For Financial Year 2018
GTT Communications, Inc. (GTT) is a publicly traded company listed on the New York Stock Exchange (NYSE: GTT) and headquartered in McLean, Virginia.
At GTT, we strive to maintain the highest standard of ethical principles and to respect human rights, both within our organisation and by encouraging high standards in our supply chain. To this end, all our employees review and sign up to our Code of Business Conduct and Ethics (“Ethics Policy”) on an annual basis. As part of our Ethics Policy, we operate a confidential whistle-blower hotline to encourage disclosure of unlawful or unethical behaviour in a confidential environment free from fear of retaliation. All our employees are made aware of our whistle-blower hotline, which they can call to report any form of human rights violation. We continually monitor the implementation and adequacy of our Ethics Policy, and periodically report on the results of this process to our Audit and Risks Committee, which in turn will make an independent assessment of the adequacy of the policy.
In order to identify and control where our greatest exposure to modern slavery lies, we currently have a number of employee policies in place which in appropriate circumstances we extend to third parties, including suppliers:
- Compliance with Laws, Rules and Regulations. Obeying the law, both in letter and in spirit, is the foundation on which GTT’s ethical standards are built. All employees, officers and directors should respect and obey all international, country and local laws, rules, and regulations applicable to the business and operations of the Company.
- Competition and Fair Dealing. GTT seeks to compete in a fair and honest manner. GTT seeks competitive advantages through superior performance rather than through unethical or illegal business practices. No employee, officer or director should take unfair advantage of anyone relating to GTT’s business or operations through manipulation, concealment, or abuse of privileged information, misrepresentation of material facts, or any unfair dealing practice. To maintain the Company’s valuable reputation, compliance with GTT’s quality control processes and safety requirements is essential. In the context of ethics, quality requires that GTT’s products and services meet reasonable customer expectations.
- Equal Opportunity Employment, Non-Discrimination and Anti-Harassment. GTT is committed to providing a work environment that is free of unlawful discrimination or harassment of any kind. GTT is firmly committed to providing equal opportunity in all aspects of employment. The term “harassment” includes harassment based on any category
- Health and Safety. GTT strives to provide a safe and healthy work environment. Each employee, officer and director has a responsibility to follow safety and health rules and practices and to report accidents, injuries, and unsafe equipment, practices, or conditions. Violence and threatening behaviour are not permitted. GTT is obligated to maintain compliance with applicable national health and safety laws and regulations.
- Anti-Corruption/Anti-Bribery. It is the policy of GTT to comply with all applicable anti-corruption and anti-bribery laws.
- Sanctioned Countries, Restricted Parties and Anti-Boycott. GTT is committed to conducting its business in compliance with laws applicable to transactions regarding sanctioned countries, restricted parties and anti-boycott.
- Anti-Money Laundering. GTT employees, officers and directors are prohibited from engaging in or facilitating transactions anywhere in the world involving funds that were derived from illegal activities. GTT must comply with all applicable anti-money laundering laws, rules and regulations of the U.S. and all other countries where we do business. Therefore, we must carefully scrutinize all payments and transactions with customers, vendors, business partners, agents and affiliates. We will not accept any funds or make any payments that are or appear to be derived from illegal activities.
- Reporting any Illegal or Unethical Behaviour. Employees, officers and directors are encouraged to talk to GTT Human Resources, GTT Legal, or any of GTT’s executive officers about observed illegal or unethical behaviour and when in doubt about the best course of action in a particular situation. The Company maintains an Ethics and Compliance Helpline and website (“Helpline”) which are monitored by the Audit Committee and GTT Human Resources department.
We have a zero-tolerance approach to slavery in any form, and are committed to continuing to build on our practices to combat slavery and human trafficking. Although we believe that due to the nature of what we do, the risk of slavery in our supply chain is relatively low compared with other industries, we are not complacent about this risk and are alert to the fact that we have suppliers in geographical areas carrying out work for us that could be susceptible to the exploitation of people.
For all suppliers, we include contractual obligations in our standard paperwork requiring suppliers to comply with all applicable laws, including laws on modern slavery and human trafficking. If a supplier does not meet our standards we will implement an action plan, which may include termination.
GTT will annually review and ensure that our risk management policies are adequate.