Modern Slavery and Human Trafficking Policy

1. Purpose and commitment

Intuity Communications Ltd is committed to conducting its business ethically, responsibly and with integrity.

We have a zero-tolerance approach to modern slavery, human trafficking, slavery, servitude, forced or compulsory labour, child labour and other forms of labour exploitation within our own operations and throughout our supply chains.

We expect the same standards from our suppliers, subcontractors, distributors, manufacturers, technology partners, network providers and other organisations working on our behalf.

This policy supports the principles and requirements of the Modern Slavery Act 2015 and relevant UK Government guidance on identifying and managing modern slavery risks within supply chains.

Intuity applies a proportionate, risk-based approach to preventing, identifying and responding to modern slavery.

2. Organisation, business and supply chains

Intuity Communications Ltd is a UK communications and technology services provider supporting private-sector, public-sector, education and other organisations across the United Kingdom.

Our services include:

• Unified communications and business telephony.
• Cloud communications and UCaaS.
• Contact centre and CCaaS solutions.
• Connectivity and network services.
• Cyber security.
• Managed IT and IT support.
• Business mobile services.
• Hardware, software and licensing.
• Professional and technical services.
• Associated installation, maintenance and support services.

Our business is principally service-led, but the delivery of those services depends on a wider technology supply chain.

Our supply chain may include:

• Telecommunications carriers and network operators.
• Cloud and software service providers.
• Technology manufacturers.
• Hardware distributors and wholesalers.
• Telephone, networking, security and computing equipment manufacturers.
• Software publishers and licensing providers.
• Data centre and hosting providers.
• Logistics, courier and distribution companies.
• Subcontracted engineering and technical services.
• Specialist professional services.
• Recruitment and labour providers where applicable.
• Other organisations providing goods or services required to support Intuity's operations.

Some technology products supplied by Intuity may contain components or raw materials sourced through complex international manufacturing and distribution chains. We recognise that visibility can reduce further down these supply chains and take this into account when assessing risk.

3. Policies relating to slavery and human trafficking

Intuity does not knowingly enter into or maintain a business relationship with an organisation involved in slavery, forced labour, human trafficking or serious labour exploitation.

Our approach is supported by our wider governance arrangements and policies relating to:

• Ethical business conduct.
• Equality and fair treatment.
• Health and safety.
• Whistleblowing and reporting concerns.
• Supplier management.
• Procurement.
• Information security.
• Risk management.
• Corporate and social responsibility.

Suppliers and subcontractors are expected to:

• Comply with the Modern Slavery Act 2015 where it applies to them.
• Comply with applicable employment and human-rights legislation.
• Prohibit forced, bonded, involuntary and trafficked labour.
• Prohibit unlawful child labour.
• Provide workers with lawful terms and conditions.
• Ensure wages and working hours meet applicable legal requirements.
• Provide safe and appropriate working conditions.
• Avoid unlawful retention of identity documents.
• Not require workers to pay inappropriate recruitment fees.
• Provide mechanisms through which workers can raise concerns.
• Apply equivalent standards, where appropriate, to their own supply chains.

Where proportionate to the risk involved, these requirements may be incorporated into supplier onboarding, contractual provisions, purchasing conditions or supplier reviews.

4. Due diligence

Intuity applies proportionate due diligence when appointing and managing suppliers and subcontractors.

The level of due diligence undertaken is based on factors including the type of product or service, geographical location, industry sector, labour model, complexity of the supply chain and our level of dependency on the supplier.

4.1 Supplier assessment

Before appointment, higher-risk suppliers may be required to provide information covering:

• Ownership and operating locations.
• Manufacturing or service locations.
• Use of subcontractors.
• Workforce arrangements.
• Modern slavery policies and statements.
• Labour and employment standards.
• Ethical sourcing arrangements.
• Supply-chain controls.
• Audit or certification arrangements.
• Previous modern slavery concerns or investigations.
• Procedures for reporting and remedying labour-rights concerns.

4.2 Modern Slavery Act compliance

Where a supplier is required to publish a Modern Slavery Statement under section 54 of the Modern Slavery Act 2015, Intuity may verify that an appropriate statement is publicly available and review the information contained within it.

4.3 Risk-based checks

Additional checks may be undertaken where:

• A supplier operates in a country or sector associated with increased labour exploitation.
• Manufacturing involves complex international supply chains.
• Temporary, migrant or agency labour is heavily relied upon.
• Goods contain commodities associated with recognised forced-labour risks.
• Subcontracting materially reduces visibility of workers or working conditions.
• Credible concerns have been raised about a supplier.
• The nature or value of a public-sector contract requires enhanced due diligence.

4.4 Ongoing monitoring

Due diligence does not end when a supplier is appointed. Material suppliers and suppliers assessed as presenting increased risk may be reviewed during the relationship.

Reviews may include updated questionnaires, policy reviews, contractual compliance checks, discussions with suppliers, review of publicly available information and requests for corrective actions.

5. Risk assessment

Intuity recognises that modern slavery can occur in any sector and that risk should be assessed according to the potential effect on workers rather than solely according to financial or reputational risk to Intuity.

5.1 Electronics and telecommunications hardware

Telephones, computers, networking equipment, security appliances and associated electronic products can have long international supply chains involving component manufacture, assembly and raw-material extraction.

The greatest exposure is generally further upstream in the manufacturing and raw-material supply chain rather than within Intuity's own UK operations.

5.2 Manufacturing supply chains

Some technology manufacturers operate global manufacturing and component sourcing arrangements covering multiple jurisdictions. Intuity therefore gives additional consideration to the labour and human-rights controls operated by manufacturers and authorised distribution partners.

5.3 Logistics and distribution

Warehousing, freight, transport and courier operations can involve subcontracting, temporary labour and agency workers. These characteristics are considered when assessing relevant suppliers.

5.4 Subcontracted technical services

Engineering, installation, cabling, field services and other subcontracted activities may involve multiple levels of subcontracting. Intuity seeks appropriate visibility of organisations and personnel materially involved in delivering services on its behalf.

5.5 Recruitment and temporary labour

Where recruitment agencies, temporary workers or other labour providers are used, particular consideration will be given to lawful recruitment, right-to-work arrangements, worker treatment and the risk of recruitment fees, coercion or exploitation.

5.6 Overseas services and support

Where services or support functions are delivered outside the UK, Intuity considers country, sector and labour risks as part of its supplier assessment.

6. Managing identified risks

Where increased modern slavery risk is identified, Intuity will take proportionate action according to the seriousness and likelihood of the risk.

Actions may include:

• Requesting further information from the supplier.
• Undertaking enhanced due diligence.
• Requesting evidence of employment or supply-chain controls.
• Requiring completion of a supplier questionnaire.
• Requesting a corrective action plan.
• Introducing additional contractual obligations.
• Increasing supplier monitoring.
• Requiring increased visibility of subcontractors.
• Requesting evidence of independent audits or assessments.
• Escalating concerns to senior management.
• Temporarily preventing further purchasing.
• Considering alternative sources of supply.
• Terminating the relationship where serious concerns cannot appropriately be resolved.

Any suspected criminal activity may be reported to the appropriate authorities.

7. Supplier and subcontractor requirements

Suppliers and subcontractors are expected to cooperate with reasonable requests from Intuity relating to modern slavery and ethical sourcing.

For strategically important, high-value or higher-risk suppliers, Intuity may require confirmation that the supplier:

1. Has assessed modern slavery risks within its business and supply chain.
2. Maintains suitable anti-slavery policies and controls.
3. Carries out appropriate due diligence on its own suppliers.
4. Provides modern slavery awareness or training to relevant personnel.
5. Maintains arrangements for workers to report concerns.
6. Investigates suspected violations.
7. Takes appropriate remedial action when problems are identified.
8. Informs Intuity of material modern slavery issues that could affect services supplied to Intuity or its customers.

Failure to cooperate with reasonable due diligence requirements may affect the supplier's continued approval.

8. Reporting concerns and whistleblowing

Employees, contractors, suppliers and other stakeholders are encouraged to report any concern or suspicion relating to slavery, human trafficking, forced labour or other labour exploitation.

Concerns may include indicators such as:

• Workers appearing to be under coercion or control.
• Retention of passports or identity documents.
• Excessive or unexplained deductions from pay.
• Workers being required to pay recruitment fees.
• Restriction of workers' freedom of movement.
• Threats, violence or intimidation.
• Inappropriate accommodation linked to employment.
• Excessive working hours.
• Unexplained third-party control of wages.
• Evidence of child labour.
• Workers being unable to leave their employment freely.

Concerns should be raised as soon as practicable with Intuity Communications Ltd.

Email: info@intuitycomms.com

Reports will be treated seriously and handled sensitively. No person should suffer detrimental treatment for raising a genuine concern in good faith.

9. Responding to an incident

Where a potential instance of modern slavery is identified, Intuity will consider the needs and safety of affected workers as part of its response.

Depending on the circumstances, actions may include:

• Protecting affected individuals from further harm.
• Obtaining appropriate specialist advice.
• Preserving relevant evidence.
• Escalating the matter internally.
• Engaging with the supplier.
• Agreeing and monitoring corrective actions.
• Notifying relevant authorities where appropriate.
• Reviewing whether existing due diligence controls need to be strengthened.

Intuity recognises that abruptly terminating a supplier relationship can sometimes increase the risk to vulnerable workers. Decisions will therefore consider both the seriousness of the issue and the potential effect of the proposed action on affected individuals.

10. Training and capacity building

Modern slavery awareness forms part of Intuity's wider approach to ethical procurement and responsible business.

Relevant employees will receive appropriate information, guidance or training to enable them to recognise and respond to modern slavery risks. Training will be proportionate to individual responsibilities.

Personnel involved in procurement, supplier selection, contract management, subcontractor management and operational delivery will receive additional awareness covering:

• What constitutes modern slavery and human trafficking.
• Common indicators of exploitation.
• Higher-risk sectors and supply chains.
• Risks associated with electronics and technology supply chains.
• Supplier due diligence.
• Escalation and reporting procedures.
• Appropriate handling of suspected incidents.
• Responsibilities when working with suppliers and subcontractors.

Modern slavery awareness will be included within relevant induction or ongoing compliance training. Refresher training or awareness updates will be provided periodically and where there are material changes to legislation, government guidance or Intuity's risk profile.

Training completion will be recorded where formal training is provided.

11. Monitoring effectiveness and performance indicators

Intuity will monitor the effectiveness of this policy and its supply-chain controls using proportionate Key Performance Indicators.

A target of 100% completion will apply to mandatory modern slavery training assigned to relevant employees and to enhanced due diligence identified as necessary for higher-risk new suppliers before approval, unless an authorised exception has been recorded.

Performance will be reviewed by management as part of Intuity's wider governance and supplier-management arrangements.

12. Continuous improvement

Intuity recognises that modern slavery risk management is an ongoing process.

We will seek to improve our controls by:

• Increasing visibility of important supply chains.
• Improving supplier risk classification.
• Strengthening supplier questionnaires where appropriate.
• Incorporating appropriate anti-slavery requirements into supplier arrangements.
• Reviewing emerging geographical and sector-specific risks.
• Improving employee awareness.
• Reviewing lessons from any concerns or incidents.
• Monitoring changes to government guidance.
• Updating this policy and associated processes accordingly.

13. Governance and responsibility

Overall responsibility for this policy rests with the Board of Directors of Intuity Communications Ltd.

Management is responsible for ensuring that proportionate controls are implemented within procurement, supplier management and service delivery.

Employees involved in supplier selection and management are responsible for applying these controls within their areas of responsibility and escalating concerns where appropriate.

14. Annual review and transparency

This policy will be formally reviewed at least annually and additionally following:

• Significant changes to Intuity's operations or supply chain.
• Identification of a material modern slavery risk.
• Significant changes to relevant legislation.
• Significant changes to UK Government guidance.
• Lessons identified following an incident or supplier review.

Where Intuity is legally required to prepare a slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015, a statement covering the relevant financial year will be approved and published in accordance with the Act.

Intuity may also publish such information voluntarily where this supports transparency, responsible procurement or public-sector contracting requirements.

15. Board approval

This policy is subject to formal approval by the Board of Directors of Intuity Communications Ltd.

16. Contact

Questions, concerns or requests for information relating to this policy should be addressed to Intuity Communications Ltd.

Email: info@intuitycomms.com

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