modern slavery POLICY
ISLAND GREEN POWER LIMITED: GLOBAL ANTI – SLAVERY AND HUMAN TRAFFICKING POLICY
Policy
1.1 Slavery is an international problem that is estimated to affect aver 40 million adults and children around the world. It is a serious and often hidden crime in which people are exploited for criminal gain. The impact can be devastating for the victims.
1.2 Island Green Power Limited has a zero-tolerance approach to slavery and human trafficking inits supply chain as well as in its own operations. It is our Policy to conduct all our business with honesty, integrity and transparency. We are committed to acting professionally, ethically and fairly in all our business dealings and relationships wherever we operate; and to implementing and enforcing effective processes to identify and prevent slavery and human trafficking in our supply chain.
1.3 Island Green Power Limited takes our obligations in relation to the prevention, detection and reporting of slavery and human trafficking extremely seriously. We apply due diligence procedures, taking an appropriate and risk-based approach, in respect of our own business and in our supply chain, in order to mitigate identified risks.
SCOPE AND APPLICATION
In this policy, the “Company” refers to Island Green Power Ltd. Island Green Power Limited is a Bermuda registered business with its head office in London. It is part of a group with offices in the UK, Spain and Bermuda.
2.2 The Company operates in the energy industry and is specifically involved in electricity generation and solar battery storage development. Our team sits across UK and Spain managing the development of projects. This includes speaking with landowners and land agents and reviewing land suitability and dealing with grid connections. We also liaise with external planning advisors, respond to planning objections and instruct technical experts where necessary.
2.3 Island Green Power Limited employs staff who work mainly in the UK and Spain. Many of those employees are highly skilled in the energy sector. We also employ legal and finance professionals.
2.4 The policy applies to:
- all the Company’s divisions, subsidiaries affiliates and project companies, including joint ventures controlled by Island Green Power Ltd or any of its affiliates; and
- all Company directors, employees, contractors, trainees, agency staff, volunteers, sponsors, agents and consultants (“Company personnel”) or other person performing services for us or on our behalf, wherever located.
2.5 Companies and joint ventures in which Island Green Power Limited does not have a controlling interest should be provided with a copy of and act consistently with this policy.
2.6 This policy should be followed in conjunction with other policies and procedures of theCompany. This includes but is not limited to the whistleblowing policy, anti-bribery and corruption policy and policy relating to failing to prevent facilitation of tax evasion under theCriminal Finances Act.
PURPOSE
3.1 The purpose of this policy is to:
- Outline the law regarding modern slavery and how it is relevant to Island Green PowerLimited;
- Establish our roles and responsibilities, in observing and upholding our position on preventing modern slavery and human trafficking in the supply chain;
- Identify the procedures created to reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
- Provide information and guidance on how to recognise indicators that could be a sign of modern slavery and or human trafficking.
RESPONSIBILITY FOR THIS POLICY
4.1 The Directors of Island Green Power Limited are fully committed to implementing the Policy and ensuring that the Company's business relationships are conducted in accordance with its terms.
4.2 Chandni Ruparelia, Head of Legal will review and oversee the operation of the Policy and report to the directors to ensure that the Policy is effective in addressing the risk of slavery and human trafficking in the supply chain.
POSSIBLE SIGNS OF SLAVERY AND HUMAN TRAFFICKING
5.1 The term modern slavery is an umbrella term which designates a situation of exploitation of a person who cannot refuse or leave work because of violence, coercion, abuse, threats or deception. Slavery includes forced labour, debt bondage, servitude and recruitment using deception for labour or services (see explanation of these terms in Appendix 1). Island GreenPower Limited is committed to preventing slavery and human trafficking in its supply chain as well as in its own operations.
5.2 The following is a list of possible indicators of modern slavery and human trafficking. This is not intended to be an exhaustive list.
- Workers may not have free movement and may always be accompanied. They may also appear fearful of those that accompany them.
- A worker may not have access to their own identity documents. They may be in the possession of the employer and the worker denied access to them. There may also be other signs that workers movements are being restricted.
- Workers may not have a contract of employment and may not receive pay slips outlining their income and tax paid.
- Workers may be living in poor quality accommodation, provided by the employer.They may live in groups and accommodation may be overcrowded. The 3accommodation may be on site or nearby.
- Workers may be transported to and from work in groups.
- Individuals may work long hours, without time off and in working conditions with poor health & safety arrangements.
- Individuals may appear malnourished or unkempt and have unsuitable clothing or equipment for the work that they are doing.
- Individuals may be injured or not have access to healthcare.
- Individuals may not speak the language of the country they are working in.
- Workers may appear anxious or fearful and reluctant to speak with outsiders.
5.3 If you encounter any of the above red flags during the course of your work, you must report them to Chandni Ruparelia, Head of Legal as soon as possible.
5.4 The Company has a whistleblowing policy and procedure in place to allow employees to, inter alia, report knowledge or suspicion of slavery or human trafficking which ensures that staff or members can raise their concerns confidentially without fear of reprisal. This policy should be read in conjunction with the whistleblowing policy.
TRANSPARENCY
6.1 Island Green Power Limited opposes modern slavery and human trafficking in all forms, wherever in the world it may occur. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.
6.2 The Company observes a robust recruitment process which is compliant with local employment legislation. We ensure that pre-employment checks, including right to work document checks are made and referencing during the recruitment process.
6.3 Island Green Power Limited expect the same high standards from all of our contractors, suppliers and other business partners. We seek assurances from suppliers that they are taking relevant steps to prevent modern slavery from occurring within their business and supply chain.
6.4 The Company takes a risk-based approach to identifying all suppliers and contractors, in addition to the locations in which they operate in order to establish where the risk of slavery and human trafficking is the greatest.
6.5 Island Green Power Limited will cease business relationships with any such persons who, in the reasonable opinion of the Board, fail to address modern slavery or human trafficking within the organisation.
CONSEQUENCES OF FAILURE TO COMPLY
7.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
7.2 We may terminate our relationship with individuals and organisations working on our behalf or within our supply network if they breach this policy.
REPORTING VIOLATIONS
8.1 You should raise concerns about issues relating to slavery or human trafficking in our business or in our supply chain, or any situation that you believe may violate this policy, at the earliest possible stage. Such concern should be reported to Chandni Ruparelia, Head of Legal as soon as possible.
8.2 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of actions taken to comply with this policy. Disciplinary measures will be taken against anyone engaging in such retaliation against a report made in good faith.
8.3 For your own safety, you should not approach or challenge individuals you believe may be involved in human trafficking or slavery. Instead, you should raise it with the Legal Team as soon as possible.
8.4 In all cases, the Company will protect the identity of the person making a report as much as possible, based on the need to prevent potential harm to others, to comply with the law and to conduct a complete investigation.
GUIDANCE AND TRAINING
9.1 Slavery and human trafficking legislation and practices are often complex and can be hidden away and difficult to spot. Appendix 1 provides more detail of common terms used and slavery practices as well as an explanation of the offences covered under the Modern Slavery Act. However, this policy can only provide guidance on the general requirements of these laws and you should consult Chandni Ruparelia, Head of Legal when more specific guidance is needed.
9.2 Island Green Power Limited will ensure that its policy on slavery and human trafficking is effectively disseminated and communicated throughout the organisation and it will continue to monitor and review its policy and procedures in order to ensure that its entire staff continues to comply.
9.3 This policy and related policies will form part of the mandatory training for all staff. Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy. Training will be delivered as part of the induction process for new joiners and further training will be provided annually or whenever there is a substantial change to the law or to our policy
IMPLEMENTATION, INTERPRETATION & AMENDMENT
10.1 The Legal Department has day to day responsibility for implementation, interpretation, monitoring, review and amendment of this policy.
10.2 The Legal Department will be responsible for ensuring that reviews of the supply chain are conducted in addition to an annual assessment of the risk of slavery and human trafficking in the company and within its supply chain. They will report to the Board annually on the steps taken to implement the policy and on its effectiveness. They will also report to the Board the effectiveness of the measures taken to identify and minimise the risk of slavery and human trafficking in the supply chain.
10.3 The Legal Department will also be responsible for the publication and review of a modern slavery and human trafficking statement under s 54 Modern Slavery Act 2015 at such time as there is a legal requirement to do so. (See Appendix 1 – Transparency in the supply chain).
CONCLUSION: YOUR RESPONSIBILITY
11.1 You must ensure that you read, understand and comply with this policy.
11.2 Detection and reporting of modern slavery and human trafficking are matters for which allIsland Green Power employees should take responsibility. The Company is committed to the high standards of conduct and all employees are required to take an active role in complying with this Policy.
11.3 You must contact the Legal Department for guidance if you are concerned or unclear about contractors, suppliers and other business partners commitment to taking steps to prevent modern slavery from occurring within their business and supply chain.
11.4 Never ignore rumours of poor working conditions or other “red flags” that raise suspicion of slavery or human trafficking. Any such information should be reported to the LegalDepartment.
11.5 Contact the Legal Department for guidance before entering into a transaction with a supplier, contractor or business partner that raises any doubt about compliance with this policy. For example, if you are unsure about whether the treatment of workers, or working conditions may constitute any form of slavery.
11.6 You must notify Chandni Ruparelia, Head of Legal, as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
11.7 You must comply fully with any investigation into slavery and human trafficking issues in our supply network or any breach of this policy.