Fibrenet Global Anti-Human Trafficking and Slavery Statement

Fibrenet Global Ltd

Anti-Human Trafficking And Slavery Statement

Introduction

Fibrenet Global Ltd is committed to treating everyone in our business and supply chains with dignity and respect. We take seriously our role in combatting human trafficking and slavery in our supply chain, and we work to ensure the well-being of the people who help make our products and provide materials to our supply chain. This statement sets out the steps Fibrenet has taken to address the risks of human trafficking and slavery in our supply chain.

The U.K. Modern Slavery Act of 2015, require certain commercial organisations to publish statements describing the steps the organisation has taken during the prior financial year to ensure that human trafficking and slavery are not taking place in their operations or supply chains.

This Anti-Human Trafficking and Slavery Statement is made pursuant to the requirements of the above statutes and regulations. For fiscal year 2024/25, this statement addresses our ongoing efforts to combat and prevent human trafficking, slavery and forced, compulsory or involuntary labour in our supply chain.

Our Business and Supply Chain

Fibrenet Global is a provider of optical transceivers, own branded and vendor branded as well as associated peripherals including patch cords, attenuators, and associated network equipment. Fibrenet provides equipment to  Broadband Communications, Commercial Aerospace, Industrial, Information Technology and Data Communications, Military, Mobile Devices, and Mobile Networks.

Our global supply chain consists of approximately 5 Tier 1 Direct suppliers. Fibrenet defines its Tier 1 Direct suppliers as those who provide raw materials and goods for production and with which we have direct transactional business.

Policies and Commitment to Prevention of Human Trafficking

Fibrenet Global has several policies that reflect our commitment to eradicate human trafficking and slavery in our operations and supply chain.

In 2021, Fibrenet Global issued its Global Human Rights Policy which reflects our global commitment to human rights and the integration of this commitment into our operations and supply chains. This policy unites our core policies related to human rights worldwide and reflects our belief in the principles stated in the UN Guiding Principles on Business and Human Rights.

Fibrenet Global strictly prohibits human trafficking and slavery. Our code of conduct for suppliers expressly prohibits the use of forced, bonded (including debt bondage) or indentured labour, involuntary or exploitative prison labour, slavery or trafficking of persons. This includes transporting, harbouring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labour or services.

We also require that there are no unreasonable restrictions on workers' freedom of movement in the facilities in which they work, and no unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment agreement in a language that the worker understands. The agreement must describe the terms and conditions of employment, and no changes may be made to the employment agreement, except where necessary to meet local law and provide equal or better terms. All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment. We and our suppliers may not hold or otherwise destroy, conceal, confiscate or deny access by employees to their identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law. Workers shall not be required to pay employers' or agents' recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, the fees shall be repaid to the workers.

Furthermore, in 2021, Fibrenet Global adopted its Responsible Minerals Policy ("RMP"). The RMP demonstrates our commitment to responsible mineral sourcing and provides details about our responsible mineral sourcing program, which is based on RMI's Responsible Minerals Assurance Process. Our program employs a risk-based approach to validate smelters and refiners based on their mineral procurement processes. We are mindful of the potential human rights abuses associated with mineral sourcing and remain diligent to ensure our sourcing of minerals does not perpetuate or contribute to such abuses.

Due Diligence/ Verification

Fibrenet Global communicates its standards to the supply chain and has the right to use a third-party data collection provider to assist with the identification and risk mitigation of any human trafficking and slavery issues throughout our global supply chain. Fibrenet Global's suppliers are required to affirm that they will conduct their businesses in accordance with our standard operating procedures, which includes our right to assess suppliers and inspect their facilities.

Risk Assessment

In 2023-2024, the scope of Fibrenet Global's supplier risk assessment included all Tier 1 Direct suppliers. Fibrenet Global also further refined the scope of its geographical-based risk assessment to focus on suppliers located in high-risk geographies as identified in the Global Slavery Index ("GSI") we are able to extract the most risk-sensitive data from our supply chain, while also detecting any unexpected deviations from low-medium risk suppliers.

Fibrenet Global's supply chain mapping and surveying will continue to be conducted annually. Data from this exercise will provide metrics to allow us to understand the scope of any potential human trafficking or slavery issues in our supply chain and also to inform remediation decisions of any incidents of trafficked or forced labour in our supply chain.

Assessment of Effectiveness

For Fibrenet Global, effectively managing human-trafficking and slavery risks means we must be able to facilitate positive change through our processes and activities. This starts with a strong foundational program in which continuous improvement is a core principle. Additionally, our programs are evolutionary and flexible to allow us to adapt to new regulations or localised or global events requiring our attention.

Our revised geographical-based risk assessment methodology has allowed for a more meaningful focus on those regions where the greatest risk for human-trafficking and slavery may be present. This approach, coupled with increased multi-lingual supplier communications, has helped us increase our overall supply chain assessment response rate year over year.

Accountability

Fibrenet Global maintains a compliance program intended to ensure a culture of ethics and compliance among our workforce. This program includes periodic compliance training, regular communications to employees, annual certifications and multiple means of reporting concerns.

Suspected violations can be anonymously reported by phone or email. These reporting mechanisms are available both to employees and external parties. Violations of any of these policies can result in corrective action, up to and including termination.

Training

Fibrenet Global continues to train key employees, who have direct responsibility for supply chain management or for recruitment of new employees, on human trafficking and slavery. This training includes topics such as identification of human trafficking warning signs and prevention of human trafficking within our organisation and in our supply chain as well as direction to reporting mechanisms. Additionally, we have finalised our plan and training materials for Environmental, Social and Governance and Anti-Human Trafficking & Slavery awareness training to our global workforce. We will continue to train relevant new employees and will evaluate on-going training annually.

Fibrenet Global is committed to maintaining high standards of social responsibility and continuing to combat human trafficking and slavery in our supply chain.