Modern Slavery Policy

Last reviewed: AUGUST 2026

1. Purpose

This policy sets out Utelize Communications Ltd’s commitment to preventing modern slavery, human trafficking, forced labour and exploitation within our business and supply chains. We are committed to acting ethically, with integrity, and in compliance with applicable laws, including the Modern Slavery Act 2015. This policy is published to explain the standards we expect within our business and from those we work with.

2. Scope

This policy applies to all employees, workers, directors, contractors, suppliers and business partners who work for or on behalf of Utelize Communications Ltd. It is intended for both internal use and publication on our external website.

3. Policy Statement

Utelize has a zero-tolerance approach to modern slavery and expects the same standards from those we work with. We will not knowingly support, work with, or purchase from any organisation involved in slavery, servitude, forced or compulsory labour, human trafficking, child labour or any form of exploitation.

4. Responsibilities

Senior management is responsible for ensuring this policy is implemented and reviewed. Managers are responsible for promoting awareness within their teams and escalating concerns. All employees are expected to act with integrity, remain alert to potential risks and report any concerns promptly.

5. Suppliers and Business Partners

We expect suppliers and business partners to comply with applicable employment, labour and human rights laws, treat workers fairly, and maintain appropriate standards in relation to recruitment, working conditions, pay, working hours and freedom from coercion. Where appropriate, we may request evidence of their approach to preventing modern slavery and reserve the right to end relationships where serious concerns are identified and not addressed.

6. Due Diligence and Risk Management

We take a proportionate, risk-based approach to assessing modern slavery risks. This may include supplier checks, contractual terms, management review, and escalation of concerns where higher-risk activities, geographies or services are identified.

7. Reporting Concerns

Anyone who suspects modern slavery or labour exploitation within our business or supply chain should raise their concern as soon as possible. Employees should report concerns to their line manager or a member of senior management. Suppliers, customers or other external parties should raise concerns through their usual Utelize contact. Concerns may also be raised under our Whistleblowing Policy where applicable. Reports will be treated seriously and handled sensitively. We will not tolerate victimisation of anyone who raises a genuine concern in good faith.

8. Training and Awareness

We will promote awareness of modern slavery risks through appropriate communication, guidance and training relevant to employees’ roles, particularly for those involved in supplier selection, purchasing, recruitment or contract management.

9. Review

This policy will be reviewed periodically and updated where necessary to reflect changes in legislation, guidance, business operations or supply chain risk.

Approval: This policy was approved by Sally Ainsley, Group Operations Director, Utelize Communications Ltd.