1. Modern Slavery and Human Trafficking statement

  • 1.1 This statement sets out Blu Wireless actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and supply chain.
  • 1.2 This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.
  • 1.3 2021 is the first time Blu Wireless has published this statement, going forward it will be reviewed annually and published no later than 30 June.
  • 1.4 As part of Telecommunications sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
  • 1.5 Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

2. Organisational structure and supply chains

  • 2.1 This statement covers the activities of Blu Wireless:
  • 2.2 From our HQ in Bristol, we are leading a new era of high-speed connectivity. We utilise mmWave frequencies to generate ultra-fast, resilient, carrier-grade and cost-effective wireless networks. Our unique mmWave solutions are engineered for emerging connectivity needs – from smart city networks to connected vehicles. We work together with integrators manufacturers, and service providers to deliver the superior speeds of connectivity needed for the data-intensive applications of the future.
  • 2.3 We currently operate in the following countries: UK, Europe, and the US.
  • 2.4 Given the nature of the products Blu Wireless provide our workforce is typically highly skilled and in permanent employment or specialised contract employees, we do not employ seasonal staff.
  • 2.5 Blu Wireless relies on a global supply chain to develop and manufacture components of our product portfolio. We work directly with suppliers and partners from China and India and Europe, this includes engineering and manufacturing organisations.
  • 2.6 The management of human rights risk and impact to Blu Wireless business is embedded into management systems and processes. The Senior Management team is responsible for ensuring compliance with local laws and regulations. Functional teams work with the Senior Management team to ensure compliance with this policy.
  • 2.7 If any future investigation identifies confirms or indicates potential victims of modern slavery Blu Wireless will work to the best interests and protection of these individuals or groups.
  • 2.8 As of April 2021, Blu Wireless considers that none of its activities are at high risk of slavery or human trafficking.
  • 2.9 Responsibility for anti-slavery initiatives is defined in Blu Wireless policies, the Blu Wireless policy will be reviewed by the Senior Management team annually and the policy will be approved by the CEO.

3. Relevant policies

  • 3.1 Blu Wireless operates the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
  • 3.2 The Blu Wireless Whistleblowing policy (BW-000640-CP) encourages all employees, customers and business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
  • 3.3 Blu Wireless Employee Code of Conduct policy (BW-000639-CP) makes it clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • 3.4 Blu Wireless Recruitment policy (BW-002349-CP) uses only reputable employment agencies to source staff.

4. Due diligence

  • 4.1 Blu Wireless will undertake due diligence when considering taking on new suppliers and will regularly reviews its existing suppliers. Our due diligence and reviews include:
    • 4.1.1 Mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking.
    • 4.1.2 evaluating the modern slavery and human trafficking risks of each new supplier.
    • 4.1.3 Blu Wireless will review annually the Modern Slavery and Human Trafficking Statements of its major suppliers and maintain where possible a history of supplier published statements.

5. Performance indicators

  • 5.1 Blu Wireless will develop key performance indicators (KPIs). This will include.
    • 5.1.1 Defining a process for supply chain verification expected to be in place by April 2021 whereby we evaluate potential suppliers before they enter the supply chain.

6. Training

  • 6.1 Blu Wireless requires all staff within our organisation to complete awareness training on modern slavery.
  • 6.2 As well as training staff, Blu Wireless will raise awareness of modern slavery issues by circulating a series of emails to staff explaining,
    • 6.2.1 the basic principles of the Modern Slavery Act 2015.
    • 6.2.2 how employers can identify and prevent slavery and human trafficking.
    • 6.2.3 what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation.

7. Approval

7.1 This statement was approved by our Senior Management, who review and update it annually.