Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

Virgin Media O2

ModernSlaveryStatement
In this statement unless the context otherwise
requires, the term "we," "our" and "Virgin Media O2"
refer to VMED O2 UK Limited and its subsidiaries.
June 2024

Conflict minerals

Approvals

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

Conflict minerals

Approvals

Page 2Introduction
This statement has been published in accordance with Section 54 of
the Modern Slavery Act 2015. It sets out the steps taken by VMED O2 UK
Limited and its subsidiaries (Virgin Media O2) for the financial year ending
31st December 2023 to prevent modern slavery and human trafficking in
its own business operations and supply chains.
This is the third statement produced by Virgin MediaO2, a business formed in June 2021 when the Virgin
Media and O2 (including giffgaff) businesses werebrought together as a joint venture owned by Liberty
Global and Telefonica SA.
2023 summary
We operate solely in the UK, but we are reliant on a
global supply chain. In 2023, our supply chain remained
the primary risk area with respect to forced labour andwe continued to operate policies designed to minimise
this risk, conducted risk-based due diligence and foundno instances of forced labour.

Key focus areas in 2023 included:• ensuring Virgin Media O2 visibility of recent
due diligence addressing suppliers which
provide branded solutions.
• running modern slavery risk management
reviews of suppliers operating in risk sectors.
• developing a new, enhanced Virgin Media O2 			
Supplier Code of Conduct that has replaced
the previous codes we used when purchasing
for Virgin Media and O2 brands, which reflects
sector best practice with respect to the 				management of forced labour risk.
• monitoring the results of sector audits
addressing suppliers we share withother operators.

VMO2 | Modern slavery statement 2024

Introduction 		

About our business

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About our business
Based in the UK, we are acustomer-first organisationthat brings a range of
connectivity services together
in one place with a mission
to upgrade the UK
A joint venture of Liberty Global and Telefónica,
Virgin Media O2 combines the UK’s largest
mobile network and the largest gigabit
broadband network. We are an integrated
communications provider of mobile, broadband
internet, video and fixed-line telephony toresidential customers and organisations in
the UK. Our mobile network is operated under
the O2 brand and our fixed-line network under
the Virgin Media brand.
In 2023, our Virgin Media O2 businesses
collectively supported some 44.9 million
mobile connections and 34% of UK fixedlines. To underpin our product and service
delivery, we purchased from a global supply
chain of around 1,900 direct suppliers, witha total annual spend of approximately £8.1bn.

Products and services
Consumers

Business & wholesale customers• Broadband• Converged fixed and mobile connectivity• TV• Mobility• Home phone• Mobile connectivity• Security• Virgin Media Finance plc

Our sustainability strategy• Virgin Media Mobile Finance Limited

We are committed to using our scaleand reach to create an inclusive,
green and connected future for ourcustomers and the communities inwhich we operate. Through our Better
Connections Plan, we seek to:• Virgin Media Intermediary
Purchaser Limited• Virgin Media Investment
Holdings Limited• Virgin Media Senior
Investments Limited• Virgin Media Secured Finance plc• Cloud• Virgin Media SFA Finance Limited• Devices• Data and Analytics• Virgin Media Operations Limited• Converged bundles• Fibre to the home (FTTH) build for nexfibre• Virgin Media Payments Limited• Virgin Media Wholesale Limited• We have the largest gigabit fixed 			network in the UK, with an expanding 		
infrastructure through the rollout of 		
nexfibre FTTH. Our entire fixed network
offers gigabit speeds, as nexfibre FTTH
grows our footprint to 17 million homes
as of 31 December 2023.
• We are the largest mobile operator in 		
the UK, serving 44.9 million connections.
Our 5G network covers over 50% of 		the UK outdoor population and we 		
service different market segments 		through our own brands and mobile 		virtual network operator(MVNO) partners.

• Virgin Mobile Telecoms Limited• We have a diverse and experienced
UK workforce of 15,700 people 			 • VMED O2 UK Limited
employed by the family of Virgin 			 • VMED O2 UK Holdco 4 Limited
Media O2 businesses addressed• VMED O2 UK Holdco 5 Limitedby this statement, i.e.
• giffgaff Limited• VMED O2 UK Financing I plc• NTL Glasgow• VMED O2 UK Holdings Limited• NTL Kirklees• Telefonica UK Limited• Upp Corporation Limited• equip 6 million people with digital 		
skills and connect one million digitally
excluded people by 2025;• achieve net zero carbon emissions
across our value chain by 2040 andenable 10 million circular actions for
consumers to take by 2025.
Our sustainability strategy and 2023
performance against our strategic
priorities are outlined in our Annual
Report. At the heart of our plan is acommitment to make sure our business
operates in a sustainable and ethicalway – with all our people, partners
and suppliers playing a part. Building
a sustainable supply chain is criticalto upholding an ethical business,so we establish clear sustainability
expectations of our suppliers, integrating
environmental, social and governance(ESG) goals and standards into our
procurement processes.

• Virgin Media Business Limited• Virgin Media Limited
VMO2 | Modern slavery statement 2024

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

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Page 4

Managing modern slavery risks
Training and awareness
The first step to improving how we manage
modern slavery within our operations is making
sure that our employees understand the potential
risks and how to respond to them. To raiseawareness of modern slavery and labour
exploitation, we:• Developed employee training explaining
what forced labour is, why it matters, andhow to recognise the signs and report any 			concerns. Employees also undergo mandatory 		
annual training on our Virgin Media Code of 		Conduct, which outlines our businessprinciples and values. In 2023, this was 			completed by 99% of our workforce.
• Provided guidance on our supplier portal
about the management of modern slavery
risks and how to implement effective controls.

Key policies
We have a range of policies both for employees
and suppliers that minimise the risk of forced
labour within our operations and supply chain.

Internal

Supplier-facing

Our people policies are designed to makesure everyone feels valued and respected.

We've previously operated two policies
aimed at reducing the threat of forced
labour within our supply chains: theTelefónica Supply Chain Sustainability
Policy and the Virgin Media Supplier
Code of Conduct. These legacy
policies have now been consolidated
into a single code of conduct - theVirgin Media O2 Supplier Codeof Conduct, which specificallyprohibits all types of forced labour.

Our Virgin Media O2 Code of Conduct
policy is the overarching frameworkthat sets out the behaviours we
expect of our employees, guided
by our company policies.
We have a dedicated ‘Speak Up’ helpline,
and associated policies, to support
employees who wish to raise concerns
relating to discrimination, bullying andharassment, health and safety, and fraud.
Our policies provide flexibility andtime away from work when needed,
recognising the importance of worklife balance. We recently introduced
a new Flexible Working Policy acrossthe business, together with enhanced
guidance for both employees andmanagers to create flexible teams.

The new code is effective for all Virgin
Media O2 procurement processes.
It requires suppliers to implement
strong risk management measures
to effectively manage forced labourrisks and to put in place best practicemeasures developed within the Joint
Alliance CSR (JAC) sector initiative.

VMO2 | Modern slavery statement 2024

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

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Managing modern slavery risks (cont.)
Internal forced labour risks
We are committed to conducting businesswith integrity and fairness and we upholda zero-tolerance approach towards forced
labour within our operations. We expect
the highest levels of ethical conduct inorder to safeguard the rights and well-beingof all our people. We view that there isno risk of forced labour within Virgin MediaO2 operations.
Creating a welcoming, inclusive cultureis critical to helping our employees feelsafe and empowered at work. Our fourpillars of ‘Belonging, Clarity, Development
and Recognition’ closely align with ourcommitment to Diversity, Equity andInclusion (DE&I). We continue to champion
our DE&I agenda through a wide rangeof activities:• Feedback channels for our people to 		share their views on DE&I. We havea regular employee engagement survey‘Your Say’, a dedicated annual DE&I 		
Survey (Vibe) and six DE&I networks 		which all have Executive Committee andsenior leader sponsors. Over half of ouremployees are members of a networkand they play a crucial role in raising 		awareness of the most important issues
		that affect their members.

• ‘Ally Up’ workshops. In 2023, we 			launched 'Ally Up’, our inclusion initiative
focused on DE&I topics like anti-racism.
Through dedicated workshops, we aim		to educate and empower all employees.
• A zero-tolerance approach to all
forms of discrimination.
We reinforced our zero-tolerance
stance on abuse to protect our 			customer-facing staff. This included 		a pilot in 2023 in our retail stores aimed
at addressing instances of discriminatory
behaviour by customers observed byour store colleagues and providing 		enhanced support for our people 			through training and adequate aftercare.
We also implemented a streamlined 		
reporting process and support system
to safeguard their well-being.
• Gender and ethnicity pay gaps.
We report pay and ethnicity gaps 			annually and have made improvements
in our pay gaps this year.

• Inclusive Leader programme.
Designed to support senior leadership 				teams improve their understanding 		
of inclusion, apply their knowledge,
and measure their impact, the Inclusive
Leader programme will be rolled out toall people leaders throughout the year.
• Inclusive recruitment.
We continue to enhance the way we		recruit by investing in new systems		
with better data insights that drive
action to increase the diversity 			of our talent. In 2023, we implemented
a new recruitment system that 			provides candidates with a more
inclusive and simplified approach 			to applying for roles. We’re also 			reviewing our assessment and 			interview processes to remove 			any barriers and eliminate bias.
We have removed the requirement 		to a provide a CV in almost 50% of
our hiring outcomes, and we use 			independent assessment observers
to support managers when interviewing
to ensure more inclusive decision making.

Managing supply chain
forced labour risks

You can find our Supplier code of conduct
here, along with all our other supplier-facing
policies and details of:

Our UK-based business buys a diverse
range of products and services from a
global supply chain which we view as
our only significant exposure to forced
labour risk. Purchasing is managed by a
dedicated Virgin Media O2 Procurement
team supported by procurement services
from our parent shareholders Liberty
Global and Telefónica SA.

•3how to become a VMO2 supplier;

The Virgin Media O2 Procurement teambuys under the brands of our major
operating business and contractuallycommits all suppliers to a single supplierfacing code of conduct, developed in
2023, that sets our revised and updated
supply chain sustainability standards inclear and uncompromising language.
All forms of forced labour are prohibitedand the practices we expect supplier tooperate to minimise the risk of forced
labour are clearly detailed.

•3how and what we buy;
•3what we consider when selecting
3a supplier;• 3our supplier facing policies
3and terms;• 3a link to our Speak Up channel;• guidance for suppliers on topics
3we view as important like managing		
3modern slavery risks.

VMO2 | Modern slavery statement 2024

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

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Page 6

Approvals

Managing modern slavery risks (cont.)
2023 due diligence approaches and outcomes
Even though our operations are confinedto the UK, catering to both businessand consumer needs, our supply chainsare global as we buy a diverse array of
products and services to support ourbusiness.
We centralise our procurement efforts
through a unified team that buys for all
Virgin Media O2 brands and sources both
directly and via procurement services
operated by Liberty Global and Telefónica
SA. These entities, like Virgin Media O2,
strictly prohibit forced labour and trafficking
within their operations and supply chains.
They enforce this prohibition throughstringent policies reinforced by risk-oriented
due diligence practices.
In 2023, Virgin Media O2 spentapproximately £8.1 billion procuring
goods and services from roughly 1,900
suppliers. While our primary suppliers are
predominantly UK-based, our extended
supplier network is global and includes
facilities in Asia, Europe, the USA, and South
Africa. We focus our efforts on mitigating
forced labour risks in our supply chain, since
this is where the highest risk lies.

Our approach involves leveraging sectorwide initiatives, collaborating with our parent
organisations, and conducting our own
risk-based due diligence. Our strategies for
managing forced labour risks are integrated
into our broader supply chain sustainability
management activity, such as:
1. Embedding stringent requirements 		
within our procurement processes, 		enforced through our new Virgin 			Media Supplier Code of Conduct 		which prohibits all forms of forced 		labour and compels suppliers to
adopt robust risk management
practices to address this issue 			effectively.
2. Assessing the suitability of bidding 		
suppliers to meet our sustainability
criteria in targeted tenders, consideringfactors like the nature of their			
operations and geographical 			presence, with a particular 				emphasis on their approach tomodern slavery risk mitigation. We 		
actively engage with suppliers to 		address any identified shortcomings.

3. Identifying suppliers deemed to 			pose heightened sustainability risks 		
and requiring them to supply EcoVadis
or Integrity Next scorecards, providing
insight into their overall sustainability 		practices.
4. Conducting sustainability reviews in 		
contract with selected suppliers, witha specific focus on modern slavery
risk management.
5. Undertaking audits of selected			
suppliers either directly, through			
industry initiatives, or by mandating		
independent third-party audits, 			
ensuring transparency andaccountability.
6. Targeting suppliers operating insectors with elevated forced labour 		risks and conducting specialised 		
Modern Slavery Risk Assessments. 		
These evaluations scrutinize suppliers'
policies and processes to ensure
they unequivocally prohibit forced		
labour and drive risk- based due 			diligence practices across their own
supply chains.

Our Modern Slavery Risk Assessments review the policies
and processes used by our suppliers to manage modern
slavery risks ensuring they:
Have published a modern slavery statement alignedwith the Modern Slavery Act.
Operate appropriate internal policies and a supplier code of
conduct that addresses modern slavery and its enablers.
Have a policy that prohibits forced labour and trafficking
and requires compliance with the law.
Maintain documented labour contracts and do not
charge worker fees.
Have established working hours controls and associatedreporting that ensure working hours meet legal norms.
Pay salaries aligned to legal norms and do not use fines
as a disciplinary process.
Do not require worker deposits, hold ID documentation
or operate curfews.
Have grievance and whistleblowing
processes.
Can identify their risk areas considering activity
and location.
Plan and implement due diligence in high-risk areas
and drive improvements as needed.

VMO2 | Modern slavery statement 2024

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

Conflict minerals

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Page 7

Managing modern slavery risks (cont.)
Our 2023 activities included:• Raising awareness and visibility 				 of supply chain due diligence efforts 		
		 to assess facilities that provide 					 branded solutions, either by purchasing		 sustainability audits from expert 					 providers or by seeking visibility of 				 independent recent facility audits.
•		 Conducting modern slavery risk 					 management reviews with a sample
		 of UK-based suppliers operating in		 the at risk construction sector.
•		 Monitoring the audit results of the Joint
		 Alliance for CSR (JAC) sector initiative. 		
		 In 2023 there were around 123 audits
		 of common suppliers.
• Running sustainability reviews with 				 selected suppliers that included 					 an examination of their forced labour 				 management policy and process.
• Developing a new Virgin Media O2 		
		 Supplier Code of Conduct that has
		 now replaced the previous codes used		 by Virgin Media O2 operating brands
		 a nd enhancing this new code to reflect		 sector best practice developed with the		 JAC community on forced labour.

• Establishing a supplier-facing web 				 portal where we have published		 guidance for our suppliers on forced 				 labour risk management.

Outcomes & KPIs
• None of our 2023 due diligence activities
		 identified any instances of forced 					 labour in 2023 and no concerns were				 raised via the various whistle blowing 				 channels we have access to.
• 99% of our employees received training
in our code of conduct.

			 companies to oversee the initiative’s 					 strategy and direction. JAC members 		
			 share resources and best practice 					 to develop and implement long-term 		
			 CSR requirements across different tiers			 of the ICT supply chain globally, 			
			 while ensuring that audit findings 						 are shared and corrective actions
			 plans implemented, where necessary,			 to raise standards.
• We share supply chain ESG insight andinformation with our Parent shareholders
Telefonica SA and Liberty Global.

Collaboration• 		 We are an affiliate member of JAC 					 via our Parent shareholders Telefónica 					 SA and Liberty Global. JAC, the			 Joint Alliance for CSR, is a non-						 profit association of telecoms 						 operators aiming to verify, assess 						 and apply Corporate Social 							 Responsibility (CSR) practices across 		
			 the manufacturing sites of its key 					 suppliers. JAC has a Board composed 					 of representatives from our member 		VMO2 | Modern slavery statement 2024

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

Conflict minerals

Approvals

Page 8Whistleblowing channels
We monitor Telefónica and Liberty
Global whistleblowing channels
for any reports that relate to ourcommon suppliers and the Virgin
Media O2 Speak Up confidential
reporting channel, through which
suppliers, their employees, or any
other interested parties can reportany concern they have regarding
Virgin Media O2 operations or supply
chains. In 2023, we received no
indications of concerns relating toforced labour or trafficking via anyof these channels.
We encourage anyone with concerns relating
to Virgin Media O2 and forced labour issues to
use the Virgin Media O2 Speak Up to reportany concern (anonymously if you wish).
For more information, contact us athttps://speakupvirginmediao2.co.uk
We will handle any concerns raised in confidence
and investigate all credible reports of potential
compliance violations made in good faith. We prohibit
any discrimination or retaliation against individuals
who report suspected violations. All communications
received are treated in accordance with theprinciples of respect and confidentiality.
VMO2 | Modern slavery statement 2024

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

Conflict minerals

Approvals

Page 9Conflict Minerals
Resources known as 'conflictminerals’, such as tin, tantalum,
tungsten and gold are minerals
sourced from conflict-prone
regions like the Democratic
Republic of Congo (DRC) andits neighbouring areas. They are
identified as ‘conflict minerals’ iftheir extraction may have directly
or indirectly benefited or funded
armed groups, thereby contributing
to human rights violations.

These minerals continue to pose a heightened riskof forced labour. While Virgin Media O2 does notdirectly engage with smelters or refiners, they
are integrated into our extended supply chain.
Consequently, we stipulate in our Supplier Codeof Conduct that our suppliers must:• 		 operate policies and processes to assess
			 and minimise the risk of conflict minerals in			 their supply chains;• 		 align with the Organisation of Economic
			 Co-operation and Development (OECD)
			 Due Diligence Guidance for Responsible
			 Supply Chains of Minerals from conflict-affected			 and high-risk areas;• 		 if requested, complete and share the Conflict 						 Minerals Reporting Template.
During sustainability reviews with suppliers, particularattention will be paid to their strategies for managing
the risks associated with conflict minerals.

VMO2 | Modern slavery statement 2024

Introduction 		

About our business

Managing modern slavery risks

Whistleblowing channels

Conflict minerals

Approvals

Page 10

Approvals
The boards of directors forthe following companies haveapproved this statement:• giffgaff Limited• NTL Glasgow• NTL Kirklees• Telefonica UK Limited• Upp Corporation Limited• Virgin Media Business Limited• Virgin Media Limited• Virgin Media Finance plc• Virgin Media Mobile Finance Limited• Virgin Media Intermediary Purchaser Limited• Virgin Media Investment Holdings Limited• Virgin Media Senior Investments Limited• Virgin Media Secured Finance plc• Virgin Media SFA Finance Limited• Virgin Media Operations Limited• Virgin Media Payments Limited

They have all delegated authority to Lutz Schuler
to sign this statement on their behalf.

• Virgin Media Wholesale Limited• Virgin Mobile Telecoms Limited• VMED O2 UK Limited• VMED O2 UK Holdco 4 Limited

Lutz Schüler
Chief Executive Officer Virgin Media O2June 2024• VMED O2 UK Holdco 5 Limited• VMED O2 UK Financing I plc• VMED O2 UK Holdings Limited
VMO2 | Modern slavery statement 2024