Modern Slavery Act Statement

The Modern Slavery Act 2015 (the “Act”) created offences in respect of slavery, servitude, forced or compulsory labour and human trafficking.

This is the Modern Slavery and Human Trafficking Statement of the Maintel Group, consisting of Maintel Holdings Plc and its subsidiaries.  It is made pursuant to s.54(1) of the Act and has been adopted by all companies in the Maintel Group as their respective slavery and human trafficking statement for the financial year ending 31 December 2022. In accordance with the requirements of the Act, the statement will be reviewed, updated and published annually and will therefore be reviewed and updated at the end of the 2022 financial year.

In accordance with the Act, this Statement is published on Maintel’s website, www.maintel.co.uk.

Our Business and Supply Chain

Our business involves the supply, configuration and support of telecommunications solutions worldwide and we had Group revenues of around £100m in 2022. We have around 500 employees, operating from 4 offices throughout the UK and one in the Republic of Ireland. Our supply chain therefore involves the sourcing, acquisition and supply of telecommunications services, software and hardware. It is far reaching and complex in nature, incorporating around 500 suppliers, most of which in turn will have their own suppliers.

The vast majority of our purchases of goods and services are globally recognised brands that are supplied through distribution or reseller channels within the UK; however many of the goods in particular are likely to have been produced elsewhere with some of these countries potentially posing a greater risk than that present in the UK. Some suppliers, however, are local UK companies, and their own employment policies are also taken into account.

Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. We are, however, committed to operating our business ethically and with integrity, and so as customers we play an active role in monitoring them to ensure that they operate in an ethical and transparent manner.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or elsewhere in our business. Should Maintel be made aware of any such practice it would act immediately and decisively to highlight and remedy it.  Our anti-slavery position reflects our commitment to acting ethically and with integrity in all of our business relationships.  This is supported by our policies on bribery and corruption, and whistleblowing.

Due diligence processes in relation to slavery and human trafficking

The directors of Maintel believe that the risk of it or any of its suppliers not adhering to the Act is small, but nevertheless has adopted the following processes as part of our initiative to identify and mitigate the risk:

• identify and assess potential risk areas in our supply chains;
• monitor potential risk areas in our supply chains;
• raise any concerns with suppliers with a view to obtaining comfort that they are adhering to our principles, failing which their contract would be terminated;
• protect whistle blowers.

In practice, this entails focussing on the larger suppliers to the Maintel Group, together with those which we consider to have inherent risk.

Maintel relies initially on desk-based research to verify that its suppliers are themselves adhering to the provisions of the Act. It does so by:

• ensuring that its larger and higher risk suppliers display statements on their websites that they are complying with the Act or equivalent local legislation;
• writing to all suppliers asking them to confirm compliance.

Maintel has also developed standard contractual wording for inclusion in its supplier agreements where feasible to do so, and has produced a Supplier Code of Conduct which is made available to all suppliers and which sets out minimum requirements for our suppliers.

Our Modern Slavery Act Statement and Policy will continue to be reviewed and developed as part of the Company’s regular Corporate Governance agenda.

This Statement has been approved by the board of Maintel Holdings Plc.

Dan Davies

Chief Executive Officer

6th March, 2024