MODERN SLAVERY POLICY

INTRODUCTION

Here are the steps Intercity has taken and continues to take to understand and minimise the potential risk of modern slavery in its business and supply chains. This statement is published in line with section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31st December 2025.

Intercity is committed to acting ethically and with integrity in all its business relationships and to implementing effective systems and controls to prevent modern slavery and human trafficking.

This statement has been approved by the Board of Directors of Intercity Technology Group Holdings Ltd and is reviewed annually. 

ABOUT INTERCITY

Intercity provides IT solutions in communications, cloud, security and managed IT services. In this statement “Intercity” applies to our entire Group of companies, this includes Intercity Technology Group Holdings Ltd (ultimate parent company), Intercity Technology Holdings Ltd (parent company) and Intercity Technology Ltd, which has the subsidiaries Intercity Networks Ltd, Intercity Managed Services Ltd, and Chandler Communications Ltd and Centrality Ltd.
Intercity primarily operates in the UK and employs the majority of its workforce directly.

OUR COMMITMENT TO THE PRINCIPLES OF THE MODERN SLAVERY ACT 2015

Intercity is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. We operate a zero-tolerance approach to slavery and human trafficking in all its forms. We are a signatory of the United Nations Global Compact.

As an equal opportunities’ employer, we're committed to creating and ensuring a non-discriminatory and respectful working environment for our team. We want all our team to feel confident that they can expose wrongdoing safely and confidentially, without any risk to themselves.

OUR POLICIES IN RELATION TO THE MODERN SLAVERY ACT 2015

Intercitys comprehensive policy framework helps us manage our approach to modern slavery risks. As part of Intercitys ongoing commitment to combating modern slavery, in 2025 we have conducted an internal refresh of our polices including but not limited to:

• Anti-Slavery and Human Trafficking Policy
• Code of Conduct and Business Ethics Policy
• Whistleblowing Policy
• Anti-Bribery and Corruption Policy
• Supplier Management Policy
• Sustainable and Responsible Procurement Policy
• Employment and recruitment policies which comply with all UK law

Our whistleblowing policy includes a mechanism for reporting genuine suspicion of any criminal conduct or breach of a legal or professional obligation by anyone in the firm or the group, or by a client or contractor, which includes instances of modern slavery.
All relevant policies are reviewed on a regular basis and apply, where appropriate, to employees, contractors and suppliers.

Access to Intercity policies are available to all colleagues via our Company SharePoint pages or our People Portal.

OUR SUPPLIER DUE DILIGENCE PROCESSES

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, all supplier reviews incorporate a review of the controls undertaken by the supplier to ensure compliance to the Modern Slavery Act 2015.  Additionally, any proposed new supplier is required, on a risk-assessed basis, to demonstrate their compliance before they can be considered for addition to the preferred supplier list (PSL).

We are implementing a Supplier Code of Conduct to ensure suppliers are aware of our expectations around conduct and behaviours to encourage a collaborative and compliant based working relationship and reviewing and further developing our existing clauses around modern slavery to ensure suppliers are contractually committed to operational compliance.

RISK AND COMPLIANCE

We have taken steps to evaluate the nature and extent of our exposure to the risk of modern slavery occurring in our supply chain and, based on this assessment, consider the risk to be relatively low due to the nature of our business, sector and geographic footprint. However, we recognise that modern slavery risks can exist in all sectors and remain vigilant to these risks.

Intercity does not tolerate slavery and human trafficking within its supply chains and would immediately seek to investigate and take appropriate action, including termination of the relationship, where evidence of a failure to comply with Intercity’s policies was discovered.

MEASURING EFFECTIVENESS

We have taken the following steps:

• established and assessed areas of potential risk in Intercity’s business and supply chains.
• monitored potential risk areas in Intercity’s business and supply chains.
• reduced the risk of slavery and human trafficking occurring in Intercity business and supply chains.
• provided adequate protection for whistleblowers.

We continue to develop appropriate metrics to measure the effectiveness of our modern slavery controls and processes.

TRAINING FOR COLLEAGUES

To support the principles of the Modern Slavery Act 2015, we will continue to provide awareness training to the Intercity Team on the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking.

All colleagues at Intercity are provided with modern slavery training every two years, which is mandatory and monitored for completion, and members of our Procurement Team are also provided with specific training on an annual basis on their role in preventing modern slavery in our supply chain. This training ensures that all team members involved in procurement activity are aware of and follow modern slavery procurement guidance provided by the UK Government.

Modern slavery awareness is also incorporated into onboarding processes for relevant roles.

Andrew Jackson
Group Chief Executive Officer, Intercity Technology Ltd