Modern slavery statement

Modern Slavery Act 2015 

enfinium Slavery and Human Trafficking Statement 2021


enfinium  (Enfinium Limited) is committed to improving our understanding of, and our practices to combat, slavery and human trafficking.  

This statement outlines the actions we have taken and continue to ensure that our business and our supply chain are slavery free.  

In this statement “enfinium” refers to  Enfinium Limited and its subsidiaries, each of which has separately recognised and adopted this statement.  

Organisation structure and business 

enfinium  is the fourth largest UK energy from waste business and is an industry leader in the conversion of everyday residential and commercial waste into renewable electricity.  enfinium  is owned by the European Diversified Infrastructure Fund III, an infrastructure fund managed by First  Sentier  Investors.  

enfinium  has 4  energy  from waste facilities in the UK. These sites represent a total annual waste processing capacity of over 2.3 million tonnes with a total combined electric generating capacity of 247 MW (gross).  enfinium  has approximately 214 employees in the UK and engages with suppliers and customers worldwide. 

Risk assessment 

Since the date of enfinium’s last Slavery and Human Trafficking Statement: 

  •  enfinium  continues to monitor compliance with our anti-slavery policy across the business;  
  • with the transition from construction activities to steady state operations at two of our facilities, we have a lower number of migrant workers across our business and therefore there has been a reduced risk of a breach of our anti-slavery policy; and 
  • enfinium  carries out due diligence on all new suppliers, including the risk of goods or services being provided from countries deemed to have a high risk of modern slavery according to the Global Slavery Index.

Procurement and supply chain 

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 the goods and/or services to 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.  

Our policies on slavery and human trafficking  

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  anti-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 and must confirm that they have read and understood its content.  

enfinium  also has a whistleblowing policy so that all employees are able to raise concerns about practices within our business or supply chain without fear of reprisals.  


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 senior managers, site based staff and supply chain management staff.  This training includes: 

  • Introduction to modern slavery; 
  • Definitions of modern slavery; and 
  • What to do if they spot signs of modern slavery in the UK or abroad.  


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 2019.  

Due to the impact of the Covid-19 pandemic, this statement is delivered in accordance with UK Government guidance (Guidance: Modern slavery reporting during the coronavirus (COVID-19) pandemic (20 April 2020))  more than six months following  enfinium’s financial year end.  

Signed by

Mike Maudsley

A Director of  enfinium Limited

January 2022