BT LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation Other

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Workers within your supply chain Businesses in your industry or sector

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Demonstrated progress

Conducted 50 on-site supplier assessments to identify modern slavery risks. No concerns indicating potential forced labour identified via assessments or Speak Up. Achieved 98% completion of mandatory modern slavery training. Continued to support, fund and promote the UK Modern Slavery Helpline. Deployed a Worker Voice solution to five additional supply chain sites (~1,200 workers). Invested in the Child Rights Action Hub DRC to help address risk of child labour in our raw material supply chain.

Reported risks and mitigations

• Risk: Cobalt is used in lithium‑ion batteries found in some equipment we sell or use. That means there’s a heightened risk of child labour in our raw material supply chain in DRC.
• Area: Within your supply chains
• Tier: Tier 3 suppliers and below
• Group: Children
• Location: Congo (Democratic Republic)
• Mitigation: Through a partnership with Save the Children we invested in the Child Rights Action Hub DRC to help address this risk. This locally embedded, multi‑stakeholder initiative is developed and implemented by The Centre for Child Rights and Business. It helps identify children in high‑risk contexts and delivers child‑centred solutions like education, healthcare, psychosocial support, access to decent work and apprenticeship opportunities for eligible youth and family livelihood planning.
• Risk: Supplier sites in China, Thailand and the Philippines that use recruitment agencies, specifically recruitment fee controls and health and safety practices.
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Children
• Location: China Philippines Thailand
• Mitigation: Working with Labor Solutions, we expanded our Worker Voice programme to five extra supplier sites in China, Thailand and the Philippines – reaching more than 1,200 people. Building on last year’s insights, we prioritised recruitment agencies. Overall feedback was positive, and the project highlighted opportunities to strengthen recruitment fee controls and health and safety practices. We’ve agreed corrective action plans with all the sites.
• Risk: Construction and engineering are sectors with high modern slavery risk. As Openreach continues rolling out the fibre network in the UK.
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Migrants
• Location: United Kingdom
• Mitigation: Reviewed Openreach’s controls for overseeing its build partners over the lifetime of their relationships. Although there were strong policies, contracts and workforce visibility in place, the review highlighted that risks can remain hidden within complex subcontracting and onboarding arrangements. We learned we needed clearer ownership, stronger in‑life assurance and more targeted training and worker awareness. Next year we’ll take forward the recommendations to strengthen our approach.