Introduction

Manx Telecom is the leading Communications Solutions provider on the Isle of Man. Across the Group we have over 250 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 and equipment suppliers. Around 750 suppliers sell to us.

We recognise that our role as a major corporate entity on the Isle of Man goes beyond offering employees worthwhile careers, providing customers with the latest technology, and delivering increasing shareholder value to investors. 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 selling into the local market and a sixth unit, Global Solutions, operating internationally.

Slavery and Human Trafficking Policies

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Manx Telecom 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 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.

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.

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 are in the process of re-launching our mandatory training suite, which includes training on our expectations with regards to Modern Slavery and Human Trafficking.

We will continue to raise awareness within our existing team 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 was approved by the Board of Directors on 22 June 2017

gary sig

Gary Lamb
Chief Executive Officer

22 June 2017