This statement is made on behalf of ESIM.NET GROUP LIMITED ("the business") pursuant to Section 54(1) of the Modern Slavery Act (the "Act") and constitutes its slavery and human trafficking statement for the year ending 31st December 2020, ESIM.NET GROUP LIMITED is a limited company registered in England and Wales (company number 12117745).

As a key provider in the eSIM sector, the business always works to the highest ethical standards and ensures that it complies with all laws, regulations and rules that are relevant to its business.

Slavery and human trafficking are totally unacceptable and the business will not tolerate forced labour of any description within the company or in its supply chains. The business recognises its moral and legal responsibility to help prevent modern slavery and human trafficking and commit to taking robust and effective steps to ensure no such activities arise in the operation of the business.

The aim of the business is to achieve the highest ethical standards in this regard and as a minimum, will comply with all relevant legislation. All employess of the company have a responsibility to be alert to the risks of modern slavery and human trafficking in their daily activities. With that in mind, employees are expected to report to management any concerns that an employeee may have in this regard and managers are expected to act upon any concerns raised without delay.

This statement sets out the action that the business has taken to identify, understand and address risks of modern salvery and human trafficking in its business and suply chains. It also sets out the steps put in place aimed at ensuring that there is no slavery or human trafficking in its business or supply chains.

Responsibility
Responsibility for the business anti-slavery initiatives is as follows:

  • Overall
The business HR Manager has been appointed as the key contact for issues relating to modern slavery and human trafficking within its UK operations. The business Commercial Director has been appointed as the key contact for modern slavery and human trafficking issues within its supply chains.

  • Risk Assessments
For the business supply chains, its Quality department are responsible for carrying out the modern slavery and human trafficking risk analysis.

Relevant Policies
ESIM.NET GROUP LIMITED has in place the following policies that set out its approach to the identification and prevention of modern slavery and human trafficking within the business and its supply chains.

The business commitment to acting etchically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within its supply chains is reflected within its Ethical Trading and Code of Conduct Policy.

The business is committed to ensuring that its suppliers adhere to the highest ethical standards. Suppliers are required to demonstrate that they provide their workers with safe working conditions, treat them with dignity and respect, and act ethically and within the law in their use of labour.

Serious breaches of the business Ethical Trading and Code of Conduct Policy shall lead to the termination of the business relationship.

  • Whistleblowing Policy
The business encourages all of its employees, workers, customers and other business partners to report any concerns related to activites within the business or its supply chains. This includes any circumstances that may give rise to an increased risk of slavery or human trafficking. The whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Due Diligence and Compliance
As part of the business initiative to identify and mitigate risk, the business undertakes due dilligence when considering working with potential new suppliers and regularly reviews the business existing suppliers against the same criteria. The due diligence and reviews include:

  • Assessing whether or not particular activities, countries or regions are high risk in relation to slavery or human trafficking by conducting supplier audits or assessments;
  • Taking steps to improve any substandard supplier practices including the provision of advice to suppliers through the audit and assessment process and face to face meetings on suppliers premises;
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate the business Ethical Trading and Code of Conduct Policy, including the termination of the business relationship;
  • Suppliers are requested to confirm in writing that they shall adhere to the business Ethical Trading and Code of Conduct Policy.
Measuring Performance
In order to measure the business effectiveness in ensuring that modern slavery and human trafficking is not taking place within its business or supply chains, it is;

  • Continuing to adapt the system for supply chain verification whereby the organisation evaluates potential suppliers before they enter the supply chain; and
  • Conducting a  review of its existing supply chains, expected to be completed within 2020, whereby the organisation evaluates all existing suppliers.
Training
The business requires that all key staff within our supply chain complete training on modern slavery to ensure they understand the risks of modern slavery and human trafficking infiltrating the business or its supply chains.

 
Managing Director
ESIM.NET GROUP LIMITED
Dated 1st January 2020