At enfinium Group Limited (enfinium), we are committed to conducting our business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery and human trafficking in any form, be it human trafficking, forced labour or child labour. We are committed to:
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps we have taken, and continue to take, to ensure that our business and supply chains 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 a leading UK energy from waste operator with five operational sites in the UK, in West Yorkshire, Kent and Flintshire, and one in construction. enfinium diverts 2.7 million tonnes of unrecyclable waste from climate-damaging landfill, putting it to good use by turning it into home grown energy, enough to power 600,000 UK homes. enfinium’s ambition is to use existing energy from waste infrastructure to support green economic growth, through heat networks, private wires to industrial users, and carbon capture technology that creates durable, high-quality carbon removals critical for the UK to achieve net zero by 2050.
enfinium’s Executive Committee and Finance, Audit and Risk Committee, comprised of senior management and Board members, regularly review enfinium’s supply chain, both in the UK and internationally, including to ensure that suppliers are not from any sanctioned countries. enfinium’s management team is 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 enfinium’s core values of ‘Taking Ownership’ and ‘Making a Positive Impact’.
Since the date of enfinium’s last Modern Slavery and Human Trafficking Statement in August 2025:
enfinium’s procurement and supply chain department plays a key role in the identification and management of slavery and human trafficking risk within the organisation.
enfinium has a dedicated internal procurement and supply chain department that is responsible for the process of procuring goods and/or services for the enfinium facilities in order to fulfil its business model. This centralised team oversees all procurement across enfinium’s business and is responsible for sourcing all supplies required for the day-to-day running of the 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 suppliers, 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 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 any risk of 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 Contractor at Kelvin, and previously our EPC Contractor at Skelton Grange, have satisfied us that they proactively monitor anti-slavery in their supply chains. We have an agreement with our EPC Contractor at Kelvin whereby enfinium has the right to audit their procedures and performance on an open-book basis 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 must confirm that they have read and understood its content. Our contractors and suppliers are made aware through contractual compliance requirements, and which require personnel to comply with our modern slavery policy.
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 reprisals. If any concerns are raised they are directed to an enfinium Board member who liaises with management to investigate and, if appropriate, address such concerns.
Our Employee Assistance Programme also provides a confidential support service whereby employees can seek advice and information which covers a wider range of topics, including modern slavery and 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 provide training to 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 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 regularly review our supplier due diligence and new supplier initiation form.
We understand that modern slavery and human trafficking are ongoing issues and that we must be vigilant and pro-active in managing this risk at all times. In 2026 we will continue to regularly monitor and review our modern slavery protocol for onboarding new suppliers, ensure mandatory training on modern slavery and trafficking is undertaken by all employees, contractors and relevant third parties and review our Modern Slavery Policy as part of its annual review.
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 2025. This statement was approved by the Board of Directors of Enfinium on 13th October 2026.
Signed by
Mike Maudsley
Chief Executive Officer
on behalf of enfinium Group Limited
13th October 2026
