Modern Slavery Statement

This statement applies to all employees, contractors, vendors, and third parties to ensure the protection of information assets across Flag, GCX, and their subsidiaries.

 

1. Introduction 

FLAG and GCX are wholly owned subsidiaries of GCX Topco Limited. GCX provides global managed data telecommunications services, while FLAG offers subsea cable infrastructure capacity. For more information, visit https://www.gcxworld.com and https://www.flagtel.com.

We keep a zero-tolerance stance on modern slavery and human trafficking and are committed to ethical conduct and integrity across all operations and relationships. We enforce robust systems and controls to prevent modern slavery within our business and supply chains.

Modern slavery, a criminal offence under the UK Modern Slavery Act 2015, includes slavery, servitude, forced labour, and human trafficking—each involving exploitation through deprivation of liberty.

This commitment applies to all staff, contractors, vendors, and third parties across our global subsidiaries.

This statement is made subject to section 54(1) of the Modern Slavery Act 2015 and represents our slavery and human trafficking statement for the financial year ending 31 March 2025.

 

2. Our Statement on Slavery and Human Trafficking 

We are committed to preventing modern slavery and human trafficking in all areas of our business and supply chains.

We have zero tolerance for such practices and take proactive steps to ensure that everyone working with us—globally and in any capacity—benefits from an environment where their rights and freedoms are respected.

 

3. Supply Chain and Supplier Due Diligence 

As a global network services provider, we source a wide range of goods and services, with most external spend directed towards network infrastructure, IT, and related services.

We seek to work with suppliers who share our commitment to responsible sourcing and aim to maintain collaborative relationships, addressing issues constructively to meet business requirements.

Our procurement procedures require tailored due diligence for prospective suppliers prior to engagement or financial commitment.

We recognise our ongoing responsibility to assess and mitigate the risk of modern slavery and human trafficking. In 2024/25, we made meaningful progress in understanding these risks, establishing this statement, and initiating control measures.

 

4. Reporting a concern 

Staff with questions or concerns about this statement, or who wish to report issues anonymously, may speak with their manager, Head of Department, any member of management, HR, or use the “Speak Up Line.”

All reports will be treated confidentially and investigated as appropriate. Staff should also refer to the Whistleblowing Policy and Code of Conduct for further guidance.

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5. Updates 

Management may amend this statement at any time without prior notice. Please refer regularly to the intranet or the Flag and GCX websites for the latest version.

This statement does not form part of any employment or service contract and does not override applicable national laws or regulations in jurisdictions where Flag or GCX operate.