Modern Slavery Act Statement

Modern Slavery Act Statement

This statement is made by euNetworks Group Holdings Limited, the ultimate parent company of the euNetworks group of companies and is published in accordance with the Modern Slavery Act 2015 which requires organisations with global turnover exceeding £36 million who conduct business in the UK to publish a Slavery and Human Trafficking Statement on their websites.

Organisation Structure and Supply Chains

euNetworks Group Holdings Limited “the Company” is a Western European provider of bandwidth infrastructure services, headquartered in London with operations located in:

  • Austria

  • Belgium

  • Bulgaria

  • France

  • Germany

  • Ireland

  • Italy

  • Spain

  • Switzerland

  • The Netherlands

  • United Kingdom

euNetworks employs approximately 410 people.

For more information about euNetworks, please visit our website: www.eunetworks.com.

Policies in Relation to Slavery and Human Trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.  These include:

  • Whistleblowing Policy:

    • All employees have the right (and responsibility) to alert the Company if they become aware of another employee who is doing something that is illegal, in breach of regulation or other serious form of misconduct or dishonesty.

  • Business Ethics Policy:

    • Employees actions must be legal and consistent with the Company’s policies and values.

  • Anti-slavery and Human Trafficking Policy

    • Reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

  • Sustainability Policy

    • Reflects our commitment to promoting sustainability and our commitment to the promotion of a broader Environmental, Social and Governance (ESG) agenda. This includes commitment to developing a workforce that reflects the divers communities in the locations in which we operate, helping people achieve their true potential and managing the risk to anyone affected by our operations.

Due Diligence Processes

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted due diligence procedures.

Our due diligence procedures aim to:

  • Identify and action potential risks in our business and supply chains;

  • Monitor potential risks in our business and supply chains;

  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains; and

  • Provide protection for whistleblowers.

Risk Assessment and Management

euNetworks recognises that the risk of modern slavery may exist in all global supply chains. However, based on the nature of our operations and supply chain, we currently assess the overall risk within our business and direct supply chain as low. The majority of our suppliers are located within Europe and operate in industries generally considered lower risk for modern slavery and human trafficking. We continue to monitor our supply chain and review our policies and procedures to ensure appropriate controls remain in place.

Key Performance Indicators to Measure Effectiveness of Steps Being Taken

euNetworks is committed to ensuring that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and supply chain.

To assess the effectiveness of our actions, we monitor:

  • Completion of employee policy acknowledgements and compliance training;

  • Any whistleblowing reports relating to unethical labour practices;

  • Supplier onboarding and due diligence procedures;

  • Ongoing review of supplier relationships and contractual standards.

As a signatory to the United Nations (UN) Global Compact, we respect and support internationally recognised human rights standards and seek to prevent human rights violations within our operations and supply chain.

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This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Our Group’s slavery and human trafficking statement for the financial period ending 31 December 2025. It was approved by the Board on 26 May 2026.