Anti-Slavery and Human Trafficking Policy

INTRODUCTION

We have reached the threshold requiring us to publish a statement in accordance with the UK Modern Slavery Act 2015 (the ‘Act’) and this will be published each year.  As ever we are mindful of risks associated with modern slavery, and work to mitigate against them. This policy sets out the steps that Zenobē are taking to manage the risk of modern slavery and human trafficking in our operations and supply chains.

Modern slavery takes various forms and is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. We have a zero-tolerance approach to modern slavery and human trafficking in our organisation and in our supply chains.

Zenobē fully supports the aims of the Act. We work actively to eradicate the risk that modern slavery and human trafficking might be present in our operations and supply chains. We implement, and will continue to implement, systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our organisation or in any of our supply chains. We expect that our contractors, suppliers and other business partners will hold their own contracting partners to the same standards.

Our anti-slavery and human trafficking policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, interns, seconded workers, volunteers, agents, contractors, and suppliers. This policy does not form part of any contract of employment or contract to provide services and we may amend it at any time subject to agreement with the board of directors.

ORGANISATIONAL STRUCTURE, SHAREHOLDERS AND SUPPLY CHAINS

We have secured investment from some of the world’s leading strategic investors in energy storage, including KKR, Infracapital and JERA Storage BV. These organisations have set up comprehensive, regularly-reviewed policies and processes to ensure that their supply chains are not linked to modern slavery and human trafficking.

MODERN SLAVERY AND HUMAN TRAFFICKING POLICIES

Policy for Zenobē’s Own Business: 

The prevention, detection and reporting of modern slavery in any part of our organisation is the responsibility of all those working for us. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy. Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Workers must notify their line manager or the legal team or a member of the board of directors (as they consider appropriate) or raise a concern in accordance with the Whistleblowing Policy as soon as possible if they believe or suspect that a breach of this policy has occurred, or may occur in the future. Workers are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, workers must contact the General Counsel.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered any such treatment, you should inform your line manager, a member of the HR department or the Head of Legal immediately. If the matter is not remedied, you should raise it formally using the Grievance Procedure.

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and annual training will also be provided.

Policy for Zenobē’s Suppliers:

We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our supply chains. All suppliers must comply with our anti-slavery and human trafficking policy and provide details of measures they have taken to ensure compliance.

We take a risk-based approach to our contracting processes, and we keep all contracts under constant review.  We include specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.

On an annual basis, we ask our suppliers to fill in an anti-modern slavery questionnaire. The questionnaire requires them to provide assurance and evidence that their supply chains are not implicated in modern slavery. It requests details about their internal policies and procedures on this matter, and how often these policies and procedures are updated. It also requests information about their relationships with direct and indirect suppliers, including but not limited to the identities and locations of such organisations; where they source raw materials and components from; how they monitor compliance with their internal anti-slavery and human trafficking policies; and who is responsible for monitoring and enforcing such policies.

Our suppliers are obliged to demonstrate that they are implementing measures, such as audits, to eradicate the possibility that their supply chains could be linked to modern slavery.

Consistent with our risk-based approach, we may require:

• employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our standards.
• suppliers engaging workers through a third party to obtain that third party’s agreement to comply with our standards.

We also assess the merits of writing to suppliers on an individual basis to check their compliance with standards required to combat modern slavery and trafficking. As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant auditing our suppliers to ascertain their level of compliance with our standards. If we find that individuals or organisations working on our behalf have breached these standards, we will take appropriate action, which may include termination of working relationships.

BREACHES OF THIS POLICY

Any employee who is found to have breached this policy will face disciplinary action in accordance with the Disciplinary Procedure, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy. 

RESPONSIBILITY FOR THE POLICY

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Chief Operating Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the General Counsel.

June 2024