Modern Slavery Act Transparency Statement

Cornerstone Telecommunications Infrastructure Limited (“Cornerstone”) provides and maintains the passive infrastructure on which Vodafone, Telefonica and other customers affix their antennas and associated cellular radio equipment. In accordance with s.54 of the Modern Slavery Act 2015, this statement sets out the steps Cornerstone has taken during the 2023-2024 financial year to try and ensure that slavery and human trafficking are not taking place in any of our supply chains and any part of our business.

Cornerstone recognises the importance of the Modern Slavery Act 2015 in protecting the liberty of all people. The Board of Cornerstone fully supports and promotes compliance with this legislation.

Cornerstone employs approximately 250 people throughout the UK. We also engage with a range of other service providers and equipment suppliers/partners to deliver our projects. The supply chain for our core activities consists of established suppliers/partners within the telecoms industry, providing services such as site acquisition, design, construction, and maintenance. We also work closely with providers of the following products and services:

• Site providers;
• Real estate and town and country planning professional services;
• Legal services;
• Design and construction services for existing and new assets;
• Maintenance and repair services for our asset base; and
• IT software and managed services.

Our suppliers/partners are predominantly UK-based, and we do not consider our industry and supply chain to be particularly susceptible to modern slavery and human trafficking. Our partners within the supply chain are predominantly providing highly technical products and/or services where we consider the risk of modern slavery practices, such as forced labour or exploitation, to be low. Nevertheless, we are vigilant regarding this risk.

To ensure a strong supply chain, Cornerstone has established baseline standards that must be met by our suppliers. Suppliers are obliged to follow our Supplier Code of Conduct, the United Nations Convention on the Rights of the Child, International Labour Conventions 138 and 182, and align to the UK Modern Slavery Act of 2015. We expect all of our suppliers and business partners to conduct their business lawfully and ethically. The adoption of business practices that prevent or eliminate modern slavery and human trafficking from taking place within their supply chains is a priority.

Key to the success of Cornerstone is the development of strong partnerships with strategic suppliers, and that means we look for partners who can work within established service levels, provide quality deliverables, and assist us in meeting and exceeding the expectations of our customers. We collaborate closely with our suppliers to ensure they share Cornerstone’s values and understand the importance of conducting business with honesty and integrity.

We carry out modern slavery due diligence on our suppliers/partners via robust internal sourcing, onboarding, and contracting processes. Our corporate Procurement Policy provides clear guidance to our employees on the actions we must take when sourcing products and services for the business, including the due diligence required for prospective partners and suppliers. As part of our onboarding process, new suppliers (depending on pre-contract risk assessment) are subject to detailed pre-qualification reviews and assessments of the supplier’s ownership, ISO Accreditations (or equivalent), commitment to best practice standards and/or legislation, financial position, capacity, capability, HSQE status and information security protocols. If, as part of this process, we were to identify a prospective supplier as being at risk of not achieving our standards (including in relation to compliance with the Modern Slavery Act 2015), then we would work with them to remedy any issues. If we cannot find a resolution with them then we will not trade with that company.

Our interaction and monitoring of our suppliers continue throughout the contracted term. We meet with our leading suppliers regularly to review Safety, Delivery, Risk and Commercial Contract Management, and carry out scheduled site inspections. It is normal for business-critical partners to also receive unannounced face to face site visits to check workforce accreditation and welfare facilities. These reviews and site visits help us to identify whether any modern slavery practices are taking place within that supplier’s business. If that were to be the case and the supplier was unable to resolve the problem, this would lead us to terminate our relationship with them and report the matter to the relevant authority, if appropriate.

We operate a whistleblowing policy under which employees can report wrongdoing within the workplace. Employees should first report issues to their line manager and then to the People Director or the Head of Legal and Compliance. We encourage employees to report any instances of unethical practices by notifying the relevant person if they suspect or become aware of any modern slavery practices occurring within our business and/or supply chain.

To maintain awareness of the risk of modern slavery and human trafficking entering our supply chain or our business, and to assist in managing such risks on an ongoing basis, over the coming year we commit to do the following:

• Internal Communications – We will continue to issue communications to all Cornerstone colleagues informing them of the continued need to adhere to the Modern Slavery Act 2015. Communication raises awareness of the issue, and we hope will encourage further innovation and engagement in relation to our approach to combating modern slavery.
• Training – During the 2023/24 period, a review was conducted of how colleagues are trained regarding Modern Slavery. A new training module will be introduced and an annual training session for awareness to ensure staff understand our position on modern slavery and are vigilant in preventing it from happening in our business.

Supplier Strategy – We will continue to review and automate our supplier onboarding procedures and strategies to increase resilience and do what we can to ensure modern slavery or human trafficking is not taking place or being facilitated by our supply chain or business.

This statement is made in accordance with Section 54(l) of the Modern Slavery Act 2015 and constitutes Cornerstone’s modern slavery and human trafficking statement for the financial year commencing 1 April 2023 and ending 31 March 2024.

Pat Coxen
CEO
Cornerstone
Date: 3/03/2024