Modern Slavery and Human Trafficking Statement 2022

The steps that Sonder Holdings Inc. (“Sonder” or “the Company”) takes to eliminate modern slavery, in any of its forms, from our operations and our supply chains are set out below. This statement is published in accordance with the UK Modern Slavery Act 2015, and is in line with Sonder’s approach to adopt responsible business practices early-on in our journey.

Overview and structure

Sonder is revolutionizing hospitality through innovative, tech-powered service and inspiring, thoughtfully designed accommodations combined into one seamlessly managed experience. Officially launched in 2014 and headquartered in San Francisco, Sonder is making a world of better stays open to all with a variety of accommodation options in cities and countries around the world. As of 30 November 2022, Sonder is expanding with operations in 40 cities spanning ten countries and three continents.

Oversight of the risk of modern slavery sits with Corporate Responsibility & Sustainabilty, Trust & Safety and Procurement. In addition, once formed, Sonder’s Audit Committee and Nominating, Corporate Governance, and Social Responsibility Committee will provide oversight in their risk management capacity.


Sonder has put in place policies to help eliminate the potential use of Company managed properties for slavery and human trafficking.

Our employee Code of Conduct requires our employees, contractors, consultants, and all others who perform work or services to Sonder, to act both ethically and legally when dealing with fellow employees and third parties with whom we do business.

Our Supplier Code[1] of Conduct outlines the values and standards we expect of our suppliers and their representatives. Among many key considerations, it sets forth expectations of our suppliers with respect to forced labor and child hiring practices. The Supplier Code of Conduct draws from the internationally recognised standards and norms including the Universal Declaration of Human Rights, ILO International Labor Standards, OECD Guidelines for Multinational Enterprises and ISO and SA standards.

In addition to this, Sonder is committed to providing effective grievance mechanisms while protecting the confidentiality, anonymity, and protection of Supplier and employee whistleblowers to the fullest extent provided by applicable law.

Risk Management and Due Diligence

Sonder encourages its employees and suppliers (where permitted by law) to report certain matters, including circumstances that may give rise to slavery or human trafficking concerns, to relevant local authorities or internal contacts.

Training and awareness raising

Sonder requires relevant employees to attend training relating to modern slavery and human trafficking. Our training includes escalation protocols, checklists, information to assist our trust & safety, city teams and frontline staff in identifying the key warning signs of human trafficking and guidance on how to report cases.

Moreover, Sonder makes available to its employees information to assist employees with identifying potential signs of slavery and human trafficking and provides a process for timely escalating concerns within the organization.

Improvement and tracking progress

Sonder will revisit its processes for combatting modern slavery and human trafficking on a periodic basis, no less than annually, and benchmark its progress against industry standards, best practices, and its own internal goals. As part of this assessment, Sonder will engage with its employees, suppliers, and wider stakeholder groups.

This statement was approved by the Sonder Board on 30 November 2022.

Francis Davidson

Chief Executive Officer

[1] Employment is freely chosen. Sonder has a zero-tolerance approach to modern slavery, including all forms of human trafficking and forced or bonded labor. All workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per the worker’s contract. Suppliers and their agents and sub-agents may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Suppliers can only hold documentation of their employees if such holdings are required by law. At no time should workers be denied access to their personal documents. Workers shall not be required to pay Suppliers’ agents’ or sub-agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker. Sonder and its Suppliers should pay particular attention to the risks of exploitation that both domestic and foreign migrant workers face.