Modern Slavery Act Statement 2019 for Intelsat Global Sales & Marketing Ltd., a U.K. subsidiary of Intelsat S.A. (“Intelsat” or the “Company”), operator of the world’s first Globalized Network and leader in integrated satellite communications, is incorporated and headquartered in Luxembourg. Intelsat has operations internationally, including in the United Kingdom.
This statement has been made and adopted by Intelsat Global Sales & Marketing Ltd. (“IGSM”) pursuant to Section 54 of the Modern Slavery Act of 2015 (the “Act”). IGSM is an Intelsat subsidiary with operations in the U.K. that meet the criteria set forth in the Act. This statement has been approved by the IGSM Board of Directors on 26th February 2020 and also applies to subsidiaries of IGSM which meet the criteria set forth in the Act. This statement covers IGSM’s business activities for the fiscal year ending 31st December 2019.
Code of Business Conduct and Ethics: Intelsat is committed to conducting global business with high ethical and legal standards. That commitment begins with Intelsat’s Code of Business Conduct and Ethics (“Code of Conduct”), available at http://investors.intelsat.com/phoenix.zhtml?c=131114&p=irol-govhighlights. The Code of Conduct applies to all employees of Intelsat and its subsidiaries, including IGSM. The Code of Conduct stresses the importance of abiding by the law, being truthful, being transparent in our business dealings, putting the needs of our shareholders and customers first, and avoiding excesses and ethical lapses.
Setting High Standards with Supplier Chain: Intelsat’s supply chain is made up of approximately 1,400 vendors in around 100 countries predominantly supplying goods and services typically associated with the satellite communications sector as well as a wide range of other services supporting Intelsat’s global business. Intelsat takes a risk-based approach to the assessment and on-going management of its suppliers. Intelsat expects a high degree of corporate and social responsibility from its suppliers and also expects its suppliers to comply with all applicable laws, in particular those regarding anti-corruption, diversity, equality, employment and the environment.
Training: The Company understands that a key component of an effective compliance environment is employee training and education regarding the rules and policies that apply to their business activities, as well as the Company’s commitment to ethical business conduct. Employees receive training on the Code of Conduct when they join the Company, as well as regular ethics and compliance training on laws that apply to our business activities to reinforce the Company’s commitment to compliance with laws and ethical behaviour.
Reporting and Monitoring Misconduct: Employees are encouraged to report any misconduct or unethical behaviour. The Company and its businesses provide multiple means of reporting concerns, including a hotline monitored 24-7, which enable anonymous reporting. Third parties can also report concerns, including through the hotline. These various means of reporting are listed in the Code of Conduct and publicized to employees. Intelsat encourage anyone to report in good faith issues about potential ethical, legal, regulatory, or human rights violations. The Company will investigate allegations and take appropriate remedial actions.