Modern Slavery Act Transparency Statement


Cornerstone Telecommunications Infrastructure Limited ("Cornerstone"), was founded in 2012 as a joint venture between Vodafone and Telefónica to manage the telecommunications network sites for both companies, including the consolidation of sites to create a single grid. Cornerstone provides the infrastructure that allows Vodafone and Telefónica to locate their antennas and associated cellular radio equipment and generate efficiencies in cell site deployment and the operation of the network infrastructure. In accordance with s.54 of the Modern Slavery Act 2015, this statement sets out the steps Cornerstone has taken during the 2017-2018 financial year to try and ensure that slavery and human trafficking is not taking place in any of the supply chains and any part of its own business.
In accordance with s.54 of the Modern Slavery Act 2015, this statement sets out the steps Cornerstone has taken during the 2017-2018 financial year to try and ensure that slavery and human trafficking is not taking place in any of its supply chains and any part of its own business.

Cornerstone organisational structure and supply chain

Cornerstone directly employs approximately 260 people throughout the UK, but we engage with a range of other service providers and equipment suppliers/partners to deliver our projects. The supply chain for our core activities consists of established suppliers/partners within the telecoms industry, providing services such as site acquisition, design, construction, and maintenance. We also work closely with providers of the following products and services:

  • Real estate and town and country planning professional services;
  • Legal services;
  • Design and construction services for existing and new assets;
  • Maintenance and repair services for our asset base; and
  • IT software and managed services.

Our suppliers/partners are almost exclusively UK-based, and we do not consider our industry and supply chain to be particularly susceptible to modern slavery and human trafficking. Our partners within our supply chain are predominantly providing low-volume, highly technical products and services where we consider the risk of modern slavery practices such as forced labour or exploitation to be low.


To ensure a strong supply chain, Cornerstone has established baseline standards that must be met by our suppliers/partners. Key to the success of Cornerstone is the development of strong partnerships with strategic suppliers/partners, and that means we look for suppliers/partners who are able to work within established service levels, provide quality deliverables and assist us in meeting and exceeding the expectations of our customers. We work closely with our suppliers/partners to ensure they share Cornerstone's values and understand the importance of conducting business with honesty and integrity, and we expect all of our suppliers/partners and business partners to conduct their business in a lawful and ethical manner. This includes adopting business practices that prevent or eliminate modern slavery and human trafficking from taking place within their supply chains.

Supply chain management and due diligence

We do carry out modern slavery specific due diligence on our suppliers/partners, as well as having a sourcing policy which provides guidance to our procurement teams on how they source products and services on behalf of Cornerstone, and the due diligence they must carry out on prospective partners and suppliers/partners. Also, as part of our supplier selection process, suppliers/partners are required to complete our onboarding documentation, which includes a detailed pre-qualification questionnaire and assessments of the supplier's finances. Insurance, capacity, capability and lnfosec/GDPR.

If, as part of this process, we were to identify a supplier or prospective supplier as being at risk of not achieving our standards (including in relation to compliance with the Modern Slavery Act 2015) then we would work with them to remedy any issues, but if we cannot find a resolution the we would not engage with that company.

Depending on their level of engagement and criticality with Cornerstone, our interaction with suppliers/partners ranges from formal monthly Commercial Contract Management (IACCM) meetings to periodic reviews as required. Some suppliers/partners will also receive unannounced site visits to check workforce accreditation and welfare facilities, for example, and these reviews and site visits would help us to identify whether any modern slavery practices are taking place within that supplier/partner's business. If that were to be the case and the supplier was unable to resolve the problem, this would lead us to ending our relationship with them.


We operate a whistleblowing policy under which employees can report wrongdoing within the workplace. Employees should first report issues to their line manager and then to the HR director. We encourage employees to report any instances of unethical practices, which would include notifying the relevant person if they become aware of any modern slavery practices occurring within our business and/or supply chain.


In our previous statement twelve months ago, we outlined a number of initiatives and actions which have been completed. One of these was our Code of Conduct, which has been launched, is predominately displayed on the company intranet, and a copy which is handed to all new starters as part of their induction. In order to maintain awareness of the risk of modern slavery and human trafficking entering our supply chain or our business, and to assist in managing such risks on an ongoing basis, we plan over the coming year to do the following:

  • Internal Communications - We continue to issue communications to all Cornerstone colleagues informing them of the continued need to adhere to the Modern Slavery Act 2015. This raised awareness of the issue and we hope will have stimulated further innovation in relation to our approach as an organisation to combating modern slavery.
  • Supplier Strategy - Ongoing reviews of our supplier sourcing policies and strategies, to ensure modern slavery or human trafficking doesn't appear in, or is facilitated by, our supply chain or business.

Sign off

This statement is made in accordance with Section 54 ( l) of the Modern Slavery Act 2015 and constitutes Cornerstone's modern slavery and human trafficking statement for the financial year commencing 1 April 2017 and ending 31 March 2018.


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Rhys Phillip



Date:date of signature

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