Modern Slavery and Human Trafficking Statement

This Statement relates to the financial year ended 31 December 2022.

Introduction

Manx Telecom (MT) is the leading Telecommunications Solution provider on the Isle of Man. Across the Group we have over 350 employees. We are headquartered in the Isle of Man, with Synapse360 operating from the IOM and the UK. Our supply chain includes partnering with many of the global leaders in telecommunications industry and IT network infrastructure and top tier equipment, service providers and suppliers. Around 900 suppliers form part of our supply chain with around 65 of these being key International Service Providers also. Collectively here in as MT.

We recognise that our role as a major corporate entity on the Isle of Man goes beyond providing customers with the latest technology and offering employees worthwhile careers. We understand that our operations touch the lives of nearly every person living and working on the Island and our impact as a technology provider is global, therefore, we have responsibilities to the wider community.

All our activities stem from, and are aligned with, our core values as embodied by our brand. Our brand values – Passionate, Respectful and Confident – inform and shape our entire approach to our activities and characterise our involvement with them.

Our business is organised into five Isle of Man focused business units: Broadband and Data Services, Mobile, Fixed Line, Data Hosting & Managed services including the Synapse360 business on the Isle of Man and within the UK, selling into the local markets and beyond and a sixth unit, OV, operating internationally and BreatheSIM also.

Slavery and Human Trafficking Policies

The UK Modern Slavery Act 2015 (the ‘Act’) requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in the workplace. We are fully committed to playing our part in eradicating modern slavery. We firmly advocate for transparency and collaboration to eliminate the risks of modern slavery.

At the heart of our approach to human rights are several important, internationally recognised, declarations, standards and codes. These are the foundations for how and where we work and or that reference best practice advice, and include:

The UN Universal Declaration of Human Rights
The International Labour Organization (ILO) Declaration on
Fundamental Principles and Rights at Work
The UN Global Guiding Principles on Business and Human Rights
The UN Global Compact
The Base Code of the Ethical Trading Initiative

Our approach to addressing modern slavery sits within this wider human rights agenda. Our strategy is supported by internal policies and is strengthened by our Supplier Terms and Conditions which can be found here.

We further support this approach within our ESG vision that can be found online here.

Our approach

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. MT has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

We operate a number of policies that are designed to enforce our commitments and to ensure that we are not unwittingly denying human rights to individuals within either our operation or the operation of those entities in our supply chain. These policies, ranging from practical steps (such as recruitment screening) to cultural influences (such as our values and vision) are well publicised and clearly enforced.

We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

We will treat any breach of our policies very seriously. For example, any employee who breaches the policy will face disciplinary action which could result in dismissal for misconduct or gross misconduct.

We consistently manage and review key performance indicators to measure the proactive steps being taken whilst we continue and evolve our training internally to enable effective awareness and measurement of the policies we have in place.

Our Supply Chain Due Diligence

With a large supplier base split between the business entities, we recognise our role as supply chain leaders and key influencers in the global efforts to eradicate modern slavery and human trafficking. We maintain an approved supplier list and conduct thorough due diligence on all suppliers especially those with a wider geographic reach before allowing them to become a preferred supplier. We also perform annual supplier performance reviews and alignment to our terms on a measured basis as part of our internal vendor enablement programme. We operate defined supplier policies for our IOM/UK and International suppliers. We require our suppliers to comply with our Purchasing Terms and Conditions, which specifically include an Ethical Procurement Policy prohibiting the use of forced, compulsory or trafficked labour or anyone held in slavery or servitude (whether adults or children). These Terms and Conditions place an expectation upon our suppliers to hold their own suppliers to the same standards. Any failure by a supplier to meet the standards set out in the purchasing terms and conditions will be a breach of contract and may result in the termination of our relationship.

We build relationships with our suppliers to ensure they understand our values, and comply with our expectation and commitment to protect human rights and the environment. As part of our procurement processes, we require all of our suppliers to comply with the requirements of the Modern Slavery Act and include appropriate contractual obligations within our commercial agreements.

We are also members of SEDEX, JOSCAR and HELLIOS FSQS for effective supplier accreditation, compliance and awareness whilst being ISO accredited. Details can be located here.

We also follow CIPS best practice standards and are members also.

Our Due Diligence framework has five stages:

Establish a broad perspective beyond our immediate business, first tier supply chain
Determine priorities based on areas of highest risk and review accordingly via our risk register
Identify the process of avoiding or mitigating risk
Define method for rectifying abuses and remediating any victims via our Board of Directors
Develop learning strategy allowing us to consider new information and evolve

We review all our service providers/suppliers annually to identify those with the highest potential risk of modern slavery. This is based on evolving risk in the sector of supply and their location, their contract type, the level of skill involved by the service provider. We also review annually any professional services consultancy company who supply MT.

Risk Assessment and Management

The two main areas of risk in relation to modern slavery at MT relate to our contractual arrangements and recruitment of staff. The steps that we will take to manage these risks are outlined below.

We will ensure that consideration of the modern slavery risks and prevention are added to MT’s Procurement Policy review process as an employer and procurer of goods and services.

We will ensure when undertaking a further review of relevant People policies that they include the consideration and prevention of risks of engagement of people or groups through Modern Slavery

Training

We will provide mandatory awareness training to all staff on the UK Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of modern slavery or human trafficking.

We will ensure that staff involved in buying or procurement, and the recruitment and deployment of workers, receive training on modern slavery and ethical employment practices.

Key Performance Indicators

95% of staff will have undertaken mandatory training in relation to modern slavery by 30 December 2023.
All people policies to be reviewed and updated by 31 December 2023, with a further review on the language and tone used on an annual basis thereafter.

Effectiveness of Approaches

We recognise the importance of maintaining constant vigilance to identify and address any issues associated with slavery and human trafficking in our business and throughout our supply chains. We are committed to continuing to enhance our capacity to identify, prevent and mitigate any actual or potential risks in these areas. Whilst also ensuring key performance indicators are measured and adhered to alongside effective training.

We believe we need to act responsibly and ethically when dealing with our suppliers and are committed to upholding the principles and objectives of the Modern Slavery and Trafficking Act.

We will continue to raise awareness within our teams with respect to modern slavery and have identified escalation points for our people to raise concerns or suspected breaches of our policies.

Approval

This statement has been approved by the Board of Directors on 29 June 2023.

Iarla Hughes
Chief Financial Officer