Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit for personal or commercial gain.
CityFibre is committed to acting ethically and with the upmost integrity in all our business relationships and take a zero-tolerance approach to slavery and human trafficking. We are committed to the compliance of duties set out within the Modern Slavery Act 2015 (MSA) and expect our suppliers, and supply chains, to take all reasonable steps to comply with the MSA. We also expect our suppliers and their supply chains, to engage in appropriate employment practices and to comply with all relevant legislation and regulations in the countries in which they operate.
As a responsible organisation we strive to incorporate respect for human rights into our employment practices and our values. We are responsible for ensuring that our colleagues and those working on our behalf are able to work freely and receive fair remuneration in return. Our HR policies and processes ensure that all direct employees are treated fairly and in a way that safeguards their human rights. We communicate these requirements to our suppliers via our Supplier Code of Conduct, which sets out the expectations of our suppliers that they shall comply with laws relating to their business, and their duties as set out in the MSA.
Steps for the prevention of modern slavery
- Whistleblowing: Our Employee Handbook encourages all employees and contractors to report concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The whistleblowing advice set out in the Handbook is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers and others who have concerns are encouraged to raise direct with the Group HR Director or the Compliance team.
- Supplier conduct: CityFibre is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in the use of their labour. CityFibre works with suppliers to ensure that they meet the standards of the code and improve their worker’s conditions. Violation and/or breach of the relevant duties as set out in the Supply Contracts are taken extremely seriously and will result in termination of the business relationship.
- Recruitment: CityFibre uses only specified, reputable employment agencies to source labour and seeks to verify the practices of any new agency it is using prior to accepting resource from that agency.
- Procurement and contract management: CityFibre’s requirements are outlined within the procurement policy and set out in our contracts with organisations delivering construction work on our behalf.
We continue to monitor and reduce the risk of modern slavery occurring in our business and supply chains by:
- Requiring all new suppliers to confirm compliance with our code of conduct and regularly review existing suppliers
- Mapping our supply chain broadly to assess product or geographical risks of modern slavery and human trafficking
- Evaluating the modern slavery and human trafficking risks of each new supplier
- Conducting supplier assurance, as part of our supplier pre-qualification process through the compliance team, which have a greater degree of focus on slavery and human trafficking where general risks are identified
CityFibre are committed to the continual improvement and review of current standards. This includes revisions based on new legislation, industry guidance as well as best practice. Looking ahead to within 2020 and out to 2021 CityFibre will be focused on:
- Creating an annual risk profile for each supplier;
- Taking steps to improve substandard suppliers’ practices and implementing Performance Improvement Programs, including providing advice to suppliers and requiring them to implement action plans
- Exploring collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
- Maintaining control and governance as the organisation grows in productivity and footprint
CityFibre requires all employees to complete Essentials Training which includes a module on modern slavery. Training is aligned to CityFibre’s wider Code of Ethical Business Conduct and covers our obligations under the MSA.
CityFibre is committed to raising the awareness of our obligations including reinforcing:
- The basic principles of the Modern Slavery Act 2015;
- How employers can identify and prevent slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
- What external help is available, for example through the Modern Slavery Helpline.
This statement applies to CityFibre Holdings Ltd, CityFibre Limited and Entanet International Limited.
This statement was approved on Friday 17th April 2020 by the CityFibre Chief Executive Officer and will be reviewed and updated annually or where a change is required.