This is XTEL’s Modern Slavery Act statement, following the UK Modern Slavery Act 2015. It covers the financial year 2023 and describes our commitment and steps taken to prevent modern slavery in our business and supply chain.

About us

XTEL is a world leader in revenue management solutions and its companies operate in many markets and countries throughout the globe. In all instances, we respect national laws and any other laws with an international reach. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity. In line with UK and international law, XTEL respects human rights and does not tolerate any form of modern slavery or human trafficking in any part of our business.

Organisational structure

XTEL is a global company. Our people are skilled professionals and are not from vulnerable groups where slavery is a risk. We take our responsibilities for recruiting staff seriously and are aware of the potential for being targeted by traffickers. We recruit through preferred suppliers with clear guidance to ensure our employees and hiring managers are alert to the signs of exploitation so that we can take the necessary action promptly and effectively should it be identified.

Our supply chain

We work with many companies across our supply chain and aim to select partners that meet high standards on ethical business conduct, employment practices, human rights, and the environment. In order to achieve this goal, most of the procurement is conducted through contracts that are negotiated by our legal team in conjunction with budget holders within our companies. Our expectations of suppliers are set out in our Supplier Code of Conduct, which is based on XTEL’s Code of Conduct and applies to all companies and people.

Our policies

We do not tolerate any form of modern slavery or human trafficking in any part of our business. We outline this commitment and set clear ethical standards for our people and companies through our policy framework. Our commitment is also reflected in our Code of Conduct, and our Diversity, Equality, and Inclusion Policy. All key policies, codes and information about our approach are available to our employees, existing and potential suppliers. We continue to develop our policy framework and to communicate it to our companies via the intranet, eLearning, and emails. Our Legal team, in conjunction with our Human Resource team, oversees our policy framework as part of our approach to ethics and compliance with the assistance of subject matter experts when the need arises. We ask senior managers in all our companies to confirm they will comply with the principles within our Code of Conduct . The XTEL Legal team investigates all alleged breaches of our Code and takes appropriate action in confirmed cases.

Due diligence in our business and our supply chain

Our Supplier Code of Conduct sets out our expectations of suppliers and is based on the XTEL Code of Conduct that applies to all our companies and people. The supplier version includes requirements for labour practices (such as anti-harassment and antidiscrimination, and health and safety), human rights (including no child, forced or bonded labour or modern slavery), and social impacts (such as anti-bribery and corruption) as well as other issues. Additionally, our supplier partners undergo pre-screening and other due diligence checks prior to appointment. We also include a “right to audit” clause in our standard terms and conditions.

We require our companies to use centrally negotiated contracts with preferred suppliers for commonly purchased goods and services, whenever possible. This enables us to have high standards and consistency across our approach and processes.

The development of these processes and practices is a journey and the continued discussions both internal and external with our supply base, will ensure that we are applying thought, leadership, best practice, and innovation to support sustainability as a XTEL priority. We will continue to strengthen our due diligence on sustainability issues, including modern slavery throughout the year.

Training

We regularly seek to improve and update training and we have a plan in place to increase training levels for our employees and partners through the implementation of a new training platform and training programs covering a variety of related topics such as diversity and general compliance.

Monitoring

Our Human Resources and Legal teams are dedicated to ensuring compliance with law, policy, and process across the business, including all those aiming to prevent modern slavery. Our people and suppliers can report concerns or suspected cases of misconduct in confidence through our Speak to Us function, which is overseen by our Human Resources and Legal departments. We regularly review and refine our policies and procedures for ensuring ethics, compliance, and respect for human rights. We will continue to expand and extend the work we do in our sustainability programme within our divisions as part of our efforts to ensure there is no forced labour or human trafficking within our global operations or supply chains. We will work closely with our clients, suppliers, and industry partnerships to raise awareness about human rights and modern slavery.