EXA Infrastructure | Modern Slavery Policy & Transparency

Last reviewed & updated: June 6, 2023

MODERN SLAVERY POLICY STATEMENT

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes EXA Infrastructure’s second statement. The previous statement was published in 2022 and set out the initial steps that EXA Infrastructure was taking to identify modern slavery and human trafficking within this area and seek how best to address this.

A copy is available at: Modern Slavery Policy Statement (exainfra.net). This statement builds upon EXA Infrastructure’s first Modern Slavery Act Statement and sets out the work undertaken during the financial year ending 31 December 2022 to, prevent modern slavery across the organisation and its supply chains.

EXA Infrastructure is a private company, incorporated in September 2021 and headquartered in London, UK. EXA Infrastructure is the largest dedicated digital infrastructure platform connecting Europe and North America, and owns 112,000 kilometres of fibre network across 32 countries. EXA’s network connects 300+ cities and offers 14 Tier 3-equivalent data centres, with sub-sea routes that include three transatlantic cables, one the lowest latency link between Europe and North America. EXA Infrastructure is wholly-owned by I Squared Capital. For more detailed information on EXA Infrastructure’s business and operations see https://exainfra.net/

APPROACH TO TACKLING MODERN SLAVERY

At EXA Infrastructure, we are committed to ensuring everyone who works for and with us is treated fairly, is able to work safely and has their human rights protected and respected. During 2022 there were approximately 460 people working for us around the world and thousands more across our global supply chains. We have a responsibility to prevent modern slavery from occurring in any form across our organisation and within our supply chains; we are committed to ensuring our organisational practices and risk-management approach support and facilitate this.

We maintained a targeted approach to identifying and tackling ethical issues, including modern slavery, in our organisation and supply chain. During 2022he impact of the global pandemic continued to be felt both within our organisation and across our supply chain. Whilst this has undoubtedly presented challenges we have conducted the following activities:

We continued to promote policies which highlight our ethical requirements with our people and suppliers.

As part of our commitment to combating modern slavery, Policies and guidelines across EXA Infrastructure set out our expectations of our people, stakeholders and suppliers. Our Supplier Code of Conduct is one such example and specifies requirements applicable to our suppliers and other third parties conducting business with or on behalf of EXA Infrastructure in the areas of compliance with laws, human rights, safe working conditions, and business integrity. This Code is maintain on our website and is subject to periodic review.

During 2022, we also continued to publicise our Corporate Code of Conduct to all staff which sets out our expectations of ethical conduct, fair, respectful treatment for our people.

As part of our Corporate Code of Conduct, we operate a confidential whistle-blower hotline, aimed principally at our employees but also available to others including those working in our supply chains which encourages disclosure of unlawful or unethical behaviour which extends to human rights violations like Modern Slavery in a confidential environment free from fear of retaliation. During 2022, we did not receive any reports relating to human rights violations. We continually monitor the implementation and adequacy of our Code of Conduct.

Our due diligence processes and approach to managing modern slavery risk continued to evolve.

As part of our efforts to monitor and reduce the risk of modern slavery occurring within our supply chains, we continued to undertake robust background checks on all new employees as part of our recruitment process to enable us to confirm their identifies. This process would have also enabled us to identify any indicators of forced labour or human trafficking.

For our suppliers, we incorporated contractual obligations in our standard paperwork requiring suppliers to comply with all applicable laws including laws on modern slavery and human trafficking. If a supplier does not meet our standards we will work with them to implement an action plan. Where suppliers fail to meaningfully engage with the action plan, then the contractual relationship with the supplier may be terminated.

We have also worked towards formulating a standard set of modern slavery questions that will be implemented into our tender processes.

LOOKING AHEAD

Over the next year EXA Infrastructure intends to build on the work that has already been carried out to date in preventing modern slavery risks in EXA Infrastructure’s supply chain. In particular, EXA Infrastructure will:

Establish an Ethical Trading/Human Rights Policy aligned with the Ethical Trading Initiative Base Code, and incorporates key International Labour Organisation Conventions and Recommendations, including clauses covering forced labour;
Implement our new set of modern slavery questions into all tender processes.
Commission an exercise to identify specific areas of EXA Infrastructure’s supply chains which could be exposed to modern slavery and ethical sourcing issues and the associated levels of risk. This will help target our activity and will inform the establishment of a modern slavery program across EXA Infrastructure;
As part of the refreshing of EXA’s Infrastructures Mandatory Training program, enhance our training offering to include modern slavery training for individuals directly engaging in related activity. Briefings will also be provided to teams, as necessary, to further embed understanding of the risks and response to any potential human rights issues.

EXA Infrastructure is a dynamic organisation with a constantly evolving business and supply chain and therefore recognises that there are always improvements that can be made to the way in which it works. EXA Infrastructure will include updates on these actions in its future statements.

This statement was approved by Senior Management on 06 June 2023