Last reviewed & updated: December 6, 2022

Modern Slavery Policy Statement 

EXA Infrastructure is a private company 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 information, see

At EXA Infrastructure, we strive to maintain the highest standard of ethical principles and to respect human rights, both within our organisation and by encouraging high standards in our supply chain.  To this end, all our employees are trained on and review and sign up to our Code of Business Conduct and Ethics (“Ethics Policy”) on an annual basis. As part of our Ethics Policy, we operate a confidential whistle-blower hotline to encourage disclosure of unlawful or unethical behaviour in a confidential environment free from fear of retaliation. All our employees are made aware of our whistle-blower hotline, which they can call to report any form of human rights violation. We continually monitor the implementation and adequacy of our Ethics Policy.

We have a zero-tolerance approach to slavery in any form and are committed to continuing to build on our practices to combat slavery and human trafficking. Although we believe that due to the nature of what we do, the risk of slavery in our supply chain is relatively low compared with other industries, we are not complacent about this risk and are alert to the fact that we have suppliers in geographical areas carrying out work for us that could be susceptible to the exploitation of people.

For all suppliers, we include we maintain a Supplier Code of Conduct on our website which 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.  We also include 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 implement an action plan, which may include termination.

EXA will annually review and ensure that our risk management policies are adequate.  This statement covers the 2021 financial year and is made in accordance with the Modern Slavery Act of 2015,