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 actions 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 supply chain 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 everyday 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. 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 286 employees in the UK and engages with customers across the UK and with suppliers in the UK and overseas. For the avoidance of doubt, enfinium’s Executive Committee and Audit and Risk Committee regularly review the supply chain which exists outside of the UK to ensure that no suppliers fall within any sanctioned countries. enfinium also has 2 new projects under construction, which are due to be operational in 2025.
Since the date of enfinium’s last Slavery and Human Trafficking Statement:
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 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 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 should a supplier be in breach of these requirements.
We are working closely with our construction EPC contractors to ensure their supply chains comply with our modern slavery policy to minimise the risk of any breach. In particular, we recognise that these projects will require a large volume of labour at certain stages of the construction programme, and we must ensure that our contractors pro-actively 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 and they 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 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 through our policy hub and internal communications.
enfinium also has a whistleblowing policy and external reporting helpline so that all employees are able to raise concerns about practices within our business or supply chain without fear of reprisals.
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:
In 2022, we launched a new Learning Management System which enabled us to deliver compulsory Modern Slavery training and other compliance training online and to monitor more easily completion and refresh training on all required training modules.
In 2024, we will aim to improve our modern slavery assessment protocol for onboarding new suppliers. We will launch a supplier code of conduct policy that will define our standards and rules that we require our suppliers and vendor partners to follow. The code of conduct will address all of our expectations on labour conditions, modern slavery, sustainability, environmental standards, diversity and compliance. Our supplier code of conduct will communicate standards and expectations for vendors. While our relationship will evolve, the policy will create a strong foundation for building long-term trust, whilst reinforcing our core organisational values. This two-way approach will protect both organisations from third-party risk, our supplier code of conduct will establish parameters that protect our wider organisation from supply chain risks whilst enabling a great way to share our values while building a reputation for social responsibility.
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 2023.
Signed by
Mike Maudsley
Chief Executive Officer
on behalf of enfinium Group Limited
18 July 2024
