Purpose
This 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) (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 2023 and it details the steps taken by us to ensure that slavery and human trafficking do not occur in our supply chains or any part of our business.
Our business
We are a full-service independent power producer (IPP) based in the United Kingdom. We develop, own and trade power generation and battery energy storage assets, supporting businesses and the National Grid.
Our diverse energy services business supports the delivery of fully funded and affordable power solutions to commercial and industrial customers using private wire and grid solutions. We also supply electricity, enter into power purchase agreements and provide market access through our trading desk. In an increasingly complex power market, our focus is optimising energy solutions for our customers, district network operators and the National Grid.
We comply with applicable legislation relating to employee terms and conditions, and none of our staff earns less than the living wage.
Our supply chains
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 throughout our supply chains.
Whilst we are not aware of any incidents of modern slavery within our supply chains or any part of our business to-date, we have continued to implement systems to:
- risk assess any new high spend suppliers;
- monitor and review potential increased risk in our existing supply chains;
- protect whistleblowers; and
- conduct analysis across our organisation to ensure consistency, comprehensiveness and quality in the manner and mode of supplier assessment both pre- and post-engagement.
We have continued to ensure that we only engage with suppliers who uphold the values to which we adhere. We expect all our suppliers to act ethically and with integrity at all times, sharing our commitment to humane and safe working practices.
Policies, procedures and compliance
We take our responsibilities seriously and aim to demonstrate our commitment to operating fairly, honestly and in compliance with all applicable legislative, regulatory and ethical requirements. We intend to foster 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 anyone employed by or associated with us, will not be tolerated.
We are committed to ensuring that our business operates ethically at every level and that our people and suppliers share and understand this commitment.
Our anti-slavery and human trafficking policy details this zero-tolerance approach to any form of slavery or human trafficking in our supply chain or within our business itself. We continuously review and update all our policies as required.
We also have the following policies in place relevant to modern slavery:
- Procurement Policy; and
- Whistleblowing Policy.
Contractual controls and due diligence
We monitor and reduce the risk of slavery and human trafficking occurring in our supply chain by undertaking a risk-based approach to due diligence with our suppliers. Our due diligence is designed to establish and assess any areas which present a risk of slavery and human trafficking and monitor such risks on an ongoing basis. Whilst 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 alone does not make our business and supply chain immune to the risks of slavery and human trafficking. We are continuing to work with our key suppliers to monitor the risk of slavery and human trafficking in our supply chain. We wish to ensure consistently high standards are applied when undertaking risk assessments and due diligence across our business and will continue to work on improving this process. Where deemed appropriate, expert external providers are engaged to support us in undertaking such diligence.
Training
All new employees who join our business are trained and made aware of our commitment to ensuring our business is free of slavery and human trafficking. We undertake refresher training with our staff in circumstances where there has been a substantial change in the Act. This financial year we noticed increased engagement through our training which brings us closer to our overall goal.
Our policies (including our anti-slavery and human trafficking policy) are made available on an on-going basis to all our employees.
Measuring performance
We have reviewed the effectiveness of the steps we have taken this year and decided it is still not yet appropriate to adopt any specific modern slavery performance indicators. However, we will continue to identify means of measuring our performance throughout the next financial year. Our objective in 2023 and beyond remains the same. Namely to continue to achieve increased engagement and communication across our business and with our suppliers.
We will continue to keep our supply chains under review to monitor and identify ongoing and future risks. We will draw upon best practice, regulatory requirements and industry guidance to help strengthen our measures to detect and prevent slavery and human trafficking.
Board approval
This Statement for the financial year ended 31 March 2023 has been approved by the Board of Directors for each of Conrad Energy Group Limited and Conrad Energy Group II Limited.
Steven Hardman (Chief Executive Officer)
Date: 27 September 2023