At enfinium Group Limited (enfinium), we uphold the belief that modern slavery in any form, be it human trafficking, forced labour or child labour is a reprehensible violation of human rights and we are committed to improving our understanding of, and our practices to combat slavery and human trafficking.
This statement outlines the steps we have taken, and continue to take, to ensure that our business and our supply chain are slavery free.
For the purposes of this statement, “enfinium” refers to enfinium Group Limited and its subsidiaries, each of which has separately recognised and adopted this statement.
Enfinium, and all key support functions including procurement and human resources, adopt and implement the same policies, standards and procedures across enfinium and its subsidiaries.
enfinium is one of the largest UK energy-from-waste (“EfW“) businesses and is an industry leader in the conversion of residential and commercial waste into renewable electricity. enfinium is owned by Igneo Infrastructure Partners, a global infrastructure fund with its core management in the UK.
enfinium has 4 operational energy -from-waste facilities in the UK, with each facility being deeply involved in its own supply chain and operations, supported and overseen by corporate functions including procurement. These sites represent a total annual waste processing capacity of over 2.3 million tonnes, with a total combined electrical generating capacity of 247MW (gross). enfinium has approximately 337 employees in the UK and engages with customers across the UK, and suppliers in both the UK and overseas. enfinium is due to complete construction of a new EfW, with another one under construction, which is due to be operational in 2026.
enfinium’s Executive Committee and Audit and Risk Committee, comprised of senior individuals, regularly review the supply chain, both in the UK and internationally, including to ensure that suppliers are not from any sanctioned countries. Enfinium’s management are fully engaged in ensuring that the business is not involved in modern slavery and that proactive action, identification and mitigation strategies are in place to help ensure this, in line with our values of ‘Taking Ownership’ and ‘Making a Positive Impact’.
Since the date of enfinium’s last Slavery and Human Trafficking Statement in July 2024:
enfinium’s dedicated internal procurement and supply chain department plays a key role in the identification and management of slavery and human trafficking risk within the organisation who are responsible for the process of procuring goods and/or services for the enfinium facilities on a day-to-day basis and oversees all procurement across enfinium’s business. The consistency of personnel and approach allows a proactive and rigorous evaluation process for all new suppliers, requiring them to demonstrate compliance with all relevant legislation and codes of practice including, but not limited to, health and safety of employees and contractors, non-discrimination, bribery and corruption and modern slavery.
Compliance is also addressed in the enfinium standard terms and conditions which govern the majority of enfinium’s supplier contracts. These standard terms and conditions require our suppliers to comply with the requirements of the Modern Slavery Act 2015 and enfinium has the right to terminate a supply contract, often immediately, should a supplier be in breach of these requirements.
We are aware that construction activities and associated supply chains have a greater risk of modern slavery and human trafficking given global reach and operation. We work closely with our contractors to ensure the correct policies and standards are in place, and to ensure that their supply chains comply with our modern slavery policy to minimise the risk of any breach. In particular, we recognise that construction projects require significant numbers of personnel and have extensive supply chains, both in terms of goods and services. We must ensure that our contractors proactively manage their workforce and the workforce of their supply chain.
Our EPC contractors have satisfied enfinium that they monitor anti-slavery in their supply chains proactively, both of which have agreed to an open book approach whereby enfinium has the right to audit their procedures and performance every six months.
enfinium has a full suite of standards, policies and procedures to manage its day-to-day business, which are adhered to throughout the enfinium organisation and its supply chain.
enfinium’s modern slavery policy reflects our commitment to acting ethically and with integrity in all of our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. All employees are made aware of the policy through our policy hub and internal communications, and contractors and suppliers are made aware through contractual compliance requirements, and which require personnel to comply with our modern slavery policy. enfinium also provides training for both employees and non-employees.
enfinium also has a whistleblowing policy and external reporting helpline so that all employees, contractors and external concerned parties are able to raise concerns about practices within our business or supply chain without fear of reprisal.
Our Employee Assistance Programme also provides a confidential support service whereby employees can seek advice and information which covers a wide range of topics, including modern slavery and human trafficking.
In order to raise awareness of, and to ensure a high level of understanding of, the risks of modern slavery and human trafficking in our supply chains and our business, we have developed training for our managers, site-based staff and supply chain management staff.
This training includes:
Our Learning Management System delivers compulsory Modern Slavery training and other compliance training online; this enables monitoring of KPIs in terms of completion and refreshers. Our supplier code of conduct policy defines our standards and rules that we require suppliers and vendor partners to follow, including the expectation that all businesses in our supply chain share our commitment to respecting, protecting and promoting human rights, alongside freely chosen work, compliance with International Labour Organisation standards and that suppliers should develop/implement their own policies and procedures. This addresses all of our standards and expectations on labour conditions, modern slavery, sustainability, environmental standards, diversity and compliance. We also introduced updated supplier due diligence and a refreshed new supplier initiation form.
In 2025 we will aim to improve our modern slavery protocol for onboarding new suppliers, including provision of a supplier due diligence questionnaire to include Modern Slavery and human trafficking queries and audit rights. Whilst we are committed to evolving these steps will create a strong foundation for building long-term trust, whilst reinforcing our core organisational values.
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes the enfinium anti-slavery and human trafficking statement for the financial year ending 31st December 2024.
Signed by
Mike Maudsley
Chief Executive Officer
on behalf of enfinium Group Limited
6 August 2025
