Speed Fibre Group Insights Report 2022 by hedermangms

ESG Insights Report 2022

Contents

Foreword

SFG & ESG

Materiality

ENIVIRONMENTAL

Reducing our Energy Consumption

Improving Waste Management

Addressing Travel

Biodiversity and Habitat

Our Approach to Climate Related Risk and Opportunity 16

SPEED FIBRE GROUP

The Move to Paperless Billing

Sustainable Practises within Wireless Operations

SOCIAL

Connecting Communities

Working with our Customers

Customer Satisfaction

Health and Wellbeing

Equality, Diversity and Inclusion (“EDI”)

Health and Safety (“H&S”)

Charity and Philanthropy

GOVERNANCE

Doing business responsibly

Board oversight in SFG

Risk Management

Decision Making and ESG

Commitment to Transparent Reporting

Stakeholder Engagement

Speaking up

Anti-Bribery and Corruption

Data Protection

Cyber Security

SPEED FIBRE GROUP

Foreword 2022 was a milestone year for ESG in Speed Fibre Group (“SFG”). Our key focus was driving continuous improvement across all areas falling under ESG in an effort to improve our performance against our peers in the GRESB assessment, GRESB being a European infrastructure benchmark tool for ESG performance. I’m very pleased to announce that our collective efforts paid off and we were awarded a 5-star rating and a score of 96/100 and placed second in our sector in Europe. We have witnessed firsthand the benefits of engaging in transparent evidenced based reporting as it drives better standards, improves processes and greater engagement in ESG across the business. Engaging in GRESB is not legislated for our business, it was a voluntary decision. This demonstrates how committed we are to ESG and it forces us to improve year on year as the GRESB assessment is everchanging, and each year we are met with a new suite of requirements. It has provided a solid overall basis for our ESG framework and strategy going into the future. The telecom sector plays a critical role in connecting people and businesses worldwide, driving economic growth, and enabling the digital transformation. In recognising this, we will continue evolving and improving our practices to create increasingly sustainable solutions within our industry and for the wider community to

SFG & ESG ensure social, economic and environmental longevity. To that end, we have focused on increasing stakeholder engagement on ESG matters as we consider that engagement critically important to enable a circular economy. We firmly are of the view that companies must engage in collective action with each of their stakeholders on all sustainable matters so that we can achieve the right outcomes and make a positive impact. Looking forward to 2023, we will continue to evaluate performance against our peers through the GRESB assessment with a focus on business transition risks (the risk of transition to a low carbon economy), physical risks (physical risks associated with climate change e.g. adverse weather), employee satisfaction monitoring and the procurement of green buildings certifications. We will additionally be establishing some new and exciting projects such as the formalisation of our UN Sustainable Development Goals alignment and further exploring our net zero pathway in line with Ireland’s 2030 and 2050 net carbon goals. I would like to heartfully thank all my colleagues for their contributions to this report and for their enthusiasm and energy.

_______________________________ Claire M. Murphy

General Counsel, Company Secretary and Director of Shared Services

SPEED FIBRE GROUP

Who are we:

ESG in our business:

Our business, Speed Fibre Group (“SFG”), consists of two network provision sector leaders: Enet and Magnet + (comprising of Magnet Networks and Airspeed Telecoms).

SFG has identified its most important ESG concerns and frequently engages with its stakeholders to ensure we live up to their expectations. SFG is aware that its obligations to the environment go beyond its legal and regulatory obligations. While environmental effects are unquestionably very significant, we firmly believe that our ability to positively impact society within the telecoms industry should be a primary focus of our commitment to sustainability. To this end, we use the services we offer to support a more inclusive, informed, and empowered society and business community that has the resources to successfully implement their own sustainability journeys – acting as a facilitator of circular economy.

Enet is Ireland’s largest, open access network provider. We are building and operating the largest alternative wholesale telecoms network in Ireland, which is facilitating the delivery of affordable, world-class broadband and wireless services to homes and businesses across Ireland. Magnet Plus operates Ireland’s largest connectivity network and is the only provider to grant one-stop access to all business options offered by every major network operator in Ireland.

We are keenly aware nowadays that the terms ESG and sustainability are used interchangeably, however, one must be cognisant of the underlying concepts of each term as these inherent differences are crucial for steering organisations towards a more resilient future. While sustainability and ESG are closely related concepts, they have distinct focuses and governance implications. Sustainability takes a broader, holistic view, encompassing environmental, social, and economic dimensions, while ESG provides a structured framework for evaluating specific performance criteria. A sustainable business is one that operates in a way that balances economic, environmental, and social considerations to ensure long-term viability and positive impacts. Sustainability and ESG are standing items for our board as they play a crucial role in ensuring these topics are hardwired into the business’ strategy.

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Environmental Environmental Issues such as climate change & pollution

Social Social consists around workplace practices & human capital

SOCIAL

ACT

• Continual Improvement • Updates to policies and procedures • Assess nonconformities • Take corrective action

GOVERNANCE

Managing our Impacts and Risks

ENVIRONMENTAL Governance Governance issues such as executive pay, accounting & ethics

Our Commitments: We at SFG see three high-level objectives as being fundamental to our operations; 1. Facilitating a low carbon economy – We are dedicated to carrying out our responsibilities and commitments under the 2015 Paris Climate Agreement as well as running our company with consideration for climate change. Although the direct effects we have as a network operator are minimal in comparison to those of many other firms, it is crucial that we manage the ones we do have well and make the most of our position within the telecoms sector to urge others to reduce their greenhouse gas (“GHG”) emissions. In doing so we aim to explore how we can implement a net carbon zero pathway within our business and align to Irelands 2030 and 2050 targets. 2. Social & Economic Inclusivity – We acknowledge that we significantly influence others’ ability to fulfil their ESG commitments, particularly in the social sphere. As a result, we are focused on aligning our operations in accordance with the United Nations Sustainable Development Goals (“UNSDG’s”) and will evaluate our direct and indirect positive and negative contributions with regard to achieving these objectives.

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3. Transparency & Influence – As a digital communications business we recognise we have a significant role to play in supporting Irish civic society and commercial enterprises to improve their long-term sustainability. Therefore, in the interest of transparency, we commit to annually publishing our progress on ESG performance through the Global Real Estate Sustainability Benchmark (“GRESB” infrastructure scheme) so that our stakeholders can follow our progress as we aim to maintain our 5-star rating and also in the hopes to influence other companies to begin their ESG journey.

PLANNING

• Contextualising our organisation • Defining our ESG commitments • Assigning roles and responsibilities • Procedures and planning

CHECKING

• Performance evaluation • Ongoing Management Review • Risk assesments and internal audits • Monitoring and measurements

• Operations of the business • Use of procedures and plans

The risk management procedure used at Speed Fibre Group for managing, monitoring and mitigating ESG risks

At SFG, we also recognise the importance of effective internal and external reporting to ensure our team remains focused, empowered and motivated to deliver on our sustainability goals. This also aids in the creating transparency so our stakeholders can see how we are making progress and potentially learn from our endeavours. In order to effectively monitor, track, and assess the status of each of our ESG metrics and ensure that we are on track with both our internal targets and expectations as well as industry best practices, we also adhere to a risk management framework, which is aligned to third party standards wherever possible. In this

way we are able to manage our obligations and commitments, reduce our negative impacts on the environment and promote the continual improvement of our ESG performance. As such we are currently working towards achieving our ISO 14001 certification: the standard for environmental management systems, which will allow for the formalisation of our protocols, measures, controls and procedures to better manage and record our environmental risks and opportunities with a view to certification in early 2023.

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Materiality

We ensure that streamlined interim updates between reassessment captures new issues or changing topics. This ongoing assessment process acknowledges emerging risks, opportunities and stakeholder views across the business. We monitor evolving external aspects by working with third parties, but also by reviewing feedback from surveys, developing our own ESG knowledge, and analysing insights generated from our social media platforms.

HIGH

To ensure SFG has the right focus and a balanced business strategy, our ESG framework is founded upon a materiality analysis, undertaken in accordance with the Global Reporting Initiative (“GRI”) standards. This assessment allows us to identify and prioritize the environmental, social and governance issues that are of greatest concern to our stakeholders and relevant to the success of our business. This helps us to identify and prioritise our most significant risks, opportunities and areas for value creation, that ‘fall in line’ with our business’ philosophy and commercial objectives. We identified our key priorities and commitments by conducting a qualitative materiality assessment of our firms ESG risks and opportunities.

Carbon Emissions

Importance to stakeholders

Stakeholder Engagement GRESB Reporting

Waste Management

Employee Physical Climate Training and Risk Development Customer Employee Satisfaction Engagement

Fraud Water Use

Habitat and Biodiversity

LOW

SFG General Counsel Claire Murphy selected for The Legal 500 GC Powerlist: Ireland 2022.

SFG Lawyer Louise O’Connor selected for The Legal 500 GC Powerlist: Ireland 2022.

96/100 and 5-star rating in GRESB in 2022.

Enet won a NISO Occupational Health and Safety Award.

Enet was recognised as a ‘Deloitte Best Managed Company’ in 2022.

Magnet+ was awarded ‘Brand of the Year’ by the All-Ireland Business Foundation.

Monthly Well-Being and H,S&E campaigns.

96% of employees received training in 2022 amounting to 2,419 training hours completed.

Extension of our hybrid working policy.

Application to Silver Investor in Diversity Awards.

Group-wide GDPR and Cyber Security training.

Published our first ESG Insights Report.

Installation of electric car chargers in our Limerick office.

Magnet+ awarded ISO45001 for Occupational Health & Safety.

Recertification of ISO9001 and ISO14001 for the business.

Employee & Inclusion and Contractors Health Diversity and Safety

Lobbying

Community Giving and Engagement

Legal Compliance

Whistle-blower Protection

LOW

Data Security

Conflicts of Interest

SFG Awarded ‘In-House Legal Team of the Year’ from the Dye & Durham Irish Law Awards.

Relevance to business success

HIGH

Participation in STEM Education.

2022 HIGHLIGHTS

Speed Fibre Group materiality matrix. Various ESG related issues are ranked based on importance to stakeholders and relevance to business success. P8

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Environmental

P 10

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Reducing our Energy Consumption

Improving Waste Management

Addressing Travel

Biodiversity and Habitat

Our Approach to Climate Related Risk and Opportunity

The Move to Paperless Billing

Sustainable Practises within Wireless Operations

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At SFG, we strive to minimize our negative effects and maximize our positive influence whenever we can. This is being achieved and implemented through the lowering of our energy consumption and, consequently, our carbon footprint; protecting terrestrial ecosystems and biodiversity; limiting production where possible; and properly disposing of waste. Through our customers, partners, employees, and members of the community at large, SFG hopes to promote

and consequently be an enabler of circular economy. These guidelines are outlined in our collection of environmental sustainability policies. Our environmental strategy specifically targets the operational portion of our business and additionally SFG expects all subcontractors and suppliers to co-operate fully in the implementation of this system.

Reducing our Energy Consumption The reduction of our carbon footprint is a key element of our ESG framework and developing net zero pathway. Our various energy policies clearly outline our approach to these issues. We have identified our main carbon impact areas as follows: • Scope 1: direct emissions through corporate fuel usage, heating at SFG offices and employee travel in company owned vehicles. • Scope 2: electricity used by SFG at sites owned and/or controlled by them. • Scope 3: indirect emissions through employee travel in employee-owned vehicles, employee home-working emissions, emissions associated with materials and supply chain.

Work from Office Work from Home (2019) (2021)

2021

2022

Scope 1

144 tC02

203 tC02

Kilometres

Scope 2

976 tC02

1021 tC02

Tonnes of C02

Scope 1&2 Data - 2021 & 2022

976

Tonnes of C02

1021

1,155,536

515

144

600

4,000,000

500

3,500,000 3,000,000

800

400

2,500,000

600

2,000,000

400

1,500,000 144

203

300 200

1,000,000

100

500,000

Scope 1

Scope 2 2021

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339,930

4,500,000

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4,040,266

Scope 3 C02 Tonnes per year

1200

200

Hybrid (2022)

Scope 3 Data

Scope 1 & 2 Energy Data 2021 & 2022

1000

We calculate our scope 1 and 2 emissions on an annual basis using a systematic data collection procedure and framework. As you can see from the above graph there has been an increase across scope 1 and 2 of emissions between 2021 and 2022. This is due to the growth of the business combined with a greater understanding of how we can more accurately record our energy data to prevent greenwashing (see more on this below). We have continued to monitor our Scope 3 emissions to understand the impact moving to a hybrid working environment had on our CO2 emissions year to year, which you can clearly see an overall positive effect as demonstrated in the below graph.

2022

0 Work from office (2019) Work from home (2021) Hybrid (2022)

Kilometres

Tonnes of C02

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The concept of ‘Greenwashing’ is one which has come to the fore in recent years. Greenwashing is an issue in which businesses depict themselves as more environmentally friendly or sustainable than they actually are. To aid against this we have ensured that we have stringent procedures in place for the collection of ESG related data with accompanying ‘checks and balances’ through internal audit processes and verification of supplied data by external consultants. In order to promote environmentally responsible behaviours, we are cognisant of the need to raise employee awareness through the delivery of training and communications, which we achieve through our employee engagement platform, WorkVivo. To reduce emissions from travel, we have also started a number of employee programs and financial incentives (such car-sharing). We permanently redesigned our operations to accommodate flexible and homeworking, which helps accomplish a dual goal of emission reductions and better worklife balance, after realising the success of hybrid working throughout 2022. We have also assessed the environmental impact of IT operations and infrastructure, and identified opportunities to reduce energy consumption, carbon emissions, and waste. As a result of this, we adopt a cloud first strategy where practical, and have consolidated many of the resource intensive services to carefully selected partners. ESG policies were a major consideration when selecting these partners. We enhanced the remaining necessary services using virtualisation, which resulted in a dramatic reduction in the power and cooling requirements of the IT services provided to the business. We have also implemented a policy to prioritise power efficiency and repairability of all IT purchases and equipment. There has also been a reduction in Printing services across the group through initiatives such as The Move to Paperless Billing (see below). Lastly we ensure all IT waste is recycled using WEEE certified partners.

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Regarding the operational portion of our business, we source labour and materials locally where possible, ensure that energy design is a key part of our network design. Regular maintenance and servicing is essential to keep equipment running efficiently and in circumstances where a replacement is required, emissions and energy efficiency is a key consideration. The business has programmes in place to swap-out end of life air conditioning units and power systems at our colocations sites which house Enet and customer network equipment. The purpose of these programmes is to ensure the air conditioning performs effectively in the event of excessive heat, and sites stay up with sufficient power backup time in the event of mains power damage caused by such events as weather related incidents. In 2022, 26 new air conditioning units were installed to replace aged systems which were underperforming. A specific maintenance program for air conditioning systems was initiated in all 88 MAN facilities. This lead to the repair of 51 sites and the optimisation of all systems. As a direct result, we have observed a noticeable reduction in service issues or disruptions, which reduced the volume of truck roll to sites for incident management. The effected repairs combined with new replacements lead to a significant increase in service availability coupled with improved air cooling set points to maximise the utilisation of free air cooling and reduce the volume of mechanical cooling. Going forward into 2023 the maintenance program continues, with a further 36 aircon unit replacements scheduled, alongside targeted maintenance for the entirety of our air conditioning assets. In addition, 20 New DC power supply systems are planned for installation in 2023, replacing aged systems which are less efficient. In the past two years 27 DC power supply upgrades have been completed. The upgrade program will target a further 36 systems in the next 3 years to complete upgrades throughout all 88 MAN facilities.

The new systems require less maintenance and cooling as compared with older generations of equipment. The majority of the MAN locations also received grounds cleaning and internal facility cleaning to eliminate the accumulation of dust and foreign objects which severely impact the operations of air conditioning systems and power supply systems. In addition, lighting systems in 17 MANs locations had aged fluorescent lights replaced with more efficient LED lights which operate on a lower consumption, saving energy. The above mentioned programs to upgrade aged DC power supplies and air-conditioning systems will continue for the next three years.

Improving Waste Management Although we do not produce much waste in our business, the small amount that is produced we ensure that we have a proper recycling and/ or disposal system/process in operation through licenced waste management companies. We therefore promote sustainable waste management throughout our daily operations to limit the pollution of our local habitats and ecosystems and also encourage sensible consumption and promote/enable circular economy principles. Throughout our business all employees and contractors are trained on general awareness and cognisance of recycling and the separation of materials such as paper, plastics and cardboard boxes occurs in all of our offices. In addition, SFG ensures that all purchased stationary and ink cartridges are recycled. During our development activities we also insist on the sustainable disposal of all construction waste and ensure that responsibilities for doing so are clearly identified in all of our contracts. We understand that knowledge is power in regards waste management so we ensure that all staff know the correct use of our own recycling bins in the office through communications on our employee engagement platform ‘WorkVivo’ and also educate through informative posters placed throughout the office. As the old adage goes, “you can’t manage what you don’t measure”, so as an initiative for 2023 we aim to implement periodic waste tracking and KPI’s to benchmark our efforts and also provide a consistent set of metrics for future comparison.

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Addressing Travel We have detailed internal procedures for travel management as this is a key area for performance improvement for our corporate emissions. All travel in company vehicles is recorded and carbon emissions are calculated annually. All employees are encouraged by SFG to make sustainable travel decisions, and the company will continue looking for ways to reduce or eliminate needless or unnecessary travel. Adoption of electric vehicles in Ireland is accelerating. SFG recognises this and in an effort to ensure staff are not being inhibited by our infrastructure we have installed electric car chargers in our Limerick office to enable our staff to make the switch to a fully electric vehicle and not have to worry about charging their vehicle elsewhere.

Biodiversity and Habitat Due to the nature of our network, and our development of telecom tower locations that are often in remote rural locations, we understand that we have a duty to conserve and protect the species, habitats and associated ecosystem services during both our construction and maintenance activities. We are seeking to start regularly identifying, assessing, reporting and including in our impacts and aspects register these mitigation measures and disclosing naturerelated risks and opportunities at an asset level. In terms of wider corporate business activities, we continually prioritise sustainable use and protection of potable water and protection of ground and marine resources by means of managing wastewater discharges from our sites. We ensure the implementation of these principles through our ISO 14001 and ISO 9001 aligned Environmental Management System and Quality Management System. This involves regular ESG-related staff training, engagement with our suppliers and contractors on ESG topics, alongside the regular monitoring and reporting of key metrics. Our SFG risk register assesses each of these risks using data KPI’s for each impact area based on impact severity and likelihood,

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this helps us to re-balance our efforts and renew our objectives frequently to ensure continual improvement.

Our Approach to Climate Related Risk and Opportunity We regularly consider climate-related risks consistent with the recommendations of the Taskforce for Climate-related Financial Disclosures (“TCFD”) during our decision-making processes, we continue to enhance these processes to best manage the future risks we are likely to face. In 2021, we undertook a physical climate risk screening exercise for our key SFG offices and a selection of key infrastructure across our networks using the 427 risk platform, developed by Moody’s. Our physical risks are identified across two types: Chronic (heat stress, subsidence and coastal flooding and sea-level rise) and acute (flooding, storms). The 427-climate risk assessment utilises a simple index screening methodology to identify facilities that are particularly exposed to climate related risks. The index identifies risk against various climate hazards including earthquakes, wildfire, floods and water stress. Our analysis showed that all of our assets were at low risk from most climatic hazards, however the exercise did highlight the need for future planning around our infrastructure and consideration of mitigation techniques potentially required in the future to ensure the reliable operation of our network. Following the completion of this exercise we will continue to monitor the exposure of our network to climatic risk. SFG understand the risk that climate related incidents pose, as such the national fixed and microwave network is monitored 24x7 by Enet’s NOC in Limerick. All network elements, such as power, network devices, signal levels etc are monitored continuously by element managers, and when alarm conditions exist, these alarms are presented to the NOC operator who will investigate, diagnose and action accordingly. Operations staff and management monitor weather forecasts and implement appropriate Storm Planning and Storm Recovery Plans as

the situation arises. Where access to sites is particularly difficult, or where sites are particularly exposed, Enet endeavours to provide as much battery backup time as possible. We analyse all faults that occur on services, equipment, and sites, and look to identify patterns and root cause of failures. If specific corrective measures are implemented, we will usually monitor the site/service for an appropriate period post implementation. If corrective measures are implemented at a site due to weather related issues, we will observe the effectiveness of these measures through normal operational reporting and post implementation analysis.

Risk Category

Basis

No Risk No Exposure

Mid 2022, we participated in a ComReg consultation on “climate change and its effects on network resilience, which would address, climate related network vulnerabilities and power reduction. Enet provided insights into its strategy to mitigate climate related network risks including its infrastructure upgrade program as outlined above, relating to the reduction of energy consumption.

low Risk

Medium Risk

High Risk

Red Flag

Not significantly exposed to historical or projected risks

Exposed to some historical and/or projected risks

Exposed today and exposure level is increasing

Highly exposed to historical and/ or projected risks, indicating high potential for negative impacts

Climate Hazard

Risk Level

Site Score

Country Benchmark

Earthquakes

None

Floods

Medium

Heat Stress

Low

Hurricanes & Typhoons

Medium

Sea Level Rise

None

Water Stress

Low

Wildfire

Low

Example results report from the Speed Fibre Group physical climate risk analysis undertaken in 2021 on various facilities across the group.

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The Move to Paperless Billing Enet’s Finance team has undertaken a significant project to eliminate the printing of physical paper invoices and move to an electronic alternative to achieve the twin benefit of easing our environmental impact as a business and reducing our expenditure in relation to postage. Since this decision was made in December 2020, we haven’t printed a single invoice. - In 2018 we posted and printed 4,874 invoices - In 2019 we posted and printed 5,312 invoices - In 2020 we posted and printed 6,838 invoices. - From December 2020 onwards we began to electronically save our invoices. - From December 2020 to December 2022, we have generated but did not print 17,911 invoices amounting to 26,073 pages.

Although difficult to calculate, on average a tree will produce approximately 16 reams of paper. Since 2020, through our paperless billing initiative, we have saved 52 reams of paper which equates to approximately 3.25 trees saved!

Sustainable Practises within Wireless Operations Enet operates a national microwave radio network consisting of circa 1,800 licensed and unlicensed microwave links and incorporates almost 4,000 radio units. From early 2020, working with our vendor, Enet has introduced newer microwave technologies that are considerably more efficient than previous generations of radios, reducing spectrum consumption by 75%, tower footprint by up to 50%, and energy consumption by up to 40% per unit deployed. Almost 40% of Enet’s deployed microwave equipment is now utilising this more efficient model, and it is now the preferred method of delivering new services. In addition to this, Enet has implemented a program of proactive replacement of legacy radio equipment which allows the consolidation of multiple independent radio units onto a single space and energy efficient chassis, which has also reduced our spectrum, energy, and space usage at our high sites. All recovered units are returned to the vendor for replacement/ repair and are upgraded through that process. Units that are unsuitable for repair are either recycled or disposed of in a responsible manner by the vendor.

Similarly, Magnet+ undertook a paper bill conversion process with all customers as a green initiative. During 2022, the Magnet Finance team reduced its proportion of posted invoiced from 25% to just 6%! This is an average reduction of 2,000 invoices being posted monthly amounting to a saving of 2.79 trees over a 12 month period and saving the business approximately €25,000 in postage fees. So, overall SFG has saved over 6 trees with our paperless billing initiatives!

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Social

P 20

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Connecting Communities

Working with our Customers

Customer Satisfaction

Health and Wellbeing

Equality, Diversity and Inclusion (“EDI”)

Health and Safety (“H&S”)

Charity and Philanthropy

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Our business operations are fundamentally based on treating our stakeholders fairly, both internally and externally. Our business approach has always included providing social value creation to our consumers through the provision of high-quality fibre connectivity. We feel at SFG that we can really make a difference on the social aspect of ESG. Our networks support businesses, communities and people who were previously underserved, so that those areas can compete on a national and even international basis and give access to a wider variety of employment opportunities. 5G networks are set to become a driving force behind Ireland’s economy, as such SFG is at the forefront of how society can adapt and change working lifestyles. Furthermore, SFGs activities promote and enable the transition to a low carbon economy as we provide fibre connectivity to communities across Ireland which will assist the transition away from unnecessary business travel by increasing the accessibility of remote working. Our networks will also assist innovative and low carbon technologies and new ‘green business plans’ across Ireland by providing essential network connectivity and the ability for real time management.

Connecting Communities

Working with our Customers

The very essence of SFG is focused on regional connectivity. Both the MANs networks and the Wireless network, that we have built more recently, are focused on ensuring the connectivity requirements of those in more remote locations are met so that those areas can compete on a national and even international basis. We think that as connectivity in rural and regional areas gets better over time, more jobs will become available there, more people will be able to work remotely from hubs and homes, and commute times and distances will get shorter. This will have positive effects on the environment, rural redevelopment, work-life balance among the populace, as well as benefits for the family and society as a whole. Our networks allow for activities (employment, trade, research etc.) to be undertaken in areas of the country where that would not be possible without the existence of SFG.

We are driven by the care for our customers, and we consistently strive to improve our services and make things easier and more cost-effective for them. We are committed to delivering a reliable and flexible service to meet our customer’s needs, we do this through the development of strong partnership. This means that customers can call on us from time to time to ensure the delivery of important and urgent requirements.

100Gb in Regional Ireland: Enet is the first provider in Ireland to provide 100Gb connections in a significant manner to the industry and its end users outside of Dublin, having deployed 100Gb connections in Cork, Tralee, Shannon, Portlaoise, Waterford, Longford and Kilkenny to date. This showcases Enet’s commitment to making accessible market leading products and services in regional cities and towns traditionally left behind the innovations available to those in the capital.

Enet Case Study: Primary Schools Connectivity Case study in Regional End-users and the application of connectivity services In the past two years Enet has been pivotal in the roll out of high-speed connectivity to a primary schools across Ireland. At the conclusion of this project in the coming months we will have provided connectivity to approximately 700 primary schools all across the country! This project will be key in bringing connected learning projects to the primary school sector. Similar to what has been available in the secondary and third level schools for the past number of years. Through Enet’s involvement and cooperation, this project has the ability to reach the smaller and more remote schools ensuring all students get the same access to connectivity regardless of where they go the school – reducing the barrier to quality education for many. This connectivity will greatly enhance the educational experience for younger students, allowing for a more connected learning experience, while also providing the bandwidth to increase use of safety measures like content filtering and security precautions such as antivirus protection, ensuring a safer online space for one of the most vulnerable cohorts of end users.

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Magnet+ Case Study: LGBT Ireland Over the past seven years, LGBT Ireland has used the Magnet Talk service from Magnet+. Magnet+ are proud to partner with such an influential positive charity. Magnet Talk supports the successful operation of the network on the National LGBT Helpline nationwide by providing key technological voice solutions including the Magnet+ soft phone or the Magnet+ App. Speaking about the Magnet+ services, LGBT Ireland said: “Since implementing the Magnet+ service we’ve found that LGBT Ireland has been able to move away from the historical way of operating a helpline such as traditionally picking up the receiver in an office, we’re now able to have 65 volunteers nationwide work remotely using the Magnet+ technology which includes a Magnet Talk soft phone or Magnet Talk app, which has been a major success for us. The ability to be able to work remotely using the Magnet+ solutions has also made it easier for us to recruit volunteers, whether it’s from home, from the office or from abroad, having the option to work remote has definitely been of benefit to us. Magnet Talk has supported our 65 volunteers nationwide to be able to take calls seven nights a week, uninterrupted, across seven different locations nationwide.” Claire Murphy, Head of Fundraising and Partnerships for LGBT Ireland said: “At LGBT Ireland, we would be happy to give Magnet+ a rating of five stars out of five. We’ve always found that they are incredibly supportive, whenever we come up against a challenge, we can just pick up the phone and someone will spend as much time as needed to be able to support us so we are incredibly happy with our service from Magnet+.”

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Customer Satisfaction At Magnet+, Customer Experience is always at the fore. We have, as such, developed and implemented a Customer Experience Programme. This programme takes a top-down approach with everyone from the Managing Director down being involved and supportive. Senior management are on hand to answer queries from our customers and all negative feedback is worked on expeditiously by a cross functional team to ensure solutions are achieved in a timely manner. Positive testimonials are shared across our social media channels and internally on our intranet and screens throughout the office as a reminder of why we maintain our customer-first philosophy.

Our ‘Voice of the Customer’ (“VOC”)programme was relaunched in 2021 and has continued to grow throughout 2022. At Magnet+, we live by our tagline People Powered Connectivity. Every time you call Magnet+ you talk to a real person. Every issue that comes to our support team is dealt with in a timely manner. As part of our Voice of the Customer programme, surveys are sent to customers at different touch points throughout the customer journey. The four touchpoints are:

What we measured in 2022 We have three measurements carried out on each survey we send to customers – NPS, CSAT and Customer Effort 1. Net Promoter Score (NPS) Net promoter score or NPS asks the customer how likely they would be to recommend us to a friend from a scale of 0 to 10. This is based on the specific transactional touchpoint rather than the overall relationship. Our average NPS score in 2022 was 63. The average UK telecoms NPS score is 17, with some companies receiving minus NPS figures.

Net Promoter Score (NPS)

· Sales · Service Delivery · Faults · Help This ensures we are getting feedback from customers every time they interact with a member of the team, allowing us to make positive changes in real time.

80 60

2022

2023

43 30

40 20 0

2020

2021

2. CSAT (Customer Satisfaction) Customer satisfaction or CSAT is exactly as it sounds, it asks the customer how satisfied they are with the service provided by Magnet+ for that specific touchpoint. Our customer satisfaction scores are increasing year on year with our average CSAT score for 2022 being 91%.

Customer Satisfaction (CSAT) 100 80 60 40 20 0

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2020

2021

2022

2023

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3. Customer Effort

Survey Response Process

Customer Effort score asks the customer to advise how easy they found it to deal with us for their touchpoint. Our average Customer Effort Score for 2022 was 89%.

If a customer shares any negative feedback a survey response case is created to address the feedback. A member of the Magnet+ team will call the customer to discuss their feedback and get an understanding on what we can do to improve the customers experience into the future.

Customer Effort 89

90 88 86 84

85 83

Customer Journey Mapping

82 80 78 2020

A customer can opt out of receiving surveys if they wish. It is vital that the correct customer gets the survey so this is checked by the agent handling the case before the case is closed.

2021

2022

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Throughout our journey on the Voice of the Customer programme, we have completed Customer Journey Maps for our products. The goal of customer journey mapping is to identify key moments of truth (pain points and wow moments) and develop a detailed action plan to improve the overall Magnet+ experience. In 2022, we completed as part of our VOC programme: · 9 Workshops

Google Reviews Our Google review score for 2022 was 3.2 out of a possible 5. Year on year we continue to see a strong positive trend in our Google reviews. One factor which was responsible for the increase in reviews in 2022 was due to a new process being implemented where we ask those that provided positive feedback through a survey to share feedback to Google.

Google Reviews Score 5 4 3

2.4

2.8

3.1

3.2

2022

2023

· 2 Customer Journey Maps (FTTH & Wireless) · 4 Customer Personas · Combined Action tracker to address pain points highlighted during the sessions. These sessions involve a full end to end review of a customer’s journey. It is different to most journeys completed by companies as it focuses on the actual customers journey and not the company’s perspective. For each customer journey map, the team will create a typical customer for each product to ensure the mapping is authentic. Once the journey is completed there is a list of pain points identified and the team work on these to improve the customers experience with Magnet+.

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Health and Wellbeing SFG recognises that its employees are its most valuable resource, and that health and wellbeing are critical components of SFG’s social responsibility. We understand that a healthy workforce is essential for us to operate efficiently and effectively, therefore our commitment to ensuring we provide a safe and healthy workplace is supported by robust policies and procedures. Our flexible work schedule has already proven to be a success with 86% of employees voting that they were happy with our hybrid working model. We partner with Employee Assistance Programme (“EAP”) providers enabling our people to have a secure confidential helpline and access to counselling should the need arise in our everyday busy lives. We have a comprehensive sick leave policy that assures our people that their livelihood is secure should they be unable to work for a protracted period. Our engagement platform, Workvivo, contains a dedicated EAP page promoting online webinars on key topics such as Skin Cancer Awareness, and the importance of ‘switching off’ to name a few. In addition to our EAP offering, we place emphasis on training in key areas such as mental health and encourage good physical health practices by providing online Zumba classes posted through Workvivo. We promote the ‘bike to work’ scheme and provide bike racks at our offices to promote active transportation.

Employee Engagement Engagement will always be a priority for the business and in 2022, we particularly focused on how we could maintain engagement initiatives regardless of the geographical distribution of our people, and so the Group partnered with Workvivo to foster a sense of community. The group focused on recruiting “engagement champions” who would promote the use of Workvivo and assist in developing new creative spaces for all our employees – spaces such as Health and Fitness, Getaways & Day Trips, Our Pets, Movie Nights, Training, Equality, Diversity

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and Inclusion, Health & Safety, amongst others. Our commitment to engagement surveys remains and, with the assistance of Workvivo, rapid pulse surveys can now be distributed to gauge employees’ opinions on new ideas, how the business is doing, and what they would like to see more of to assure them they are always listened to and their opinions matter. The leadership team understand, value, and promote the belief that motivated and engaged employees are crucial for maintaining a positive company culture. Therefore, the measuring of employee engagement is seen to be a vital piece of the ‘People Puzzle’. We regularly conduct employee satisfaction surveys to assess the overall level of satisfaction, engagement, and well-being within our workforce. By collecting and analysing feedback from our employees, we aim to gain valuable insights into the key factors influencing their job satisfaction and identify areas where improvements can be made to enhance the overall employee experience. Our 2022 survey was conducted externally by EVORA and co-ordinated and distributed by our HR team. The anonymous survey contained 5 sections of statements, of which employees were asked to rate on a scale of 1-5 their overall satisfaction which that statement. The use of data and metrics helps us to understand the behaviours and levels of engagement of our people. Analysing data on employee attendance, productivity, and turnover rates provides insights into areas where we may need to improve.

SOME KEY HIGHLIGHTS BELOW: Statement

Average score out of 5

How comfortable are you with the hybrid working model (combination of remote and in-office work)?

4.3

how likely are you to continue working for the Company in the next 12 months?

4.2

Reflecting on your experiences in 2022, how would you rate your overall satisfaction with the level of diversity and inclusion groupwide

4.2

Reflecting on your experiences in 2022, how would you rate the level of support towards employee wellbeing

3.9

The firm is socially responsible with respect to charities

4.2

I am aware of and understand SFG’s ESG commitments

3.9

Equality, Diversity and Inclusion (“EDI”) SFG’s core EDI principles are to ensure we treat all our people with dignity and respect, by creating a comfortable, safe, inclusive, and secure work environment for our people but also improving the community in which we live and work. We believe that through our EDI initiatives, our overall sustainability leads to our long-term success, and we are confident that we are better equipped to navigate any challenges and opportunities in the modern world. We are an organisation that respects the dignity, uniqueness, and intrinsic worth of every individual in SFG and associated communities. Our approach to a more inclusive workforce helps us attract and retain top talent, and builds stronger relationships with our customers, contractors, stakeholders, supply chain and the wider community. Our commitment to EDI enhances our engagement and retention in the business whilst also attracting talent from all parts of the world because we live these values and behaviours, and the recent achievement of a ‘Silver’ award in early 2023 from the Irish Centre for Diversity is testament to our commitment to this programme. The uptake from our people, with 75% response rate, highlighted our pledge to EDI. In 2022 we established an EDI committee which is host to 12 employees, including support from the executive team, from varying departments, roles, and cultural backgrounds, with each

person bringing fresh ideas and perspectives to the weekly meetings. It has been through the committee that we have truly learned the wants and needs of our diverse workforce. We base all our EDI activities on what we know our employees are most interested in, and what it is that makes them feel valued and respected by the business regardless of their cultural background. Our goal is to have more diversity in our departments by focusing on recruitment, retention, development, and promotion of diverse individuals across the business. Our flexible working arrangements allows us to create a workplace that welcomes all people from across the country, with this in mind, we introduced EDI virtual coffee mornings that are held one Friday of the month and involved randomly assigning groups of 10 employees to an online coffee and catch up style meeting to allow our people to get to know each other. We have also focused on acknowledging and celebrating key cultural days such as Holi, IWD, Pride Ramadan and will continue to better support our workforce.

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Diversity and Inclusion Talent Management Invest in our People to enable them to suceed to their full potential

Mental Health & Wellbeing Support the Mental Health and Wellbeing of all our People

Attract, retain, develop and support a skilled and diverse workforce

Employment Engagement become an Employer of Choice

We empower our people to be the best that they can be, by investing in their potential, by enabling them to succeed, by supporting their wellbeing, by rewarding for their successes and ensuring that they work in an innovative and inclusive environment.

Reward & Benefits Reward our People for their contribution to the Company’s success

Health and Safety (“H&S”)

Charity and Philanthropy

The health and safety of our employee, contractors and the public has always been of major importance to us here in SFG. A safe environment is also integral to unlocking the potential of all of our team members. This is also a key concern of the Board of Directors as they recognise that a safe workplace goes hand-inhand with its success. SFG align our practices and procedures to ISO 45001 which sets the standard for occupational health and safety management systems.

In line with our commitment to making a positive impact, we are committed to promoting charitable contributions and philanthropic actions in communities beyond our immediate reach. We believe in the importance of giving back and establishing meaningful relationships with organizations that make a significant impact in different parts of the world.

Our H&S team ensure monthly updates are presented on any H&S incidents or accidents, near-misses or good-catches to ensure transparency and continuous monitoring and improving. We have procedures in place to identify and mitigate possible hazards as we recognise that prevention is better than cure in these instances so we ensure all new hires received a H&S induction in order to set standards, raise awareness of hazards, explain how H&S is managed in SFG, and make our procedures clear. We also circulate regular communications on workplace health and safety on our empoyee engagement platform, WorkVivo and additionally our contractors receive ‘ToolBox Talks’ on ways they can stay safe on site. There is also a H&S workplan for the year which includes several site visits and regular inspections which are complimented by a suite of Health and Safety polices, practices and procedures. Innovation is at the heart of our business and as such we are always looking for ways to combine our innovative thinking and our commitment to putting employee safety first.

We have been proud partners of the Hope Foundation since the start of 2020. In the past year, our collective efforts have resulted in raising an impressive sum of nearly €135,000 to support vital projects by the Hope Foundation in Kolkata. The Hope Foundation is renowned for its exceptional work in providing support to vulnerable children, their families, and communities. They address the root causes of violence and neglect through essential services such as shelter, education, and rehabilitation. Throughout 2022, we organised several fundraising activities to contribute to the Hope Foundation’s cause. We started the year with a heart-warming coffee morning, where our employees came together to enjoy delightful beverages and treats while making generous donations to support the foundation’s initiatives. This event served as an opportunity for our staff to connect, bond, and actively participate in our philanthropic endeavours. Additionally, we hosted a series of virtual events to engage and involve our employees in the fundraising efforts. A virtual quiz and bingo event provided a fun and interactive platform for our teams to test their knowledge, enjoy friendly competition, and contribute to the cause. It not only raised funds but also served as a teambuilding exercise, fostering a sense of unity and camaraderie among our staff. To further amplify our impact, we organized an online raffle, offering exciting prizes to our employees and the wider community. This digital initiative allowed us to reach a broader audience, encouraging wider participation and creating awareness about the incredible work undertaken by the Hope Foundation. Through these diverse fundraising activities, we have continued to make a difference and contribute to the betterment of vulnerable communities.

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Governance

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Doing business responsibly

Board oversight in SFG

Risk Management

Decision Making and ESG

Commitment to Transparent Reporting

Stakeholder Engagement

Speaking up

Anti-Bribery and Corruption

Data Protection

Cyber Security

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Doing business responsibly At SFG we don’t just believe in doing business but doing it responsibly. We believe that doing business responsibly is not only the right thing to do socially or environmentally – it is also the smart thing to do. Being considerate of our impact both on society and the environment creates an image of responsibility and accountability, this makes business sense in an ever-changing commercial environment. We seek to understand global trends and their impact on our stakeholders expectations to help manage risk and grasp/ create opportunities. We consider a range of issues within our corporate governance strategy including management structures (including board composition, audit committee structures, delegation of authority and director independence), external engagement (including lobbying activities, political contributions and conflicts of interest) and business practises (including risk management, cyber security, fraud, bribery etc.). SFG appreciates and understands the clear relationship between a business’s approach to governance and its ultimate success. We believe that governance means “doing business responsibly” and this is a key, simple message that is transcended in everything we do. We endeavour to manage the interests and expectations of our stakeholders in a matter which upholds the basic principles of corporate governance which include; accountability, transparency, fairness, and responsibility. As there is no ‘one-size-fits-all’ approach to governance, SFG has taken the time to ensure there is a clear and structured governance framework within the business, and we adopt a continuous development approach that ensures we analyse our effectiveness and performance in relation to governance matters on an ongoing basis.

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Board oversight in SFG Governance takes a top-down approach in SFG. SFG’s bord of directors (the “Board”) who meet as a whole every two months to discuss operational and strategical commercial matters in additional to other topics such as health and safety, risk management, committee updates, and much more. The Board has ultimate oversight of the businesses operational and strategical objectives and the effective direction and implementation of all items detailed within the Board’s terms of reference and the Board’s yearly workplan. However, the Board has delegated authority to the Executive Leadership Team (the “ELT”) to manage the implementation of these objectives in conjunction with the management team. The ELT is comprised of the group CEO, CFO, CTO and Company Secretary, General Counsel & Director of Shared Services. The Board established board sub-committees to ensure the adequate assistance and discharge of duties. The Board maintains an oversight over each of its sub-committees and they monitor these sub-committees by reviewing the minutes of sub-committee meetings and through discussions with the respective sub-committee Chairperson on their activities, decisions, actions, or improvement recommendations on any area within their remit. The Renumeration Committee has the responsibility for setting and/or reviewing any remuneration policies as required by the Board from time to time. The Audit and Risk committee are charged to ensure that appropriate procedures are in place in the business (i) to identify, evaluate and manage risk from a strategic and operational perspective, (ii) to monitor the implementation of risk management procedures, and (iii) to oversee the relationship with the external auditor, including reviewing the findings of the audit on the Group, and reporting to the Board as necessary. They also conduct an annual review of internal controls and key ESG Policies. Moreover, they ensure an adequate and appropriate level of insurance cover is in place each year.

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Risk Management From an operational perspective, to manage and mitigate risks, legal or otherwise, the company frequently updates the business’s risk register. Management is responsible for identifying and updating the register on an ongoing basis to ensure the business is implementing appropriate controls to mitigate risks. SFG recognise that poor governance of certain risks can lead to reputational damage and economic loss. The risk register has also been expanded to cover people and environmental risks, in particular risks associated with the transition to a low

carbon economy. In this regard the business has developed a suite of policies and embedded certain procedures to better govern and manage arrangements right across business departments from the procurement of supplies, the management of contractors, the recruitment of headcount, to the management of network resiliency. Regular management meetings with senior management ensure each of the policies and processes are always under review with a view to continuously improving and ensuring proactive governance.

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sess As

Repor t

Identity

Decision Making and ESG

Commitment to Transparent Reporting

Whilst SFG has made great strides in improving the governance in the business, it is always striving for improvement and excellence within this area. In so doing, SFG made ESG a strategic area of focus for the company during 2022. In recognition of this being shortlisted for a Good Governance Award. Considerable work has been conducted over the past year to enhance ESG factors being considered in all decision-making practices in the business but more particularly in respect of energy performance, greenhouse gas emissions, health and safety, customer satisfaction, and employee engagement as we identified these as our most significant ESG impact areas in a materiality assessment. We are now implementing ESG related objectives for ELT members and Senior Management to show our commitment to these practices and ensure we are not simply ‘window dressing’.

One way which we in SFG aid transparent reporting is through our board reporting and board papers. Our Governance team has procedures in place for the efficient and succinct drafting, compilation and distribution of information to the board on a monthly basis. Efficiency and clarity are key tenets to good information flows and as such the team always ensure that the right information is given at the right time and in the right format. We also recognise the importance of external benchmarking and voluntary disclosure. In 2022 we chose to voluntarily report our efforts to GRESB, an internationally recognised rating agency, and we received 5-star rating, a score of 96/100 and placed second in our sector in Europe. The GRESB scheme is the leading globally recognised reporting and benchmarking scheme for infrastructure assets. It is a thirdparty independent scheme that our investors rely upon to ensure their investments are meeting best practice standards. The GRESB submission is structured around two important elements namely: management submission items, which examine what you say you will do, and performance data measuring what you actually do. Both are then benchmarked against best practice standards and relevant disclosure frameworks and additionally peer group assessed. The tool helps us identify areas for improvements and allows us to engage with our investors on sustainability topics. We continue to score highly in the management component, which is structured into five aspects: leadership, policies, reporting, risk management and stakeholder engagement, due to our ESG strategy and reporting frameworks. We also score highly in the performance component of the survey in which we submit data relating to our energy, greenhouse gas, water and waste performance, as well as health and safety and employee and customer metrics. In addition to GRESB, SFG are in the process of alignment with the UN Sustainable Development Goals as an objective for 2023.

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Stakeholder Engagement Stakeholders are defined as “those individuals, groups of individuals or organisations that affect and/or could be affected by an organisation’s activities, products or services and/or associated performance”. At SFG, we believe having a positive relationship with our stakeholders is critical to success. We have developed an internal policy, aligned with GRI Standards, which sets out how we identify our key stakeholders, how frequently we meet with them, through what medium (virtual or in person), and what information we typically would share with them and in what format. Engagement and two-way dialogue help to identify the concerns that are important to our stakeholders and also show how our business is responding and managing its impacts. We have recognised our main stakeholders as being: • The Department of the Environment, Climate and Communications • Our regulators such as ComReg; • Our suppliers; • Our customers; • The board of directors; • Our shareholders; • Our employees; and • The public

During 2021 we conducted a stakeholder engagement exercise. This exercise aided as a comparison of our materiality outcomes against the views of our stakeholders We issued the survey to a broad range of stakeholders including regulators, investors and our partners to gauge their opinions. We asked the stakeholders to rank a number of ESG issues based on order of importance and also asked them about their expectations of Speed Fibre Group in terms of ESG reporting, management and objectives. The results from this led to the creation of our GRI Standards aligned Stakeholder Relations Policy. Stakeholder Engagement will be a key focus area past 2022 as we formalise our plan to integrate meaningful engagement with our stakeholders.

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Speaking up Whistleblowing has been a topic of great discussion over 2022 due to the enactment of the Protected Disclosures (Amendment) Act 2022. We in SFG promote a culture of integrity through our leadership and believe that open communication leads to a healthy and successful business and working environment. SFG is committed to the highest possible standards of honesty, openness and accountability and take all wrongdoing extremely seriously. SFG has implemented policies and procedure to educate and inform employees about what whistleblowing is, the procedure for reporting and what protections will be afforded to them in such instances. SFG has implemented and maintained a secure and robust internal reporting channel. A designated representative has been assigned to deal with any such reports and thereafter conduct thorough and prompt investigations in line with the timeframes given in our policy and also in alignment with current legislation. SFG hopes to foster an environment in which people feel free to voice concerns without fear of repercussion but also wish to reiterate that we take any reported concerns seriously.

Anti-Bribery and Corruption SFG conduct all business in an honest and ethical manner and as such have a zero-tolerance approach to bribery and corruption. We are committed to compliance with trade sanctions, anti-terrorist financing laws, export controls and anti-boycott laws to protect our people, clients and stakeholders. Employees and management of SFG pride themselves on their commitment to acting professionally, fairly and with integrity in all our business dealings and relationships. SFG’s Anti-Bribery and Corrpution policy clearly set out the expection on employees to recognise and mitigate any form of corruption they are faced with in relation to their office, employment, position or business. Employees are given guidelines for accepting gifts and how to raise concerns in line with our Speaking Up policy.

Data Protection Data protection was a key focus point for 2022 in SFG. SFG has invested in a continuous improvement approach to our data protection obligations. We have developed a governance charter for data protection that embeds data protection obligations into each business area. We also take a strategic view on data protection, ensuring that ethical and other considerations in relation to the adoption of new ways of working and new technologies are considered through data protection by design. Data protection helps us ensure we stop and consider the issues and impacts of data processing to the organisation and to our stakeholders.

Cyber Security IT plays a central role in developing and implementing technology solutions, services, and infrastructure that enable sustainable business practices. IT also helps collect, analyse, and report on ESG performance and impact. Microsoft Teams and Workvivo have improved engagement and inclusion in the company by helping cross team/ department communication and collaboration. Both platforms have seen a huge rise in engagement and activity over the last 12 months. We have utilised online training services to increase awareness, provide training, and promote best practises. To date, these courses have mainly been on governance, cybersecurity, and privacy. We have selected our CRM and ERP platforms to improve efficiency and automate workflows. This enhances transparency, ensures compliance, and facilitate decision making. IT is helping to strengthen the governance of the company by ensuring compliance with laws and regulations, enhancing cybersecurity and data privacy, and promoting transparency and accountability. We support the company’s efforts to align with stakeholder expectations, industry standards (aiming for alignment with ISO 27001), and best practices (ITSM & data governance) and will provide digital platforms that enable risk management, reporting, and assurance. This process started in partnership with VMgroup to benchmark and improve the security footprint of the business and will continue with the implementation of 24/7 cybersecurity monitoring.

During 2022, data protection basics training was rolled out to the organisation as a whole along with the launch of our Data Governance Charter. Towards the latter end of 2022, we launched our Data Advocates Programme in order to decentralise data protection and have it be a collaborative topic within the business. Data Advocates were nominated to represent each department. As part of their role they will be responsible for the Register of Processing Activities for their department and conducting actions like Data Protection Impact Assessments. The implementation of this programme will be a key project for 2023 alongside others such as the EECC preparation project. Our Data Protection Team aim to invstigate and align our practices with ISO27701, in conjuntion with our IT Department. SPEED FIBRE GROUP

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