on Modern Slavery to periodically assess risks and mitigation measures; and
● The development of additional KPIs to allow ElevenLabs to measure the success of its initiatives.
XII. APPROVAL
The Eleven Labs Inc. Board of Directors has approved of this Policy as of June 2025.
Signed for and on behalf of ElevenLabs
