Statement Concerning Modern Slavery Act (UK)

This statement is made on behalf of Cogent Communications Holdings, Inc. pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes our slavery and human trafficking statement.

Cogent Communications UK, Ltd. is a UK corporation registered with Commercial Registry under No.: HRB 73 632, with principal place of business located at 20 Mastmaker Court, Mastmaker Road, London, E14 9UB, UK and with VAT #: GB766151326. Cogent Communications UK, Ltd. is part of the Cogent group of companies operating in North America, Europe and Asia and is managed and ultimately owned by Cogent Communications Holdings, Inc.

Cogent Communications Holdings, Inc. is a Delaware corporation with registration number 5504601 and with its headquarters at 2450 N Street, N.W. Washington, DC, 20037. Cogent Communications Holdings, Inc. is a publicly traded corporation with its shares traded on NASDAQ Stock Exchange under symbol CCOI.

Cogent Communications Holdings, Inc. is a facilities-based provider of low-cost, high-speed Internet access and other communications services. We deliver our services primarily to small and medium-sized businesses, communications service providers and other bandwidth-intensive organizations in North America, Europe and Asia. Further information about Cogent Communications UK, Ltd. and Cogent Communications Holdings, Inc. can be found on our website

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains.

We are an internet service provider that predominantly employs professionally qualified and highly skilled people. We consider the risk of Modern Slavery occurring within our business to be low. We select suppliers that have the same values as us, including a commitment to the highest professional standards and ethical conduct in their business dealings.

All of our employees are required to comply with our internal policies, procedures and code of conduct. Every employee is expected to practice high standards of business ethics in every business relationship – with each other, with Cogent, with our customers, with our business partners, and with our competitors. Failure to comply with the law or our policies is subject to disciplinary measures and possible termination.

We have in place a policy and procedures for whistleblowing, which are posted on our Intranet and which ensure that employees can confidentially report concerns regarding our compliance with laws, ethical business practices or compliance with our codes of conduct.

Our third party supply chain consists mainly of equipment and services suppliers: suppliers of telecom equipment, suppliers of IT and technology services, office supplies, cleaning, catering facilities, professional services, fiber vendors and owners of buildings in which we operate, etc. We believe that our supply chain is, therefore, low risk as regards slavery and/or human trafficking. We have not identified an immediate need to take any additional action with regard to such relationships.

We review our procurement and supply chain management procedures regularly with a view to further reinforcing our commitment to the ethical conduct of our business.

We intend to raise more awareness internally of this Statement and in relation to modern slavery across all staff by publishing this statement internally on our intranet.

The Cogent Board of Directors approved this statement on behalf of the members on November 1, 2023.

/s/ David Schaeffer
Dave Schaeffer,
Chairman and Chief Executive Officer