UK Modern Slavery Act Statement

Introduction

Masergy Communications is committed to the fight against modern slavery and human trafficking. This statement describes some of the key measures we take to combat these and other illegal and immoral practices.

Masergy Communications UK Limited (“Masergy”) is the UK subsidiary of Masergy Communications, Inc. Masergy is a managed IT services provider, delivering a software-defined network and cloud platform that includes Managed SD-WAN, UCaaS, CCaaS and Managed Security solutions. The head office of the group is in Plano, Texas and we have operations around the world.

Our Policies

Masergy is required to comply with all Masergy Group policies designed to promote ethical business behaviour. Enshrined in our UK Employee Handbook is our policy on Business Ethics and Employee Integrity, which emphasises the high standards our employees must adhere to, not just in financial matters, but in every aspect of our business relationships. The policy outlines, among other things, our commitment to complying with local, state, or federal laws and regulations, (which would include laws aimed at combatting modern slavery and human trafficking), with violations resulting in employees facing disciplinary action up to and including summary termination of employment. Our Handbook also has clear directions to our employees that they must co-operate with governmental agencies and regulatory bodies and to ensure compliance, employees are required to inform the Group’s General Counsel of any governmental request or enquiry.

We actively encourage our employees to report wrongdoing whenever they encounter it. In the Handbook, we have a detailed whistle-blower policy, which explains how we protect whistle-blowers in the company and provides guidance on making whistle-blower complaints. Our policy makes clear that retaliation against employees and workers who report genuine concerns, is not tolerated.

These policies are backed up by further policies in the Handbook, designed to encourage a respectful and harassment-free work environment, as well as policies on combatting bribery and corruption and other unlawful practices. In addition, there is a separate section of our Handbook that addresses the prohibition of illegal activities in connection with the use of the Masergy Group services including mandatory reporting by employees of any trafficking of child pornography to the General Counsel and the System-Administrator of the Network Operations Center or Sr. Manager-Data NOC.

We also try to prevent modern slavery and human trafficking through careful background and immigration checks conducted as a condition of employment. Passports, work permits and visas are examined and were we to have suspicions that a person might have been trafficked, we would report the matter to the police.

As part of our efforts to combat modern slavery, we always try to work with reputable suppliers, with whom we have had a successful relationship for prolonged periods, or who are recommended by third parties we trust. Although we have not yet had this experience, were we to become aware of any information that suggested a supplier might be implicated in modern slavery, we would investigate and, depending on the circumstances, and what we had discovered, work with the supplier to develop a correction plan and/or require evidence that remedial action had been taken and if we were not satisfied, we would terminate the supplier’s contract.

This statement is made in accordance with section 54 of the Modern Slavery Act 2015 and constitutes Masergy’s slavery and human trafficking statement for the financial year ending June 30, 2020, approved by its board on June 4, 2020.