This statement refers to our financial year ending 31 December 2018.
Manx Telecom (MT) is the leading Communications Solutions provider on the Isle of Man. Across the Group we have approximately 300 employees and are headquartered in the Isle of Man. Our supply chains include partnering with many of the global leaders in telecommunications and IT network infrastructure and top tier equipment suppliers. Around 850 suppliers form part of our supply chain with around 60 of these being key International partners also.
We recognise that our role as a major corporate entity on the Isle of Man goes beyond offering employees worthwhile careers and providing customers with the latest technology. 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 – Enterprising, Proactive, Confident, and Trusted – inform and shape our entire approach to our activities and characterise our involvement with them.
Our business is organised into five Isle of Man focussed business units: Broadband and Data Services, Mobile, Fixed Line, Data Hosting & Managed services including the Synapse businesses, selling into the local market and a sixth unit, Vannin Ventures, including the Goshawk business operating internationally.
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 work place. 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.
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.
Our Supply Chain Due Diligence
Our Suppliers. We operate defined supplier policies for our UK and International suppliers and issue consistent and updated supplier terms on a regular basis. We conduct due diligence on all suppliers especially those with a wider geographic reach before allowing them to become a preferred supplier. We also perform regular supplier performance reviews and alignment to our terms on a measured basis as part of our internal vendor enablement programme. Our supplier terms and conditions clearly state a code of conduct that we would expect any supplier to adhere to and be accountable for. Regular performance monitoring is key also and we require high moral values and expectations from our supply chain also.
Parts of the business at risk
With a large supplier base, we recognise our role as supply chain leaders and key influencers in the global efforts to eradicate modern slavery and human trafficking. To this end, we maintain an approved supplier list, entry to which is subject to thorough due diligence. 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.
Due Diligence Process
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 rectifyingabuses and remediating any victims via our Trading Board
- 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 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.
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.
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.
This statement was approved by the Board of Directors on 19 June 2019
Chief Executive Officer
19 June 2019