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Modern Slavery Statement 2023

This statement is made in reference to section 54 of the Modern Slavery Act 2015 and sets out the steps that Emtelle UK Ltd has taken and is continuing to take to ensure that modern slavery, child labour or human trafficking is not taking place within our business or any of our supply chain during the financial year 2022/2023.

Our Business & Global Footprint

At Emtelle UK Ltd we are the supplier of choice to many operators across the globe with our experience and innovation in manufacturing industry-leading pre-connectorised, blown fibre cable and ducted network solutions. We are a responsible and ethical employer with over 800 directly employed employees across 9 manufacturing facilities, worldwide supplier and customer and have a code of conduct, business ethics policy and a sustainability vision and strategy, that delivers positive impacts economically, socially, and environmentally. We are committed to the elimination of Slavery in any form.


Although not defined in law The ILO (International Labour Organisation) defines Modern Slavery as the exploitation of a person where they cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power.

The ILO defines Child Labour as ‘work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. It refers to work that is mentally, physically, socially or morally dangerous and harmful to children; and/or interferes with their schooling by: depriving them of the opportunity to attend school; obliging them to leave school prematurely; or requiring them to attempt to combine school attendance with excessively long and heavy work.

Emtelle Direct Actions

We have reviewed our recruitment practices as part of our Front-Line Leader training and have been educating all recruiting managers on the importance of face-to-face checks with original copies of right to work documents. We have also upskilled the HR Team in how to identify fraudulent documents.

We have updated our Personal Details Form as part our GDPR review, we can now confirm it includes details such as name of Bank Account. There is the obvious expectations for bank accounts to match the employees full name. Any discrepancies should be identified and investigated where the primary account is different.

The Senior Management Team, Managers of all Sites, all recruiting managers and HR recently attended an education session with Scotland Against Modern Slavery where they were educated around the red flags to look for in both our workforce and supply chain.

Emtelle is an equal opportunities employer and does not discriminate treatment between local and migrant employees. Emtelle has a stable workforce and enjoys high levels of employee retention, engagement, and development. We expect all our employees to operate in line with our Code of Conduct which requires employees to treat other people with respect and to comply with all laws and regulations.

The HR Team have been working closely with our local labour providers to ensure that Agency Worker Regulations and best practice is also maintained by our supply chain.
In this last year we have just created Wellbeing Ambassadors who will be raising awareness of the important of looking after both self and others. This would hopefully help highlight any issues identified early. Emtelle look forward to reporting on progress next year.

We also have an EAP Scheme and Whistle Blowing Policy under which employees are encouraged to confidentially seek advice and report any suspected wrongdoing. We also have a set of Values at Emtelle which we expect all employees to adhere to including Safety, Respect, Integrity & Teamwork.

Emtelle UK Ltd’s Supply Chain

We have achieved Gold Ecovadis Accreditation and have a live Sustainability Strategy which demands that we and businesses in our supply chain comply with all applicable laws. Emtelle requires our suppliers to treat all their employees with respect, pay them a fair wage and comply with all local, national, and international legislation concerning working conditions, working age requirements, and any other relevant legislation.

Before engaging a new supplier, we complete due diligence on any potential supplier including health, safety, environmental and labour practices and will not engage with organisation’s who fall below the Group’s required standards. Our procurement processes contractually require our contractors and consultants to make a declaration of intent and comply with antislavery laws and notify us of any actual or potential breaches. As part of ensuring that there is no slavery in the supply chain suppliers must be able to demonstrate compliance with this policy. Emtelle UK Limited retain the right to audit our suppliers at any time at their discretion.

Emtelle are fully committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. To date no issues have been identified.

We will apply due diligence processes across the supply chain to prevent modern slavery, human trafficking and child exploitation. Our assessment will include Identifying and assessing potential risk areas in our supply chains then Monitoring any potential high risk areas in our supply chains, and educating our workforce and supply chain that we will always protect whistle blowers.

Our supplier audit returns are monitored for red flags or risks identified. Our supply chain monitoring activities currently do not extend below the tier one supply base, we expect and rely on our supplier to monitor their supply base for compliance against our supply chain policies.

In addition, through our Wellbeing Ambassador team, we have a live action to create a ‘safe space’ on each site which will include communication tools, posters and information in relation to the warning signs our employees should watch out for.

Prevention of Child Labour

We are fully committed to ensuring there is no child labour exploitation in our business, supply chain or its sub-contractors. We commit to:

  • Only employing people over the age of 16
  • Employees between ages 16 to 18 in the UK will only be employed part-time or as an apprentice in a full-time training position
  • All employees will be issued with an employment contract outlining the terms and conditions of service
  • All employees will be paid as a minimum the national minimum wage or Living Wage dependent on age
  • All employees working hours will adhere to the Working Time Directive
  • Employee’s age will be checked as part of the right to work process to confirm they are eligible to work in the UK or relevant jurisdiction
  • Only students aged 15 or over will be offered work experience placements

HR will play a key role in checking right to work documentation to ensure employees are of the appropriate age. In 2022 no Slavery issues related to operations, or the supply chain were reported.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Emtelle UK Ltd’s Modern Slavery, Human trafficking, & Child Labour statement for the financial year ending April 2023. I confirm this is a true and accurate account of Emtelle UK Ltd’s commitment and position.


Tony Rogers

Group Chief Executive Officer
Emtelle UK Ltd 


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