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Introduction

This Statement is made on behalf of Transaction Network Services (UK) Limited (“������ý”).

The Modern Slavery Act 2015 came into effect on 29th October 2015. The Act requires companies doing business in the UK which supply goods or services and have an annual global turnover exceeding £36 million to disclose information regarding their policies to eradicate slavery and human trafficking from their supply chain and within their business. Based on the principles that form part of our Code of Conduct, ������ý is committed to improving our practices to combat slavery and human trafficking.

Organisation’s structure

We are part of the Transaction Network Services Group of companies (������ý Group). Our parent company is Transaction Network Services Inc. which has its global headquarters in Reston, Virginia, USA.

The ������ý Group is committed to high standards of ethical conduct and conducting its business in compliance with all applicable Laws in its relevant operating countries around the globe.  In support of this commitment, the ������ý Group has adopted a Code of Conduct and as part of that Code of Conduct the ������ý Group has committed to obey all applicable Laws governing its business conduct worldwide and adopting fair employment practices.

Our Business

������ý Group is a leading global provider of data communications and interoperability solutions and provides services to customers in over 60 countries. By combining innovation, advanced technology, experience and service excellence, ������ý Group delivers managed communications solutions to service providers and enterprises on a global scale. Thousands of companies from the retail, banking, financial markets and telecom industries count on ������ý to build and manage their mission critical communications platforms, improving their ability to communicate and transact efficiently and effectively.  ������ý Group operates some of the largest real-time community-based networks in the world, enabling industry participants to simply and securely interact and transact with other businesses, while connecting to the data and applications they need over highly available platforms.  For further details of the ������ý Group companies, the countries in which they operate and our businesses, please refer to our website: .

Our supply chains

In order to provide our services, we need to procure a range of goods and services across a diverse supplier base which includes large national or international corporations (such as telecommunication network and equipment providers) as well as small and medium-sized businesses.

Our Stance on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  We will not tolerate any such activities within our own operations or within our supply chain.

Risk Assessment and Due diligence processes

As part of our initiative to identify and mitigate risk and ensure compliance with the Modern Slavery Act, we will continue to maintain relevant business processes and systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains and undertake necessary due diligence checks.
• Protect whistle blowers.

Supplier adherence to our values and ethics

We have zero tolerance to slavery and human trafficking.  We are committed to taking appropriate steps to ensure that everyone who works for or with ������ý in any capacity has a working environment in which fundamental rights and freedoms are respected. As part of our new supplier set up process, we will look to implement an appropriate validation process, such as anti-slavery questionnaire (to be completed by the relevant supplier).

Training

We aim 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. Our recruitment policy aligns with our Code of Conduct and all new employees are required to familiarise themselves with the contents of our Code of Conduct as part of their induction.  As part of our induction programme, ������ý will require new employees to familiarise themselves with Slavery and Human Trafficking Statement and the separate Anti-slavery and Human Trafficking Policy.  All ������ý employees will be expected to adhere to Anti-slavery and Human Trafficking Policy as well as our Code of Conduct. All employees are provided with the details of an independent whistleblowing hotline to whom they can make disclosures anonymously.

This statement has been approved by the board of directors of ������ý UK and is made according to the requirements of section 54 of the Modern Slavery Act 2015 for the financial year ending 31 December 2021. This statement applies to all UK subsidiaries within the ������ý Group that are required to have a modern slavery statement.

Dated: 26^th January 2024