Modern Slavery Statement
February 2025
This modern slavery statement (“Statement”) is made by Substantial Topco Limited (the “Company”, “we”, “our”) for itself and on behalf of its subsidiaries, including but not limited to: Netomnia Limited, YouFibre Limited, Brsk Limited, and Brsk ISP Limited (together the “Group”), pursuant to Section 54(1) of the Modern Slavery Act 2015 and relates to its most recent financial year, ending 31st December 2024.
We are committed to improving our practices to combat modern slavery and human trafficking throughout the Group. This Statement highlights the key activities we have undertaken during this financial year to combat all forms of modern slavery in our Company and Group supply chain.
About the Company
We are the ultimate parent company of the Group which is made up of internet services providers and network operators in the United Kingdom. We are committed to acting ethically and with integrity.
Our Policies
Given the nature of the business, the Group has many supply chains from which it is supplied primarily with raw materials and products for construction services. We have policies in place that underpin our commitment to ensure modern slavery and human trafficking does not occur within our supply chains or in any part of the Group. We regularly review and update our policies and we expect our supply chains to adopt the same approach.
Risk Assessment
We understand that the following areas give rise to the highest modern slavery risks within the Group:
- Raw materials – some of our raw materials such as fibre cable, closures and routers are sourced from countries such as India and Vietnam.
- Country – we have some employees and contractors working from South Africa, which is deemed more vulnerable to slavery and human trafficking.
- Construction and installation – building and maintaining our infrastructure can involve labour intensive work performed by our contractors.
As part of our initiative to identify and mitigate risk we have in place:
- policies, including our code of conduct, which promote positive and ethical working practices for our employees, including but not limited to pay and benefits, working conditions, diversity and whistleblowing;
- robust anti-slavery terms in our higher-risk contracts;
- due diligence questionnaire that is to be completed by potential suppliers, as necessary on a risk-based approach; and
- regular audits of our existing suppliers and contractors, in particular those in high-risk areas. For example, we may undertake on-site audits of particular suppliers to assess whether any potential actions need to be taken if issues are identified.
Our Effectiveness
Following a review of the effectiveness of the steps we have taken this year to ensure that modern slavery or human trafficking does not occur within our supply chains, we intend to introduce new training materials to all members of staff and consider requiring its higher risk suppliers to ensure that its personnel have received the necessary training.
This Statement was approved by the Board of Directors of Substantial Topco Limited at a Board meeting on 13th February 2025.
Jeremy Chelot
Group CEO
Substantial Topco Limited
