Purpose
This Anti-Slavery and Human Trafficking Statement (the Statement) is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and is published on behalf of (i) Conrad Energy Group Limited and its subsidiaries; and (ii) Conrad Energy Group II Limited and its subsidiaries (together, the Companies), each having a consolidated turnover in excess of £36 million. References in this Statement to “we”, “us” or “our” are to the Companies.
This is our Statement for the financial year ended 31 March 2026. This Statement sets out the key steps taken by us to ensure that slavery and human trafficking do not occur in our supply chains or any part of our business.
It continues to be a priority for us to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking. We acknowledge our responsibilities under the Act and are fully committed to identifying, preventing and addressing modern slavery and human trafficking risks across our operations.
Our business
Conrad Energy is a leading energy provider and Independent Power Producer, delivering energy to the grid and business customers. We power change through fast, flexible energy supply to the grid when renewables can’t meet demand. Our vision is for a cleaner, greener, more efficient energy future and our mission is to play a key part in the UK’s energy transition.
We also work with businesses and landowners to generate, store, supply and buy energy – reducing costs, creating revenue and increasing efficiency. We operate 83 UK sites, operational or in construction, and have a potential to generate 983MW from a variety of technologies.
We comply with applicable legislation relating to employee terms and conditions and health and safety, and none of our staff earns less than the living wage. We are not aware of any incidents of modern slavery in our business or supply chains to date.
Our supply chains
Modern slavery risks are considered as part of our wider Environmental, Social and Governance (ESG) and supply chain risk management framework. We recognise that modern slavery is a crime and a fundamental violation of human rights. We continue to be committed to ensuring that there is transparency in our business and in our approach to tackling modern slavery risks throughout our supply chains.
While we are not aware of any incidents of modern slavery having occurred in our business, we recognise that the absence of identified incidents does not eliminate the risk of modern slavery occurring. We continue to review and improve our internal processes to ensure we have appropriate systems in place to mitigate the risks of modern slavery and human trafficking, including:
- risk assessing any new high spend suppliers;
- monitoring and reviewing risks in our existing supply chains by re-assessing existing suppliers on a rolling basis;
- protecting whistleblowers; and
- conducting analysis across our organisation to ensure supplier assessments are applied consistently, comprehensively and to a high standard, both pre- and post-engagement.
We expect all our suppliers to always act ethically and with integrity, sharing our commitment to humane and safe working practices. We only engage with suppliers who uphold the values to which we adhere
Policies, procedures and compliance
We aim to demonstrate our commitment to operating fairly, honestly and in compliance with all applicable legislative, regulatory and ethical requirements. We are committed to fostering a culture in which integrity and responsible and ethical values are at the core of our business and our decision-making process. Any abuse of human rights, either within our business or by anyone employed by or associated with us, will not be tolerated.
We have appropriate policies in place that underpin our commitment to ensuring that there is no modern slavery or human trafficking within our supply chains or in any part of our business. In particular, our anti-slavery and human trafficking policy details our zero-tolerance approach and expectations of the people working with or for us. We review this policy annually and update it as required.
We also have and regularly review the following:
- employment policies which protect our people;
- a procurement policy; and
- a whistleblowing policy. To date, we have not received any whistleblowing reports relating to modern slavery or human trafficking in our operations or supply chain.
To date, we have not received any whistleblowing reports relating to modern slavery or human trafficking in our operations or supply chain.
Contractual controls and due diligence
We monitor and reduce the risks of slavery and human trafficking occurring by taking a risk-based approach to due diligence with our critical suppliers. Our due diligence is designed to establish and assess any areas which present a risk and monitor those risks on an ongoing basis. We continue to work on improving our due diligence processes and, where deemed appropriate, expert external providers may be engaged to support us.
While many of the suppliers we work with are based in low-risk sectors and countries which are classified as “free” on the Freedom House list, we acknowledge that this does not make our business and supply chain immune to the risks of slavery and human trafficking. We remain vigilant and continue to work with key suppliers to monitor and mitigate risks.
Our supplier contracts include, where relevant to the nature and risk profile of the supplier relationship, provisions requiring compliance with applicable anti-slavery laws and to enable us to take appropriate action where material modern slavery concerns are identified.
Training and awareness
All new employees who join our business are made aware of our commitment to ensuring our business is free of slavery and human trafficking. We provide risk-based training to employees where relevant to their roles and responsibilities. We undertake refresher training with our staff in circumstances where there has been a substantial change in the Act.
Our policies (including our anti-slavery and human trafficking policy) are made available to all our employees on an on-going basis.
Measuring performance and future commitments
We recognise the importance of assessing the effectiveness of our efforts to prevent and mitigate modern slavery risks within our business and supply chains. During the reporting period, we have continued to review the effectiveness of our modern slavery procedures through our annual policy review. However, we have decided it is still not yet appropriate to adopt any specific modern slavery performance indicators.
Going forward, we will continue to review our processes against evolving legal requirements, government guidance and industry best practice. We will also assess opportunities to enhance our modern slavery compliance processes as part of our broader ESG programme.
Where concerns are identified, we will investigate promptly and take proportionate action, which may include enhanced supplier engagement, corrective action plans, suspension of new work and, where appropriate, termination of supplier relationships and engagement with relevant authorities.
Board approval
Responsibility for overseeing the Companies’ approach to modern slavery rests with the Board of Directors, supported by the senior leadership teams and relevant functional leads.
This Statement for the financial year ended 31 March 2026 has been approved by the Board of Directors for each of Conrad Energy Group Limited and Conrad Energy Group II Limited.
Tony O’Carroll (Chief Executive Officer)
Date: 16 September 2026