ESB Energy Limited (the "Company")
Statement on the Prevention of Slavery and Human Trafficking – 2020
The Company has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery
is not taking place anywhere in its own business or in any of its supply chains.
The Company is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains
and expects the same standards from all its contractors, suppliers and other business partners.
In August 2021, the board of the Company approved its first statement on the prevention of slavery and human trafficking as required by the
turnover provisions in the UK Modern Slavery Act 2015 (‘the Act’). This statement and sets out the steps taken by the Company during 2020 to prevent slavery and human trafficking in its business and supply chains.
is made pursuant to section 54 of the Act and constitutes the Company’s statement for its financial year ended 31 December 2020.
ESB’S BUSINESS AND SUPPLY CHAIN
The Company is part of the ESB group of companies. ESB is a vertically integrated utility whose business activities include the generation, transmission and distribution and supply of electricity in Ireland and the United Kingdom. Further details
of ESB business operations can be found at www.esb.ie.
The Company seeks at all times to comply with employment law applicable to it and puts in place contractual arrangements with providers of agency staff requiring that they achieve the same level of compliance.
The Company has during 2020 taken the following steps to prevent acts of modern slavery from occurring within its supply chains:
- A Contract Notice was published, by ESB on behalf of all group companies, in the Official Journal of the European Union in Q1 2020 seeking expressions of interest from suitably qualified and experienced 3rd parties to enter in a framework agreement
with the ESB Group to:
a) Undertake an insights-based risk assessment of the potential for modern slavery in ESB’s supply chain, and
b) As a separate lot to conduct on-site audits of any high-risk suppliers identified, as a consequence
of the above risk assessment.
- A Request for Tender for these services consequently issued to a number of short-listed applicants in Q.4 2020 and the corresponding framework agreement is expected to be awarded in Q.3 2021. The issue of this Request for Tender was unavoidably delayed
as a consequence of the impact of COVID-19 on available resources within Procurement to prepare supporting specification for this RFT. This framework agreement when awarded will build on the in-house risk assessments conducted by ESB Procurement
in 2017, 2018 and 2019 (when ESB’s vendors with a cumulative annual spend of > €250k were assessed for the risk of modern slavery in their supply chains based on their industry sector and geographical location)
- During 2020 we also instructed our current 3rd party auditor BSI (British Standards Institute) to undertake three on-site supplier audits. These audits took place in Vietnam, Sri Lanka and Brazil during the period February 2020 and early March 2020,
and no incidents of modern slavery or forced labour were found
- We also ensured that all tenderers and suppliers were aware of and signed-up to the ESB Group’s 3rd Party Requirements Document, which sets clear contractual obligations in relation to ESB’s zero tolerance-based approach to Modern Slavery
in our Supply Chains, and
- Finally we continued to provide bespoke training on the risks and impacts of Modern Slavery to ESB Procurement Staff.
The specific work outlined above is complemented by a broader reinforcement of ethical business practices across the wider group through the introduction of an updated version of ESB’s “Our Code”. This document provides clear guidance
to all employees (including subsidiaries) on any ethical issues they may encounter when carrying out their work, including how to report any suspected wrongdoing. Contracting parties supplying services to the Company are also expected to conduct themselves
in accordance with the principles of this Code. Further information about Group’s ethical business practices can be found by accessing the following link https://esb.ie/who-we-are/corporate-governance/esb-code-of-ethics---our-code
During the course of 2021, ESB plans to develop a Group Human Rights Policy, which when adopted will apply to all subsidiaries. This policy will reinforce the practices set out in “Our Code” and link the group’s range of policies on
human rights including: Health and Safety Policy, Environment and Sustainability Policy, Cultural Diversity Policy, Equal Opportunities and Diversity Code of Practice, Anti-Bribery Policy, Corruption & Fraud Policy, Whistleblowing & Protected
Disclosures Policy and Modern Slavery Policy.
The Company has also adopted ESB’s Policy on Modern Slavery (available at www.esb.ie) in and this is in the course of being communicated to all employees. This policy sets out the actions that the Company will take
to ensure the prevention of modern slavery, the roles and responsibilities from Board level down to each individual employee and the means by which any suspected incidences of modern slavery should be reported. Employees are encouraged to report any
suspected wrongdoing, and ESB’s Group Policies set out the protections for employees in reporting serious malpractice at work.
In order to understand how effective these controls are to ensure that modern slavery does not exist within our supply chain, external audits are conducted, where appropriate, on the activities of suppliers considered to operate in high risk regions or
industries. No incidents of modern slavery were found during the course of these audits.
The specific work outlined above will be complemented by a further programme of work for 2021, including the outsourcing of ESB’s internal risk assessment process to a suitably qualified third party.
The publication of this Statement was delayed due to administrative delays resulting from the Covid-19 pandemic.
This statement was approved by the Board of Directors of the Company on 11th August 2021.
ESB Energy Limited.