Modern Slavery Statement

This Modern Slavery Statement relates to actions and activities during the fiscal year 1 April
2025 to 31 March 2026.

The statement sets out Fibre Assets Limited’s (FAL’s) commitment to preventing slavery and
human trafficking in its business activities, and the steps it has put in place with the aim of
ensuring that there is no slavery or human trafficking in its business and supply chains.

FAL has a commitment to act ethically and responsibility in all its business relationships and
has zero tolerance of slavery and human trafficking. It is aware that slavery and human
trafficking including servitude and forced labour exists within the UK and other economies and
is a growing issue.

Organisational structure and supply chains

FAL provides services to build Fibre Networks and to connect customers to these networks at
dedicated locations within the UK.

The structure of its business is focused on five areas: Build, Operations, Technology,
Commercial and Support operations.

High Risk Activities

As a business that is dependent upon the purchase of goods from its suppliers, FAL is
conscious the procurement department which is part of operations holds the highest risk of
exposure to modern slavery. FAL recognises the need to ensure its providers confirm their
due diligence as to how they manage this risk.

FAL has a responsibility to continually be alert
to the risk of modern slavery, however small or in whatever part of our business.
FAL implements the following measures to ensure compliance anti-slavery initiatives:

1. Policies
The Head of Talent (HR) is responsible for ensuring the creation and review of FAL
policies. The process undertaken is to review best practice and amend to fit the
evolving structure and operations of the business.
2. Risk Assessments
Multiple personnel have the responsibility to create and undertake risk assessments
within FAL’s business to ensure that it is compliant with current health and safety and
International Organisation for Standardisation (ISO) standards.
3. FAL’s procurement team undertake due diligence in relation to any known or
suspected instances of modern slavery and human trafficking.

Training

To ensure there is a good understanding of the risks of modern slavery and human trafficking
in our business and supply chains, FAL requires all its employees to undertake online training
on such matters during onboarding. This training is refreshed annually.

Policies
FAL is committed to ensuring that there is no modern slavery or human trafficking in its
business or our supply chains. This Statement affirms its intention to act ethically in its
business relationships.

The following policies set out FAL’s approach to the identification of modern slavery risks and
steps to be taken to prevent slavery and modern trafficking in its operations:
1. Whistleblowing policy – FAL encourages all its employees, customers, and other
business partners to report any concerns related to its direct activities or its supply
chains
2. Code of Conduct – FAL’s written code of conduct outlines the actions and behaviours
expected of its employees.

Due Diligence Processes for Slavery and Human Trafficking

FAL undertakes due diligence when considering taking on new suppliers and regularly reviews
its existing suppliers. FAL’s due diligence process includes building long standing
relationships with suppliers and making clear its expectations of business partners.
Additionally, it evaluates the modern slavery and human trafficking risks of each new supplier.

Performance Indicators

FAL uses the following key performance indicators (KPIs) to measure how effective it is in
ensuring slavery and human trafficking is not taking place in any part of its business or supply
chains including:
- Employees undertaking training as they join and on a yearly refresher basis on
identifying modern slavery and human trafficking.
- Employees completing via an online provider a Right to Work and a basic Disclosure
and Barring Service check
- Suppliers proving their compliance with modern slavery and human trafficking.

FAL’s Modern Slavery Statement and its effectiveness within its business and supply chain is
annually reviewed and updated. FAL’s Senior Leadership Team endorses this policy
statement and is fully committed to its implementation.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015(“The Act”)
and constitutes our slavery and human trafficking statement for our financial year ending
March 2026.