Modern Slavery Statement 2025

This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and outlines the actions taken by Emtelle UK Ltd. during the financial year 2024/2025 to prevent modern slavery, child labour, and human trafficking within our operations and supply chains.

Our Business & Global Footprint

Emtelle UK Ltd. is a leader in the supply of pre-connectorised, blown fibre cable and ducted network solutions. With approximately 800 direct employees across multiple manufacturing sites, we are committed to ethical business practices and sustainable growth. Our Code of Conduct, Business Ethics Policy, and Sustainability Strategy support our ambition to deliver positive economic, social, and environmental impacts.

We are fully committed to eliminating all forms of modern slavery.

Definitions

While not formally defined in UK law, the International Labour Organization (ILO) defines:

Modern Slavery as the exploitation of individuals through threats, violence, coercion, deception, or abuse of power, rendering them unable to leave or refuse.
Child Labour as work that deprives children of their childhood, potential, and dignity, and is harmful to their physical and mental development.

Actions Taken by Emtelle

Recruitment and Workforce Practices

Recruitment procedures have been reviewed and enhanced, including mandatory face-to-face verification of original right-to-work documents and training on detecting fraudulent submissions.
Annual right-to-work checks are in place.
Our revised Personal Details Form includes bank account verification against the employee’s legal name, with manual verbal checks on discrepancies or changes.

Training and Awareness

Senior leadership, site managers, HR, and recruiting managers participated in a dedicated training session delivered by Scotland Against Modern Slavery to identify red flags within our workforce and supply chain.
Targeted guidance was also delivered to our procurement and supply chain teams

Ethical Employment and Support

We are an equal opportunities employer and treat all employees fairly, irrespective of origin or status.
High retention and employee engagement reflect our stable and supportive work environment.
All employees are expected to comply with our Code of Conduct, which mandates respectful behaviour and legal compliance.
Labour provider relationships are reviewed annually to ensure full compliance with Agency Worker Regulations and best practices.

Wellbeing and Whistleblowing

Our wellbeing initiative, now rebranded as W.E. at Emtelle, promotes employee wellness and engagement and fosters early detection of issues.
We provide access to an Employee Assistance Programme (EAP) and a Global Whistleblowing Policy, enabling confidential reporting of any concerns.

Supply Chain Due Diligence

Emtelle has achieved multiple levels of EcoVadis accreditation and enforces a live Sustainability Strategy, requiring all suppliers to comply with relevant local, national, and international labour laws.
Prior to engagement, potential suppliers undergo due diligence checks covering health, safety, environmental, and labour standards.
Our procurement contracts mandate compliance with anti-slavery legislation and include clauses for breach notification and cooperation.
Emtelle reserves the right to audit suppliers at any time.

Monitoring and Compliance

We monitor supplier audit returns for risk indicators and red flags.
While current monitoring does not extend beyond Tier 1 suppliers, we require our direct suppliers to ensure compliance throughout their own supply chains.
No instances of modern slavery or trafficking have been identified in our operations or supply chain to date.

Prevention of Child Labour

Emtelle UK Ltd. is committed to safeguarding against child labour through the following measures:

Employing individuals aged 16 or over only.
16- to 18-year-olds are only employed part-time or as full-time apprentices.
All employees receive written contracts outlining their terms of employment.
Wages are paid in accordance with National Minimum or Living Wage standards based on age.
Working hours comply with the Working Time Directive.
Right-to-work checks include age verification.
Work experience placements are only offered to students aged 15 or above.

Our HR team plays a critical role in these checks to ensure legal and ethical hiring practices.

Commitment and Governance

This statement reflects Emtelle UK Ltd.’s ongoing commitment to ethical business conduct, the prevention of modern slavery, and the protection of vulnerable individuals in our business and supply chains.

We will continue to assess, monitor, and enhance our processes, ensuring that all due diligence is maintained and whistleblowers are protected.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Emtelle UK Ltd.’s Modern Slavery, Human Trafficking, and Child Labour Statement for the financial year ending April 2024.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Emtelle UK Ltd.’s Modern Slavery, Human trafficking, & Child Labour statement for the financial year ending April 2025. I confirm this is a true and accurate account of Emtelle UK Ltd.’s commitment and position.

Tony Rogers

Group Chief Executive Officer
Emtelle UK Ltd

08/04/2025

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