Introduction

This statement sets out Glide’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As an ethical company, we respect the human rights of everyone who works for us and those who work on our behalf. Glide is committed to the prevention of slavery and human trafficking in all of its forms and will not tolerate or condone it within any part of its business or supply chains. We except similar high standard from our business partners.

Our Business

Glide consists of three operating companies:

• Glide Student & Residential Limited: providing manged internet services to high density accommodation throughout the UK and Europe.
• Glide Business Limited: providing ultrafast business broadband through fibre optic and leased lines for business parks and SME’s across the UK.
• Glide Shared Living Limited: providing internet, utility and communication services to customers in student accommodations and landlords with multiple properties.

Supply Chain

Our supply chain includes the procurement and installation of hardware, consumables, cabling products, software and 3rd party utilities and services including subcontracted labour.

We do not manufacture ourselves with exception of in house produced software platforms and very much rely on our suppliers to provide finished product including any test certification.

Due to the number of components in the electronic hardware we buy, it can be particularly complicated and will have many individual products from all over the world and an ever-changing group of suppliers. With these risks in mind, we have a set process (PC.03 Supplier & Contractor Control) and criteria for onboarding any new supplier to access for risk of modern slavery and human trafficking.

Understanding our Supply Chain

As part of our initiative to identify and manage risk, we aim to build and improve our systems to better:

1. identify, assess and monitor potential higher risk areas in our supply chains
2. mitigate the risk of slavery and human trafficking occurring in our supply chains through enhanced contract term controls (to the extent appropriate and obtainable),
3. train our employees as to these risks and the need to manage them, and;
4. train our employees as to these risks and the need to manage them, and;

Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.

Implementation

Management at all levels are responsible for implementing the objectives considered in this statement. Glide will monitor progress of our efforts in this area and issues (should they arise) and report back to our Human Resources team directly.

Effectiveness

In order to certify that we are effective in dealing with slavery and human trafficking in any part of our supply chains we will ensure that:

• The Modern Slavery and Human Trafficking Policy is effectively implemented throughout the operating companies by continually monitoring our processes and interviewing staff to access the success of our working arrangements;
• There is a system for supply chain identification, including adding modern slavery enquiries and controls to our vendor management and procurement polices (PC.03 Supplier & Contractor Control);
• New and existing suppliers are regularly audited to ensure that they are adhering to the requirements of the Modern Slavery and Human Trafficking Policy by the Group SHEQ Manager.

Training

Glide will provide training to educate staff on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not in place on our supply chain. Staff awareness training will be delivered during inductions and annual refresher sessions.

Monitoring and Reporting

Issues that are identified in relation to modern slavery and human trafficking should be immediately reported to the Board of Directors. More general issues in relation to the running of this policy will be reported back to the Human Resources team on an annual basis.

This statement will be reviewed annually and published on our website: www.glide.co.uk.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our groups slavery and human trafficking statement for the current financial year.