Social Responsibility

Human & Labor Rights Policy

At Consolidated Communications, Inc. (together, with its affiliates “Consolidated”), we believe it is critical for our organization to promote and protect human rights in the markets in which we operate, and in our relationships with our employees and vendors.  As a national telecommunications service provider, we believe that the freedom of our users to communicate and to access and exchange information is a fundamental component of the freedom of expression and association.  As an employer and business partner, we strive to foster a work culture that respects fundamental human rights and ensures that our business practices in no way contribute to human rights abuses.  Consistent with these goals, we have established this Human and Labor Rights Policy (this “Policy”) to create awareness and establish expectations related to legal requirements, ethical practices and human rights. These standards are based on our own Company policies, including Consolidated’s Code of Business Conduct and Ethics and Vendor Code of Conduct.  As a guide in furtherance of these goals, we embrace recognized international conventions on human rights, including the International Bill of Human Rights and the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

We expect compliance with this Policy from our employees and affiliates, as well as the vendors and partners with which we do business.  We strongly encourage our vendors and partners to join us in implementing fundamental human rights policies from within their own organizations, and remind them that stakeholders and customers strongly value general integrity as a core principle at the foundation of any Company’s operations.

At Consolidated, it is a priority for our Company and our employees to emphasize a respect for human rights when implementing new and existing business practices. This is especially critical in the developing rural markets that we serve, as we continue to build out and enhance telecommunications facilities that provide users with access to telecommunications services in areas that have historically been unserved or underserved. We also recognize that we must respect the land rights of Indigenous or Tribal communities, and observe the principles of ILO Convention No. 169 on Indigenous and Tribal Peoples, in areas where we do business.

Compliance with this Policy is incorporated into our contracts and business arrangements with vendors and business partners. We reserve the right pursuant to our Vendor Code of Conduct to monitor, through an auditing process, adherence to this Policy by our vendors in an effort to (1) enforce wage, age and labor laws; (2) promote health and safety standards; and (3) help prevent negative environmental impact in the communities we serve. It is important that we proactively monitor human rights issues affecting our vendors and business partners, as their conduct reflects on our reputation with customers and the communities where we operate.

Commitment to Value the Human Rights of Our Employees

As an employer, Consolidated strives to be respectful and supportive of our workforce and to embrace a respectful and diverse culture. Consolidated recognizes that its employees are the lifeblood of the Company, and that we must respect the fundamental human rights of our employees and provide an inclusive work environment, free from any forms of harassment, discrimination or coercion. We periodically monitor and survey employee satisfaction and engagement to ensure that we receive the feedback we need to maintain this commitment. The following principals are reflective of our commitment to human and labor rights:

Non-Discrimination

Consolidated respects our employees’ human rights and does not tolerate discrimination on the basis of race, color, religion, sex, age, national origin, disability or any other factor prohibited by law.

Child Labor

We abide by all applicable child labor laws, and adhere to the Convention on the Rights of the Child of the United Nations and Convention 138 of the International Labor Organization. We do not use or recruit underage children for labor. If we are made aware of an occurrence of illegal child labor among any of our vendors, that vendor must immediately cease such activities. We do not place younger workers in hazardous conditions or require them to engage in dangerous work.

Forced Labor

Any and all employment undertaken at Consolidated or any of Consolidated’s vendors must be voluntary. The use of force or intimidation of any form to compel work, or as punishment, is strictly prohibited.

Freedom of Association and Collective Bargaining

We maintain a healthy dialogue with our employees and where applicable, their labor representatives. Consistent with applicable labor organization laws, employees are not restricted from membership in labor organizations. Recognized organizations may partake in collective bargaining on behalf of employees and employee labor representatives shall not be punished or favored based on their representative status.

Health and Safety

Maintaining a high standard of health and safety is key to the operation of our business. We take great lengths to ensure a safe and healthy environment for our employees and to avoid the possibility of injuries to customers or the public. We know that workplace injuries and incidents are often preventable and we strive to eliminate them by training and educating our employees and establishing common sense standards to avoid putting workers at risk. We comply with Occupational Safety and Health Act (OSHA) rules and other applicable labor regulations and guidelines and require our vendors and suppliers to do the same. We promote a healthy lifestyle off-the-job, including incentivizing fitness and exercise through our Company Wellness Program.

Working Conditions and Work Hours

All employees are given reasonable rest breaks, access to facilities, potable water, and holiday leave in accordance with applicable law. Consolidated complies with all applicable wage, hour, overtime and benefits laws.

Fair Wages and Compensation

We pay our employees a fair wage at levels sufficient to satisfy their basic needs and those of their direct dependents. At the very least, we require vendors to pay the minimum wage required by local law and provide all legally required benefits. Employees shall be compensated for overtime hours at legally required rates, and in those jurisdictions where such laws do not apply, at a rate at least equal to their regular hourly compensation rate.

Harassment and Employee Treatment

We do not implement or condone threats, violence or any other type of mental, verbal or physical coercion. Likewise, we do not engage in or allow any harassment or abuse to or from our employees, or the employees of the vendors with which we do business. We construe harassment broadly to mean any conduct that embarrasses, humiliates, or insults an employee, along with any type of intimidation. Our employees are treated with dignity and provided a work environment free of violent behavior and any form of harassment. Finally, we take measures to respect the privacy rights of our employees and ensure that an employee’s private information is protected, as required by law.

 

HUMAN RIGHTS AREAS OF FOCUS

Bridging the Rural Digital Divide

The United States has a rural telecommunications problem, most notably with respect to access to high speed internet services in rural communities. Modern business, and our world in general, is deeply intertwined with the use of the internet, so much so that reliable and proficient internet service is now akin to other utilities for which universal access is available, such as telephone and electric. With this reality in mind, Consolidated has invested in and is committed to expanding high speed internet access to communities that have been historically unserved or underserved.

Freedom of Expression and Privacy

As a telecommunications service provider, we promote the right of our users to hold and freely share ideas and opinions, without causing harm to others. We also respect our users’ rights to privacy by protecting our customers’ personal information and notifying them of the types of information we collect, how and with whom it may be shared, how it may be used and how it will be protected. At the same time, we cooperate with governmental agencies and law enforcement in response to lawfully authorized government requests to produce information.

Indigenous and Tribal Communities

In our attempts to provide telecommunications services to historically unserved or underserved areas, we know that we must observe a proper level of respect for the culture, traditions and land rights of Tribal Communities, and promote the protection of cultural heritage sites, consistent with ILO Convention No. 169.