Modern Slavery and Human Trafficking Statement

January 2022

Introduction

This Statement is made on behalf of Spectrum Fibre Limited and its Group, which trade as Ogi. To find out more about our company and its structure, visit the Corporate page on our website. We are a real fibre broadband and business managed services company based in Cardiff, south Wales.

The Modern Slavery Act 2015 comprises actions relating to “slavery, servitude and forced or compulsory labour”
and “human trafficking” (“Modern Slavery”).

Ogi’s statement covers its:

  1. Structure and Supply Chain
  2. Policies
  3. Assessing and Managing Risk
  4. Training
  5. Effectiveness and Future Actions

Structure and Supply Chain

Our supply chain providers include businesses that support the build of our network as well as specialist professional and advisory services and businesses that support our employees and their work environment.

Policies

Ogi has a number of policies which aim to minimise the risk of modern slavery in our supply chain. These include:

  • Our Company Handbook which aims to cultivate a workplace environment that is fair, open and respectful,
    and one that promotes and protects the rights and dignity of all employees.
  • Our Purchasing Policy which sets out internal requirements for buying goods and services.
  • Our Whistleblowing Policy which encourages employees to report any concerns including any related to
    modern slavery/trafficking and child and forced labour.

We do not tolerate forced labour or human trafficking of any kind in our business, or in our supply chain. We recognise that modern slavery exists in both developed and developing economies and across business sectors. Consequently, we take our obligations under the Modern Slavery Act very seriously, as part of our wider approach to human rights. Our commitments on human rights are guided by the principles set forth in the United Nations Universal Declaration of Human Rights and we support the UN Guiding Principles on Business and Human Rights.

We also make sure our suppliers are aware of our policies and adhere to the same high standards. All our suppliers need to declare that they strictly adhere to the Modern Slavery Act 2015. Where suppliers fail to meet our expectations, we work to remediate gaps. We require high standards of ethical behaviour throughout the business, and policies and procedures exist to ensure employees, suppliers and contractors at all levels understand and maintain such standards at all times.

Assessing and managing risk

Ogi regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain.

We ensure all our suppliers adhere to our Modern Slavery Policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our policy, we will immediately seek to terminate our relationship with the relevant supplier.

Ogi uses a wide range of suppliers who supply goods for sale, provide services and support our operations. We recognise there are many challenges that we face with regards to full transparency across each tier of our supply chain. We segment our direct suppliers based on value and risk and carry out due diligence accordingly.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence procedures. We identify potential high-risk suppliers across our supply chain, based on the country in which the supplier is based as well as the sectors in which they operate.

Our procedures are designed to:

  • establish and assess areas of potential risk in our business and supply chains
  • monitor potential risk areas in our business and supply chains
  • reduce the risk of slavery and human trafficking occurring in our business and supply chains
  • provide adequate protection for whistle-blowers.

Training

We invest in educating our employees to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

Effectiveness and future actions

Ogi will continue to review our procurement process and engage with our suppliers. We also plan to review and publish our policy relating to procurement. We intend to review and strengthen our supplier policies with respect to modern slavery and consider ways we can effectively review and evaluate transparency statements published by our suppliers. We have robust supplier on-boarding controls and procedures and will continue to review and develop these. We will communicate this Statement and our Modern Slavery Policy to our employees and provide training and support where this is needed to ensure they are aware of our obligations.

We plan to specifically address our construction partners along with any sub-contractors in a phased approach communicating our principles for modern slavery and asking for information about their policies and processes for tackling forced labour and human trafficking.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015. It constitutes Spectrum Fibre Limited’s slavery and human trafficking statement for the financial year ending 31 December 2022.