Section 172 statement

Section 172 of the Companies Act 2006 requires Directors to take into consideration the interests of stakeholders in their decision making. The Directors continue to have regard to the interests of the Company’s employees and other stakeholders, including the impact of its activities on the community, the environment and the Company’s reputation, when making decisions.

The success of the Company is dependent on the support of all of our stakeholders. Building positive relationships with stakeholders that share similar values is important to the Company and working together towards shared goals assists us in delivering long-term sustainable success. Details of the Company’s key stakeholders and how we engage with them are set out below.

• Parents. As owners of the Company we rely on the support of Vodafone and Telefónica and their opinions are important to us. We have an open dialogue with them through one-to-one meetings, group meetings, and Board meetings. Discussions with Vodafone and Telefónica cover a wide range of topics including financial performance, strategy, outlook, governance and ethical practices.
• Employees. The Directors recognise that the Company’s employees are fundamental to the success of the business and delivery of our strategic ambitions. The success of the business depends on attracting, retaining and motivating employees. From ensuring that we remain a responsible employer, from pay and benefits to our health, safety and workplace environment, the Directors factor the implications of decisions on employees and the wider workforce, where relevant and feasible. There are many ways we engage with the Company’s employees like townhall meetings, surveys and weekly newsletters.
• Suppliers. We build strong relationships with our suppliers to develop mutually beneficial and lasting partnerships. Engagement with suppliers is primarily through a series of interactions and formal reviews and we also host regular conferences to bring suppliers and customers together to discuss shared goals and build relationships. Key areas of focus include innovation, product development, health and safety and sustainability. We are committed to treating all our suppliers fairly. This includes negotiating fair payment terms, in particular for our smaller suppliers, and working hard to minimise late payments. The Board recognises that relationships with suppliers are important to the Company’s long-term success and is briefed on supplier feedback and issues on a regular basis.
• Communities. We engage with the communities in which we operate to build trust and understand the local issues that are important to them. Key areas of focus include how we can support local causes and issues, create opportunities to recruit and develop local people and help to look after the environment. We partner with local charities and organisations at a site level to raise awareness and funds.
• Government and regulators. We engage with the government and regulators, such as Ofcom, through a range of industry consultations, forums, meetings and conferences to communicate our views to policy makers relevant to our business. We are a registered Code Operator with Ofcom. Key areas of focus are compliance with laws and regulations, and health and safety. The Board is updated on legal and regulatory developments and takes these into account when considering future actions.