This statement is made on behalf of eSIM.net Group Ltd (“the Company”) in accordance with section 54(1) of the Modern Slavery Act (the “Act”) and constitutes its statement on slavery and human trafficking for the financial year ending 31 December 2025. eSIM.net Group Ltd is a limited company registered in England and Wales under company number 12117745.
As a key provider in the telecommunications sector, the Company always adheres to the highest ethical standards and ensures compliance with all applicable laws, regulations and rules.
Slavery and human trafficking are unacceptable, and the Company does not tolerate any form of forced labour, whether within its organisation or its supply chains. The Company recognises its moral and legal responsibility to contribute to the prevention of modern slavery and human trafficking and is committed to taking rigorous and effective measures to ensure that no such activities occur within its operations.
The Company’s objective is to achieve the highest ethical standards in this area and, at a minimum, to comply with applicable legislation. Every employee is responsible for remaining vigilant to the risks of modern slavery and human trafficking as part of their daily activities. In this regard, employees are required to report any concerns to management, and management is required to address them without delay.
This statement sets out the measures taken by the Company to identify, understand and manage the risks of modern slavery and human trafficking within its operations and supply chains. It also describes the arrangements in place to ensure that slavery and human trafficking do not occur in these areas.
Responsibility
Responsibility for the Company’s anti-slavery initiatives is as follows:
The Company’s Head of Human Resources has been designated as the primary point of contact for matters relating to modern slavery and human trafficking within its UK operations. The Company’s Commercial Director has been designated as the primary point of contact for matters relating to modern slavery and human trafficking within its supply chains.
The Company’s supply chain quality department is responsible for carrying out risk assessments relating to modern slavery and human trafficking.
Relevant Policies
eSIM.net Group Ltd has implemented the following policies that define its approach to identifying and preventing modern slavery and human trafficking within the Company and its supply chains.
The Company’s commitment to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking do not take place anywhere within its supply chains is reflected in its ethical trading policy and code of conduct.
The Company is committed to ensuring that its suppliers meet the highest ethical standards. They are required to demonstrate that they provide their employees with safe working conditions, treat them with dignity and respect, and act ethically and in compliance with the law in relation to labour practices.
Any serious breach of the business conduct and ethics policy will result in termination of the business relationship.
The Company encourages all its employees, workers, customers and other business partners to report any concerns relating to its operations or supply chains. This includes any situation that may increase the risk of slavery or human trafficking. The reporting procedure is designed to enable employees to make disclosures easily and without fear of retaliation.
Due Diligence and Compliance
As part of its approach to identifying and reducing risks, the Company carries out thorough due diligence before engaging with potential new suppliers. It regularly assesses its existing suppliers against the same criteria. This due diligence and assessment includes:
Assessing whether certain activities, countries or regions present a high risk of slavery or human trafficking by conducting supplier audits or assessments;
Taking steps to improve the practices of suppliers that do not meet the required standards, including providing guidance to suppliers through the audit and assessment process and face-to-face meetings at supplier premises;
Applying sanctions against suppliers that fail to improve their performance in accordance with an action plan or that seriously breach the ethical trading policy and business code of conduct, including termination of the business relationship;
Suppliers are asked to confirm in writing that they will adhere to the ethical trading policy and business code of conduct.
Measuring Performance
In order to measure the effectiveness of the Company in ensuring that modern slavery and human trafficking do not take place within its business or supply chains, it will;
Continue to adapt the supply chain verification system, through which the organisation assesses potential suppliers before they enter the supply chain; and
The organisation is currently conducting a review of its existing supply chains, which is expected to be completed by 2025, during which it will assess all of its current suppliers.
Training
The Company requires all key members of staff within its supply chain to undergo modern slavery training to ensure that they understand the risks of modern slavery and human trafficking entering the Company or its supply chains.
Dated 1 January 2025
