Modern Slavery Policy

This is the Modern Slavery and Human Trafficking policy for eEnergy PLC.

 

Statement

At eEnergy we believe we should always act ethically and we value integrity and transparency in
all our business dealings. Being responsible is one of our core values, and these values, together
with our mission to accelerate the transition to a sustainable Greener future, form the basis for
how we behave and the decisions we make across the Group.

We are committed to ensuring that our business, its direct supply chain and business
partnerships are free of modern slavery and human trafficking and will not hesitate to perform
due diligence if necessary.

Any evidence or suspicion of the above occurring in any contact organisation or contact
individual or group of individuals will immediately result in us submitting a report to the relevant
authorities and suspending any interaction between ourselves and the party concerned until a
satisfactory outcome has been reached.

We acknowledge our responsibilities in relation to tackling modern slavery and human trafficking
and are committed to complying with the provisions of the Modern Slavery Act 2015, although
we are not required to report under s54 of the Modern Slavery Act 2015.

Definition of Modern Slavery

We consider that Modern Slavery encompasses:

  • Human trafficking.
  • Forced work through mental or physical threat.
  • Being owned or controlled by an employer through mental or physical abuse or the threat
    of abuse.
  • Being dehumanised, treated as a commodity or being bought or sold as property.
  • Being physically constrained or having restrictions placed upon freedom of movement.

Our policy
We will not support or be involved in Modern Slavery nor enter into a business relationship with
any party which knowingly supports or is found to have involved itself in any aspect of Modern
Slavery.

Our expectations of employees, business partners & suppliers
We expect all employees, agents, contractors, subcontractors, consultants, business partners,
suppliers and any other parties (including individuals, partnerships and bodies corporate)
associated with us or any of our subsidiaries (together “eEnergy Associates”) also to have zero
tolerance towards Modern Slavery.
We provide training to our staff to help them identify the indicators of Modern Slavery in our
business dealings.

 Due diligence process
The geographical scope of our operations is primarily limited to the UK & Ireland and the nature
of our work makes modern slavery or human trafficking an unlikely event.
However, we ensure that modern slavery is not taking place in our organisation by taking the
following steps:

  • We directly employ our staff.
  • We conduct ‘right to work diligence’.
  • Where we operate outside of these the UK and Ireland and we directly employ our staff
  • We comply with all local laws.
  • Where possible we build long-standing relationships with local suppliers and we validate
    that these entities have suitable Modern Slavery policies in place.
  • We encourage the reporting of any concerns by our staff and Associates.
  • We reserve the right to request access to the Modern Slavery policies of all eEnergy Associates
    and will from time to time conduct specific due diligence on the application of their policies.

Reporting Concerns & Reviewing
All eEnergy Associates must report any and all concerns relating to modern slavery to Group HR
or, in the case of non-employees, their normal point of contact within the Company. Our
Company’s Whistleblowing Protection Policy is designed to encourage the open and transparent
reporting of any concerns identified by an eEnergy Associate in any area of our business,
including Modern Slavery.

Approved by:
RM Williams, Director
25th February 2022
Next review:
31st December 2022 (or in the event of an incident, if earlier)