Slavery and Human Trafficking Statement pursuant to the Modern Slavery Act 2015 (UK)

This statement is made by euNetworks Holdings LP, the ultimate parent company of the euNetworks group of companies and is published in accordance with the Modern Slavery Act 2015 which requires organisations with global turnover exceeding £36 million who conduct business in the UK to publish a Slavery and Human Trafficking Statement on their websites.

Organisation structure and supply chains

euNetworks Holdings LP “the Company” is a Western European provider of bandwidth infrastructure services, headquartered in London with operations located in:

Austria
Belgium
Bulgaria
France
Germany
Ireland
Italy
Spain
Switzerland
The Netherlands
United Kingdom

euNetworks employs approximately 330 people.

For more information about euNetworks, please visit our website: www.eunetworks.com.

Policies in relation to slavery and human trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies. These include:

Whistleblowing Policy:
- All employees have the right (and responsibility) to alert the Company if they become aware of another employee who is doing something that is illegal, in breach of regulation or other serious form of misconduct or dishonesty.
Business Ethics Policy:
- Employees actions must be legal and consistent with the Company’s policies and values.
Anti-slavery and Human Trafficking Policy
- Reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Sustainability Policy
- Reflects our commitment to promoting sustainability and our commitment to the promotion of a broader Environmental, Social and Governance (ESG) agenda. This includes commitment to developing a workforce that reflects the divers communities in the locations in which we operate, helping people achieve their true potential and managing the risk to anyone affected by our operations.

Due diligence processes

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted due diligence procedures.

Our due diligence procedures aim to:

Identify and action potential risks in our business and supply chains;
Monitor potential risks in our business and supply chains;
Reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
Provide protection for whistleblowers.

Risk assessment and management

Employees and contractors are engaged in accordance with local laws and regulations and euNetworks has zero tolerance to slavery and human trafficking.

euNetworks’ business and supply chain is assessed as having no or negligible risk of slavery and human trafficking. We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in Europe and in low-risk industries. Accordingly, it is not considered necessary to take any further steps by way of elimination or risk management.

Key performance indicators to measure effectiveness of steps being taken.

It continues to be a priority for euNetworks to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. As a signatory to the United Nations (UN) Global Compact we respect and support internationally recognised human rights standards and prevent any and all actions regarded as human rights violations in our operations and supply chain.

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This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Our Group’s slavery and human trafficking statement for the financial period ending 31 December 2022. It was approved by the Board on 22 May 2024.