Modern Slavery Act Transparency Statement 2020
Cornerstone Telecommunications Infrastructure Limited (“Cornerstone”) was founded in 2012 as a joint venture between Vodafone and Telefonica to build and manage the telecommunications network sites for both companies, including the consolidation of sites to create a single grid. Cornerstone provides and maintains the passive infrastructure on which Vodafone and Telefonica and other customers affix their antennas and associated cellular radio equipment. In accordance with s.54 of the Modern Slavery Act 2015, this statement sets out the steps Cornerstone has taken during the 2019-2020 financial year to try and ensure that slavery and human trafficking is not taking place in any of our supply chain and any part of our business.
Cornerstone recognises the importance of the Modern Slavery Act 2015 in protecting the liberty of all people. The Board of Cornerstone fully supports and promotes compliance with this legislation.
Cornerstone organisational structure and supply chain
Cornerstone employs approximately 240 people throughout the UK. We also 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 the supply chain are predominantly providing highly technical products and/or services where we consider the risk of modern slavery practices, such as forced labour or exploitation, to be low. Nevertheless, we are vigilant regarding this risk.
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. We expect all of our suppliers 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 due diligence on our suppliers/partners, as well as having an Ethical Purchasing Policy which provides guidance to our 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. Also, as part of our 7 stage onboarding process, all new suppliers are subject to detailed pre-qualification reviews and assessments of the supplier’s finances, insurance, capacity, capability and Infosec/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. If we cannot find a resolution with them then we will not engage with that company.
Our interaction and monitoring of our suppliers/partners does not end there. On a monthly basis, we meet with and review our leading 27 suppliers/partners (representing c.80% of our spend) to review Safety, Delivery, Risk and Commercial Contract Management (IACCM) and/or in periodic operational reviews, and site inspections. It is normal for some suppliers/partners to also receive unannounced face to face site visits to check workforce accreditation and welfare facilities, however, from the end of 2019 onwards this has been hampered by the Covid-19 risk. 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 terminate 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 People Director or the Head of Legal and Compliance. 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 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, over the coming year we commit to doing the following:
- Internal Communications - We will continue to issue communications to all Cornerstone colleagues informing them of the continued need to adhere to the Modern Slavery Act 2015. Communication raises awareness of the issue and we hope will encourage further innovation and engagement in relation to our approach to combating modern slavery.
- Training - All our new colleagues will receive awareness training to ensure they understand our position on modern slavery and that they are vigilant to ensure it is prevented from happening in our business.
- Supplier Strategy - We will continue to review our supplier sourcing policies and strategies to do what we can to ensure modern slavery or human trafficking is not taking place or being facilitated by our supply chain or business. We will aim to undertake at least three site inspections in the coming year, notwithstanding any Covid-19 impacts on travel and face to face gatherings.
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 2019 and ending 31 March 2020.