Modern Slavery and Human Trafficking Policy

Last Modified: 10 July 2024

Zayo Group UK Limited and its affiliates (collectively, “Zayo” or “we” or “our” or “us”) is a pan-European organization whose activities and products include the delivery of communications infrastructure planning, service integration design, delivery and operation of dedicated optical communications and wavelength and network solutions to customer requirements.

A list of Zayo Group UK Limited’s United Kingdom and European affiliates can be found here.

Zayo Group UK Limited’s listing of its United Kingdom and European affiliates does not, expressly or otherwise, mean that all or any of such affiliates accept responsibility for the acts or omissions of each other.

Zayo is committed to the improvement of the environment surrounding its activities, products and services for the benefit of employees, customers and those within our sphere of influence.

Zayo is accredited to ISO 9001:2015 Quality and ISO 14001:2015 Environmental and also ISO 27001:2013 Information Security Management System.

Zayo is committed to prohibiting and driving out acts of modern day slavery and human trafficking within its business and its supply chains, including sub-contractors, and partners.

Zayo is cognisant of its obligations under the United Kingdom Modern Slavery Act 2015 and will ensure transparency within its organization and with suppliers of goods and services to our organization.

As part of Zayo’s due diligence processes into slavery and human trafficking, our supplier approval process will incorporate a review of the controls undertaken by our suppliers.  Imported goods from outside the United Kingdom and European Union and European Economic Area are potentially more at risk for slavery/human trafficking issues.  The level of management control required for these sources will be continually monitored.

Zayo will not support or deal with any business knowingly involved in slavery or human trafficking.  Zayo’s directors and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc.) and investment to ensure that slavery and human trafficking is not taking place within the organization and within its supply chains.

A full copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from Zayo’s Legal Department (eulegal@zayo.com) upon request.

This policy takes into account, and supports, the policies, procedures and requirements documented in our Integrated Management System, compliant with the requirements of ISO 9001:2015, ISO 14001:2015 and ISO 27001:2013.  The implementation and operation of this management system underlines our commitment to this policy.  Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached.

Additional procedures ensure that this policy is understood and communicated to all levels of staff and employees within Zayo, and that it is regularly reviewed to ensure its continuing suitability and relevance to Zayo’s activities.

The ultimate responsibility for slavery and human trafficking not taking place within the organization and its supply chain lies with Zayo’s Chief Executive Officer, who will ensure that it is given equal priority with other major business objectives.  Implementation of this policy is a line management responsibility at all levels, together with participation of all staff and employees.

This policy, supported by instructions, procedures and organizational arrangements within Zayo, is to be applied to all activities, products and services carried out by Zayo.  All Zayo directors, managers, supervisors, staff, employees, vendors, suppliers and subcontractors will adhere to this policy.  This policy will be revised and updated as necessary.