Modern Slavery Act 2015: Slavery and human trafficking statement

Introduction from Hayden Robinson, CFO and Head of Legal

The Commify Group of Companies, which includes the Esendex, Text Marketer and FastSMS brands in the UK, is committed to improving our practices to combat slavery and human trafficking across our supply chain.

The Organisation’s structure

We are a provider of global business communications services in the messaging sector. Our head office is 20 Wollaton Street Nottingham, NG1 5FW. We employ circa 220 people globally and trade through business units in six countries; the UK, France, Italy, Germany, Spain and Australia. With over 35,000 customers we are one of the largest providers in our market.

The Commify Group of Companies to which this statement applies includes Collstream Limited, Commify Limited, Commify UK Limited, Commify Topco Limited, Connection Software Limited, Falcon Equityco 1 Limited, Falcon Equityco 2 Limited, Mediaburst Limited, S.C.L. Consultants Limited, TA and MB Limited, TextAnywhere Limited and TextWorld Limited.

Supply Chain

As a service-based business, operating primarily in Western Europe and in the technology space, our supply chain is neither people intensive, nor does it use raw materials as we primarily purchase SMS services from global telecom providers. Our primary suppliers are the large Mobile Network Operators in each of the six countries where we operate. These include some of Europe’s largest companies such as Vodafone, Telecom Italia and EE.

In light of the above, we have assessed the risk of Slavery and Human Trafficking in our organisation and in our ongoing supply chain to be low.

Our policies and values on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Hiring Policy and overall business values reflect our commitment to acting ethically and with integrity in all our business relationships. We have high ethical standards and strong values which are particularly shown within our Employee Code of Conduct and statement of Values.

Due diligence processes for slavery and human trafficking

In our own business all employees are employed under a written contract that sets out their benefits and obligations; all UK members of staff are paid in excess of the UK national minimum wage and we expect the same to be true in our ongoing supply chain.

We also have in place systems to encourage and protect whistleblowers.

Training

To ensure an understanding of the risks of modern slavery and human trafficking in our business, we will be providing training to staff that are involved in the procurement process.

Compliance

We have not been informed of any incidents of modern slavery or human trafficking during this financial year.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2019.