ARROW COMMUNICATIONS HOLDINGS LIMITED

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

This statement has been published in accordance with the Modern Slavery Act 2015 and the 2025 Home
Office guidelines and sets out the actions of the Arrow Group and its group of subsidiaries trading under
the brand ARO (Arrow) to understand all potential modern slavery risks related to our business, the steps
taken to prevent slavery and human trafficking and measures identified to further improve these
safeguarding measures in future periods. This statement relates to the period of 1 January 2026 to 31
October 2026.
Arrow has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and
human trafficking in our operation and supply chains. It has taken concrete steps to tackle modern slavery,
as outlined in this statement and we recognise our responsibility to take a robust approach in respect of
modern slavery and human trafficking.

Our business and supply chain

Arrow Business Communications Limited and its subsidiaries, trading under the brand ARO provide a full
telecom, IT, energy consultancy and service proposition. We operate from twelve offices across England
and Scotland and have a nationwide team. We establish a relationship of trust and integrity with all our
suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding
procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health,
safety, and environmental standards. We provide a detailed due diligence questionnaire and assess each
of our suppliers and their supply chains and review their external policies on human rights and labour.
To date, we have not been made aware of any allegations of human trafficking/slavery activities against any
of our suppliers, but if we were, then we would act immediately for effective sustainable solutions that will
endeavour to improve working conditions and adequate remedies for impacted workers. If we are unable
to resolve issues with such supplier, then a responsible exit plan shall be developed to minimise adverse
effects on workers, ensuring that employment opportunities are not abruptly removed.

Responsibility

The approach adopted, and continuing to be developed, focuses on the following objectives:

• Providing on-going awareness training to staff on the Modern Slavery Act 2015 and informing them
  of the appropriate action to take if they suspect a case of slavery or human trafficking.
• Ensuring that all new employees are on-boarded with training and made aware of the risks for the
  business and its supply chain
• Ensuring that consideration of the modern slavery risks and prevention are added to key policy
  review processes as an employer and procurer of goods and service.
• Ensuring that our procurement team have on-going visibility of supplier processes and make
  informed decisions on compliance.
• Continuing to take action to embed a zero-tolerance policy towards modern slavery.
• Ensuring that staff involved in buying/procurement and the recruitment and deployment of
  workers receive training on modern slavery and ethical employment practices.
• Policy review and update and internal awareness of such policies.
• Risk assessments, led by Legal and Procurement Teams on suppliers and supply chains.

Policies

Arrow operates the following policies for identifying and preventing slavery and human trafficking in our
operations:

• Whistleblowing Policy – there is a written and communicated policy under which all employees,
  customers, and suppliers to report any suspicion of slavery or human trafficking without fear of
  retaliation.
• Code of Conduct – our code encourages employees to do the right thing by clearly stating the
  actions and behaviour expected of them when representing the business. We strive to maintain
  the highest standards of employee conduct and ethical behaviour when operating and managing
  our supply chain.
• Supplier Code – we have updated our Supplier Code and supplier contracts to make explicit
  reference to slavery and human trafficking legislation and compliance.
• Employee Handbook encourages employees to do the right thing by clearly stating the actions and
  behaviour expected of them when representing the business.
• Procurement and Supplier Onboarding polices – such policies ensure that Suppliers are risk-tiered.
  Tier 1 suppliers complete a declaration that covers modern slavery, and Tier 2 suppliers go through
  a full compliance evaluation. Modern slavery compliance, recruitment practices and right-to-work
  checks are carried out and assurances collected from suppliers that modern slavery isn't present
  in their business, including recruitment and equality and diversity policies.

Supplier due diligence

Arrow presently conducts due diligence investigations on all new suppliers during on-boarding and on
existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of particular services
• Reviewing the suppliers, and their health and safety standards, labour relations and employee
  contracts
• Requiring improvements to substandard employment practices
• Working and sanctioning suppliers that fail to improve their performance in line with our
  requirements
• Due diligence questionnaires that formalise the procedure to require all suppliers to attest that:
• They do not use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable
  notice period for terminating their employment
• They do not require employees to post a deposit/bond and don’t withhold their salaries
  for any reasons
• They do notrequire employees to surrender their passports or work permits as a condition
  of employment
• They ensure that all employees have the right to work in the UK and are being
  recompensed in line or above with the living wage
• Assessment of their risk mapping and worker rights policies
  Current statements and questions on Arrow’s form to be answered with the detail request and copies of
  requested policies and statements are:
• Assurance is required that Modern Slavery is not present in your company. Please provide brief
  details of the steps taken to achieve this;
• Assurance is required that Modern Slavery is not present in your supply chain. Please provide
  brief details of steps taken to achieve this;
• Do you have a Modern Slavery policy? Yes or No. If yes, please provide a copy of your Modern
  Slavery policy.
• Do you have a Modern Slavery statement? Yes or No. If yes, please provide a copy of your
  Modern Slavery statement or the link to your statement. (This applies to businesses with an
  annual turnover of £36 million or more where providing goods or services within the UK).

Risk assessment

We continue to conduct a risk assessment of our supply chain by considering:

• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labour and human rights groups
• On- going training workshops that highlight areas of vulnerability and modern slavery
  This ongoing assessment determines our response and the risk controls that we implement.

Awareness

Arrow will raise awareness of modern slavery issues by putting up posters across our facilities and sending
an email that is focused specifically on modern slavery to all our staff explaining:

• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery

Training

In addition to the awareness programme, Arrow continues to roll out fresh e-learning courses to all
employees and supplier contacts covering:

• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low
  prices
• How employees should respond if they suspect slavery or human trafficking
• How suppliers can escalate potential slavery or human trafficking issues to the relevant people
  within their own organisation
• What external help is available for the victims of slavery
• What terms and guidance should be provided to suppliers in relation to slavery policies and
  controls
• What steps Arrow will take if a supplier fails to implement anti-slavery policies or controls, to
  involve communication with the supplier to understand whether or not they intend to implement
  such policies in the future, and if not, re-evaluate whether their position as a supplier to Arrow
• An attestation from employees that they will abide by Arrow’s anti-slavery policy

Measuring performance

Arrow has defined a set of key performance indicators and controls to combat modern slavery and human
trafficking in our organisation and supply chain. In line with this we can confirm that :

• 100 % of employees have completed mandatory training
• 100% of employees are updated on supply chain and the code of conduct
  
  This statement covers 1 January 2026 to 31 October 2026 and has been approved by the Board of Directors.

Ciaran Rafferty

CEO