Modern Slavery Act 2015 Statement
This statement applies to Seapeak Telecom Limited and its subsidiaries, notably WaveCrest Networks Limited and WaveCrest Communications France SAS (collectively known as WaveCrest). At WaveCrest we are committed to running our business responsibly. We strive to maintain the highest ethical principles and to respect human rights. Our Company handbook sets out the overall standards and commitments towards ethical conduct, anti-corruption and legal compliance. These standards extend to our suppliers, partners, agents, directors, employees and subcontractors.
Our organisation and our supply chain
WaveCrest is a global CPaaS operator, with over 70 employees. WaveCrest currently procures, manages and sells CPaaS products and services for a global market.
Our stance on modern slavery
We have a zero tolerance to slavery and human trafficking. We will not tolerate any such activities within our own operations or within our supply chain and are committed to taking appropriate steps to ensure that everyone who works for WaveCrest – in any capacity, anywhere in the world – benefits from a working environment in which their fundamental rights and freedoms are respected.
WaveCrest undertakes appropriate due diligence checks on a representative proportion of its suppliers in order to assess compliance with the requirements of the Modern Slavery Act 2015.
Monitoring, Compliance and Training
We aim to prevent modern slavery or human trafficking in our business right from the start of our on-boarding of new suppliers. Our standard contracts with suppliers contain the following clauses relating to modern slavery:
(a) In performing its obligations under this agreement, the supplier shall and shall procure that its suppliers and subcontractors will comply with all applicable anti-slavery and human trafficking laws, statutes and regulations from time to time in force including but not limited to the Act or equivalent local legislation.
(b) The supplier shall implement an appropriate system of due diligence, audit and training to ensure that there is no slavery or human trafficking in its supply chains.
Our objective is to ensure an ongoing high level of understanding amongst our workforce of the risks of modern slavery and human trafficking in our supply chains and our business. We are committed to driving out acts of modern slavery and human trafficking from within our business and our supply chains. We currently have a number of employee policies in place to support this objective. These are included in our Company Handbook (which is available to all employees via the Company intranet); and referenced in employee contracts.
These policies include, but are not limited to:
Bribery, corruption and fraud control
Anti-Slavery and Human Trafficking
Health and safety
Anti – Harassment
Grievance and resolution
Our internal policies are reviewed in order to address modern slavery issues; and all workers and contractors undertake internal training to ensure the risks relating to modern slavery and human trafficking are understood and mitigated. All workers are provided with the details of our whistle blowing hotline through which they can make disclosures anonymously.
Evaluating our progress
Our activities are evaluated annually to re-assess risks, ensure that our risk management processes are adequate, and to reflect our commitment to the prevention of modern slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Seapeak Telecom Limited and its subsidiaries for the financial year ending 31st March 2021, and has been approved by the Board of Seapeak Telecom Limited.
Geoff Lockwood, Chairman, 1st April 2021