Introduction
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 in the United Kingdom and the equivalent legislation in the countries listed below. It sets out the steps that TXO Systems Limited and its associated companies (hereafter referred to as the Group) has taken and is continuing to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.
Our Business
TXO Systems Limited, headquartered in Chepstow (UK) (with sites in Solihull (UK), Livingston (UK), Andover (UK), Saint-Ouen-l’Aumone (France), Solingen (Germany), Eskilstuna (Sweden), Hebron (USA), Pakenham (Australia) and Londrina (Brazil) is a business that brokers and distributes Telecommunication equipment including Switches, Transmission Legacy and Optical equipment as well as providing a reclaiming and salvage service for redundant telecommunication equipment.
Our Supply Chains
Our supply chains include OEMs, customers, component makers, service providers and hardware supply, based in a number of global locations. They provide the Group with the equipment used to create the communications solutions provided by the business. Due to this diversity in supply, we recognise that certain parts of our supply chains may present higher risks of modern slavery, and we are committed to addressing these risks.
Policies
We have implemented the following policies that demonstrate our commitment to preventing modern slavery and human trafficking:
- Anti-Slavery and Human Trafficking Policy: This policy outlines our stance against modern slavery and our expectations for all employees and suppliers.
- Supplier Code of Conduct: All suppliers are required to adhere to our Supplier Code of Conduct, which includes specific prohibitions against the use of forced, bonded, or compulsory labour.
- Whistleblowing Policy: We encourage all employees and suppliers to report any concerns related to modern slavery or human trafficking.
Due Diligence Processes
The Group has established due diligence processes to identify and mitigate risks of modern slavery within our supply chains, including:
- Supplier Risk Assessments: Conducting regular assessments to identify areas of our business and supply chain that are most at risk of modern slavery. This also includes POI checks.
- Supplier Audits: Performing audits and evaluations of key suppliers, with a focus on those in high-risk areas.
- Supplier Engagement: Working closely with suppliers to ensure compliance with our policies and providing support for improvement where necessary.
Training
We provide training to our employees and key stakeholders to ensure they understand the risks of modern slavery and how to address them, including:
- Employee Training: Regular training sessions for employees on identifying and reporting signs of modern slavery.
- Supplier Training: Providing resources and training for suppliers to help them comply with our standards and improve their practices.
Performance Indicators
To measure the effectiveness of our efforts, the Group has established the following key performance indicators (KPIs):
- Number of Supplier Audits Conducted: Tracking the number and results of supplier audits to ensure compliance.
- Training Completion Rates: Monitoring the completion of training programs for employees and suppliers.
- Reported Incidents: Recording and investigating any reports of modern slavery or human trafficking within our supply chain.
Future Plans
The Group is committed to continuous improvement in our efforts to combat modern slavery. Our future plans include:
- Expanding Supplier Auditing: Increasing the scope and frequency of audits for suppliers in high-risk areas.
- Enhanced Training: Developing more comprehensive training for employees and suppliers on modern slavery risks.
- Stakeholder Collaboration: Engaging with industry groups, NGOs, and other stakeholders to share best practices and collaborate on initiatives to eradicate modern slavery.
Approval
This statement has been approved by the Board of Directors of the Group and will be reviewed and updated annually.
Effective date: January 1, 2026