Modern slavery

Modern Slavery Act 2015 

enfinium Group Limited Slavery and Human Trafficking Statement 2023


enfinium  Group Limited (enfinium) 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.  

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.

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 partially renewable electricity.  enfinium  is owned by infrastructure funds managed by Igneo Infrastructure Partners.  

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 electric generating capacity of 247MW (gross).  enfinium  has approximately 275 employees in the UK and engages with suppliers in the UK and overseas. enfinium’s procurement team 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. 

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;  
  • enfinium is halfway through construction on 2 new energy from waste facilities at Kelvin, West Bromwich and Skelton Grange, Yorkshire. Our assessment is that these activities can potentially present a higher risk in relation to modern slavery and human trafficking compared to our operational business and we are taking the necessary steps to reduce this risk as set out below;
  • enfinium revised its standard terms and conditions with suppliers. Our revised conditions oblige suppliers to comply with the Modern Slavery Act, as well as enfinium’s policies relating to modern slavery;
  • 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; and
  • no incidents of modern slavery or human trafficking were reported across the enfinium business during 2022.

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 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.  

Managing construction activities

We are working closely with our construction EPC contractors to ensure their supply chains comply with our anti-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.

enfinium’s procurement team regularly meets with our construction EPC contractors to discuss their approach and governance of anti-slavery risk in their business and supply chains. We have audited their procurement compliance and their ESG Reports, which include both EPC contractors’ assessment of the risks in their supply chain. Our EPC contractors have satisfied enfinium that they monitor anti-slavery in their supply chains proactively and they have agreed to an open book approach whereby enfinium has the right to audit their procedures and performance every six months.

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 through our policy hub and internal communications.  

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.  

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: 

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

In 2022, we launched a new Learning Management System which enabled us to deliver Modern Slavery training and other compliance training online and to monitor more easily completion and refresh training on all required training modules.

In 2023, we will aim to improve our modern slavery assessment protocol for onboarding new suppliers. We will also look at becoming a member of an accredited body which will assist us in identifying potential areas of risk and measures to mitigate these risks in our supply chain.


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 2022.

Signed by

Mike Maudsley

Chief Executive Officer

on behalf of enfinium Group Limited

18 July 2023