For the fiscal year ending January 31, 2026
1. Introduction and Organizational Structure
This statement is made pursuant to the relevant modern slavery legislation, including but not limited to the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act, and the Australian Modern Slavery Act 2018, and constitutes Navan's modern slavery statement for the financial year ending January 31, 2026.
Navan, Inc. and its subsidiaries (collectively, "Navan," "we," or "our") is a Delaware corporation with its principal place of business in Palo Alto, California. Navan provides comprehensive travel and expense management solutions through its proprietary technology platform to commercial entities globally. Our operations encompass software development, technology services, and business process management related to corporate travel arrangements, expense reporting, and financial services.
2. Policy Framework and Governance
Navan maintains a comprehensive policy framework designed to ensure ethical business practices throughout our operations and supply chain. While we have not historically maintained a standalone modern slavery policy, our commitment to human rights and ethical business practices is embedded within our existing compliance infrastructure, which includes:
a) Our Code of Business Conduct and Ethics, which establishes the fundamental ethical principles governing all Navan operations and includes our Conflict of Interest Policy that is intended to increase awareness of potential conflicts of interest and establish a procedure for reporting them;
b) Vendor and Supplier Management Protocols, which establish minimum standards for third-party relationships;
c) Information Security and Data Privacy Compliance Standards, which are regularly audited and certified by independent third parties; and
d) Stringent compliance verification procedures, including but not limited to sanctions screening in accordance with Office of Foreign Assets Control ("OFAC") requirements.
(e) A Global Trade Compliance Policy whereby Navan will not engage in or facilitate any travel bookings or other transactions involving any sanctioned countries, parties, or activities without review from Navan Legal Compliance, and only in compliance with applicable trade compliance laws, including the requirement to obtain authorization from relevant authorities, and where Navan maintains records for its global trade compliance.
(f) An Anti-Corruption Policy where employees and agents of Navan are prohibited from directly or indirectly making, promising, authorizing, or offering anything of value to a non-US government official on behalf of Navan to secure an improper advantage, obtain or retain business, or direct business to any other person or entity.
(g) A prohibition in our employee handbook on forced labor, modern slavery, human trafficking, child labor, and any other practice that exploits vulnerable persons, applicable to both employees and vendors of Navan.
The Board of Directors maintains oversight of these policy frameworks, with day to-day implementation responsibility vested in our Legal, Compliance, and Procurement functions.
3. Due Diligence and Risk Assessment Methodology
Navan's third-party risk management framework incorporates a multi-faceted approach to vendor selection and ongoing monitoring. Our due diligence processes include:
a) Screening of all potential vendors against applicable sanctions lists, politically exposed persons databases, and adverse media, in compliance with OFAC and other applicable regulatory requirements;
b) Comprehensive security and data privacy assessments conducted by our Information Security team prior to engagement;
c) Contractual provisions requiring adherence to applicable laws, which such applicable laws include those pertaining to labor practices and human rights; and
d) A strategic procurement approach that prioritizes engagement with established industry leaders and reputable entities with demonstrable compliance programs.
Given the nature of our business and supply chain, which primarily consists of technology service providers and business service vendors in developed markets, we have determined that our exposure to modern slavery risks is relatively limited. Notwithstanding this assessment, we recognize that certain categories of indirect procurement may present elevated risk profiles.
4. Risk Mitigation and Supplier Engagement
To address potential modern slavery risks within our supply chain, Navan implements the following risk mitigation measures:
a) Periodic or ongoing monitoring of existing vendors through our Third-Party Risk Management Program, which leverages our established security, data privacy, and OFAC compliance frameworks;
b) Standard contractual terms requiring vendors to comply with all applicable laws, which such applicable laws include those pertaining to forced labor, human trafficking, and employment standards;
c) A procurement strategy that limits engagement to established entities with verifiable compliance programs and business histories; and
5. Forward Commitment
Navan will undertake the following initiatives to further enhance our approach to modern slavery risk management:
a) Conducting a dedicated modern slavery risk assessment across our supply chain;
b) Implementing enhanced supplier screening questions specific to labor practices and human rights; and
c) Reviewing and updating relevant policies to explicitly address modern slavery considerations;
d) Provide targeting compliance training to personnel with vendor management responsibilities;
e) Develop an escalation and review process in the event we identify or are notified of any non-compliance with this statement;
f) Screen all potential vendors against any adverse media in compliance with OFAC and other applicable regulatory requirements
Adopted by the Board, effective as of October 29, 2025.