Introduction

While we have not reached a threshold requiring us to publish a statement in accordance with the UK Modern Slavery Act 2015 (the ‘Act’), we are mindful of risks associated with modern slavery, and we 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 is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. 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 suppliers will hold their own suppliers 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, seconded workers, volunteers, agents, contractors, and suppliers.

Organisational Structure, Shareholders, and Supply Chains

We have secured investment from some of the world’s leading strategic investors in energy storage, including 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 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 Head of Legal.

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.

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.

October 2022