1.. Introduction

This statement is issued in accordance with the requirements of Section 54, Part 6 of the Modern Slavery Act 2015 and includes what policies Exclusive Networks Ltd (Exclusive) has taken to ensure that slavery and human trafficking does not take place within our business and also that of our Suppliers for the financial year ending 31 December 2020.

Exclusive is opposed to slavery, trafficking in persons and forced labor in any form. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners.

2. Organization Structure and Supply Chain

Exclusive is a company based wholly in the United Kingdom providing Cyber & Cloud Technology solutions to resellers globally, although the vast majority is UK business. We are headquartered in Alton with a second office in London and employ approximately 220 people.

Our offerings include the supply of hardware, vendor software licences and hardware maintenance, professional services (installation and configuration) on-site and remote help desks, and telephone support.

We use our supply chain to procure hardware for resale to our customers together with vendor software licences; maintenance services; consultancy services; network & communications services and datacentre services. We work with reputable global vendors, however we appreciate there is an increased risk and we take careful steps to qualify any offshore suppliers before engagement.

We endeavor to appoint suppliers that we can trust, respect and that provide transparency. We require our suppliers to meet our high expectation of standards and business practices. We expect our suppliers to comply with applicable laws and regulations wherever they may operate and in turn to promote and expect similar standards from their own suppliers.

3. Responsibilities

Our policies relating to Slavery and Human Trafficking are implemented and maintained under the control of our HR and Compliance departments.

Within our company the primary stakeholders for driving the policy are:
a. Group Risk & Compliance Officer
b. Head of Supply Chain Optimization
c. The HR Director

Responsibilities for ensuring that policies are implemented are defined below:

a. The Risk & Compliance Officer ensures that regular meetings of the stakeholders are held to ensure compliance.
b. The Head of Supply Chain assesses new and potential risks, ensure training is maintained, make changes to policy to meet changing regulatory practices and ensure that there is appropriate communication to staff and suppliers. They are responsible for risk assessments, investigation, due diligence and training as well as for our ongoing compliance with the Act.
c. The Head of Supply Chain is responsible for developing the appropriate controls and checks for the appointment of new suppliers and that existing suppliers are reviewed annually for continuing compliance with the controls.
d. The HR Director is responsible for providing the prescribed staff training.
e. The Risk & Compliance Officer will ensure that the Key Performance Indicators are achieved and that the policies implemented are effective and appropriate.

4. References to other policies

a. Exclusive Group Ethics & Code of Conduct

5. Due Diligence Checks on Suppliers

a. New Suppliers take on procedure pertinent to Modern Slavery:
• Initial selection of a new supplier that typically has an established operation within the UK and good track record within the industry for service and compliance.
• A Supplier Code of Conduct is issued which addresses the behaviour that we expect our suppliers to adhere to which includes modern slavery. This includes a signed declaration that the supplier will comply with the code.
• Questionnaire issued to suppliers and results reviewed. This includes specific questions regarding Slavery, Human Trafficking and employment of young persons to confirm compliance with the law. Where we perceive there to be an elevated risk, due to the nature of the supply, we will seek additional assurances.

b. Existing Suppliers
• Issue revised questionnaire of major points in new supplier questionnaire including those questions related to Slavery, Human Trafficking and employment of young persons.
• Regular issue of the Supplier Code of Conduct to confirm continued compliance.

6. KPI Overview

a. The Risk & Compliance Officer will be expected to hold regular, minuted meetings with the
b. Head of Supply Chain will be measured for the effectiveness of new supplier vetting and their
annual review.
c. The HR Director will be measured for the effectiveness of training of all staff.
d. The Risk & Compliance Officer will be measured for the update of the appropriate