This Modern Slavery Statement is made by Vitrum Group Limited (“Vitrum”, “we”, “our”, or “the Company”) pursuant to Section 54(1) of the Modern Slavery Act 2015. It sets out the steps we have taken during the financial year ending June 2025 to prevent modern slavery and human trafficking in our business and supply chains.
Our Commitment
Vitrum is committed to upholding the highest standards of ethical conduct across all areas of our business. We fully support the principles of the Modern Slavery Act and are determined to identify, prevent, and address all forms of modern slavery and human trafficking within our operations and our supply chain.
About Vitrum
Vitrum is a UK-based fibre infrastructure provider, focused on designing, building, and delivering full-fibre broadband networks across underserved communities. While we operate solely within the United Kingdom, some of our materials and technologies are sourced internationally, which may carry a greater risk of unethical labour practices.
We believe everyone has the right to live and work freely, and we are committed to ensuring that our business and those we work with operate in a way that respects those rights.
Our Policies and Practices
We have adopted internal policies and supplier expectations that reflect our commitment to ethical conduct, fair employment, and human rights. These include:
- A Code of Conduct that applies to all Vitrum employees, contractors, and partners.
- Supplier due diligence practices to assess potential risk areas before engagement.
- Anti-slavery and trafficking clauses in contracts with higher-risk suppliers
- A Whistleblowing Policy enabling employees and stakeholders to report concerns in confidence.
- Ongoing risk assessments to monitor areas of the business or supply chain that may be vulnerable.
Supply Chain and Risk Areas
While our operations are UK-based, some of our key materials — including fibre, cabling, network equipment, and installation components — may originate from global suppliers in regions where labour rights protections vary.
We recognise that the following areas may carry higher modern slavery risks:
- Imported construction and networking materials from countries with lower transparency standards.
- Subcontracted labour in construction and installation.
- Technology or component sourcing through extended supply chains.
To address these risks, we take a proportionate, risk-based approach when evaluating new and existing suppliers. This may include:
- Supplier self-assessment questionnaires.
- Contractual obligations relating to modern slavery.
- Auditing and supplier reviews for high-risk activities.
Training and Awareness
We are developing internal training and awareness materials to help our staff understand the signs of modern slavery and know how to act if they have concerns. This training will be extended to relevant personnel and partners working in higher-risk roles.
Measuring Effectiveness
To ensure the effectiveness of our efforts, we will:
- Monitor compliance with supplier policies.
- Review contract terms and risk registers regularly.
- Act on any concerns raised through whistleblowing or other channels.
- Continue to review and improve our procedures annually.
Approval
This statement has been approved by the Board of Directors of Vitrum Group Limited on 6th June 2025 and will be reviewed and updated annually.
Signed,
David O’Connor
Director, Vitrum Group Limited
Date: 5th June 2025