Diversity, Equity, and Inclusion Statement

1. Our Belief

Commerce is for everyone. A marketplace works best when it reflects, represents, and respects the full diversity of the people who buy and sell on it. This Statement describes the commitments of Upmos Inc., a Delaware corporation headquartered at 9896 Bissonnet St, Houston, Texas 77036, to diversity, equity, and inclusion (“DEI”) — in our workplace, on our marketplace, and across our supply chain — and the concrete steps we take and goals we measure ourselves against. References below to “Upmos,” “we,” “our,” or “us” mean Upmos Inc. and its wholly-owned subsidiaries that operate the Upmos marketplace.

2. Definitions

We use the following working definitions:

• Diversity — the presence of meaningful representation across dimensions of human difference, including race, ethnicity, gender, sexual orientation, gender identity, age, disability, neurodivergence, veteran status, religion, national origin, socioeconomic background, and lived experience.
• Equity — fair treatment, access, opportunity, and advancement for all, with deliberate attention to the structural and systemic barriers that disadvantage some groups.
• Inclusion — a culture where everyone feels respected, supported, and able to contribute fully.
• Belonging — the felt sense that one is valued and accepted on the team and in the community.

3. Workplace Commitments

Within our own workforce, Upmos commits to:

• Inclusive hiring practices, including structured interviews, diverse interview panels, and skills-based assessment;
• Pay equity audits annually, with prompt remediation of unjustified gaps;
• Career-development sponsorship and mentorship programs targeted at underrepresented populations;
• Employee Resource Groups (“ERGs”) supported with funded programs and executive sponsorship;
• Inclusive benefits, including parental leave (regardless of gender or family structure), domestic-partner coverage, fertility benefits, gender-affirming care, and mental-health support;
• Flexible work arrangements that accommodate caregiving and disability;
• Anti-discrimination and anti-harassment training annually, with additional training for managers;
• Procurement preferences for diverse suppliers (see Supplier Diversity below).

These workplace commitments are designed to meet or exceed the protections of Title VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000e et seq.), the Americans with Disabilities Act (42 U.S.C. § 12101 et seq.) and Title I of the ADA (42 U.S.C. § 12112), the Age Discrimination in Employment Act (29 U.S.C. § 621 et seq.), the Equal Pay Act of 1963 (29 U.S.C. § 206(d)), the Lilly Ledbetter Fair Pay Act of 2009 (Pub. L. 111-2), the Genetic Information Nondiscrimination Act (42 U.S.C. § 2000ff et seq.), the Uniformed Services Employment and Reemployment Rights Act (38 U.S.C. § 4301 et seq.), the Pregnancy Discrimination Act (42 U.S.C. § 2000e(k)), the Pregnant Workers Fairness Act (Pub. L. 117-328, Division II), the PUMP for Nursing Mothers Act (Pub. L. 117-328, Division KK), § 1557 of the Patient Protection and Affordable Care Act (42 U.S.C. § 18116), §§ 503/504 of the Rehabilitation Act of 1973 (29 U.S.C. §§ 793, 794), and Chapter 21 of the Texas Labor Code (Texas Commission on Human Rights Act, Tex. Lab. Code § 21.001 et seq.).

4. Marketplace Commitments

On the Upmos marketplace, we commit to:

• Inclusive search and ranking — the algorithms that surface products do not unjustly disadvantage vendors based on the demographics of their ownership;
• Highlighting underrepresented founders through curated collections, sponsored placements at no charge, and editorial content;
• Accessibility — see our Accessibility Statement and Accessibility Compliance Policy;
• Anti-discriminatory enforcement of policy — see our Anti-Discrimination Policy and Trust & Safety Policy;
• Vendor education programming for small and underrepresented sellers.

Our marketplace commitments align with 42 U.S.C. § 1981 (equal contract rights regardless of race), Title II of the Civil Rights Act of 1964 (42 U.S.C. § 2000a, public-accommodations non-discrimination), Title III of the Americans with Disabilities Act (42 U.S.C. § 12181 et seq.), the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA, the Unruh Civil Rights Act (Cal. Civ. Code § 51) for California buyers and sellers, and the algorithmic-transparency obligations of Article 27 of the EU Digital Services Act (Regulation (EU) 2022/2065) for EU users.

5. Supplier Diversity

In our own procurement (technology, professional services, fulfillment, marketing), Upmos commits to:

• Set an aspirational target of 20% of annual third-party spend with certified diverse suppliers by 2028;
• Accept the following diversity certifications: Women’s Business Enterprise National Council (WBENC), National Minority Supplier Development Council (NMSDC), National LGBT Chamber of Commerce (NGLCC), Disability:IN, U.S. Small Business Administration’s Women-Owned Small Business and 8(a) programs, Veteran’s Affairs Center for Verification and Evaluation;
• Provide diverse suppliers with prompt payment (NET-15 or better);
• Publish annual progress in our Transparency Report.

Diverse-supplier certifications referenced above are administered under 13 CFR Part 124 (Small Business Administration 8(a) Business Development Program), 15 U.S.C. § 637(m) (Women-Owned Small Business / Economically Disadvantaged WOSB), 38 U.S.C. § 8127 (Service-Disabled Veteran-Owned Small Business), and the Office of Federal Contract Compliance Programs regulations at 41 CFR Part 60. While Upmos is not a federal contractor, we voluntarily apply these definitions so that supplier certifications recognized by federal agencies are also recognized in our procurement.

6. Measurable Goals

We hold ourselves accountable to the following goals:

Goals and progress are reviewed annually by Upmos’s Board of Directors and published in our annual Transparency Report at /transparency-report/.

7. Accountability & Governance

DEI strategy is owned by Upmos’s Chief People Officer in partnership with the Chief Marketplace Officer, with quarterly reporting to the Board of Directors. Executive compensation includes a DEI scorecard component reviewed annually.

Board-level oversight of human-capital and DEI metrics is conducted by the Nominating & Governance Committee under its charter, consistent with Item 101(c) of SEC Regulation S-K (human-capital resources disclosure) and the disclosure-controls framework of §§ 302 and 404 of the Sarbanes-Oxley Act of 2002 (15 U.S.C. §§ 7241, 7262). DEI metrics that touch employment terms are reviewed in coordination with our Compensation Committee under 17 CFR § 229.402(s) compensation-policy disclosures.

8. Reporting Concerns

If you witness or experience conduct inconsistent with this Statement, please report via the Whistleblower Hotline, by email to ethics@upmos.com, or through the Anti-Discrimination Policy’s complaint procedures.

Anti-retaliation. Retaliation against reporters is prohibited under § 704(a) of Title VII of the Civil Rights Act (42 U.S.C. § 2000e-3(a)), § 503 of the Americans with Disabilities Act (42 U.S.C. § 12203), § 4(d) of the Age Discrimination in Employment Act (29 U.S.C. § 623(d)), § 806 of the Sarbanes-Oxley Act (18 U.S.C. § 1514A), § 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (15 U.S.C. § 78u-6) for securities-law whistleblowers, § 1107 of the Sarbanes-Oxley Act (18 U.S.C. § 1513(e)), the National Labor Relations Act (29 U.S.C. § 158(a)(4)) for concerted activity, the Texas Whistleblower Act (Tex. Gov’t Code Ch. 554), and § 1102.3 of the California Labor Code for California-based reporters. Reporters may also contact the U.S. Equal Employment Opportunity Commission at eeoc.gov or the Texas Workforce Commission Civil Rights Division at twc.texas.gov/programs/civil-rights without first using internal channels.

9. Continuous Improvement

DEI is a journey, not a destination. We publish our progress annually, including where we have fallen short, and refine our programs each year based on feedback from employees, vendors, customers, and outside experts.

10. DEI Contact

For DEI-specific inquiries, accommodations, or feedback on this Statement: dei@upmos.com

How Can You Contact Us About This Policy?

If you have any further questions or comments or wish to report any problematic Content or Contribution, you may contact us by:

General Contact

• Phone: 1-855-637-2433 (Mon–Fri, 7 AM–8 PM CT)
• General Support: support@upmos.com
• Report Issue: upmos.com/report
• Send Feedback: upmos.com/feedback

Department Directory

Mailing Address

Upmos Inc.
9896 Bissonnet St
Houston, TX 77036
United States