Modern Slavery Statement
Modern Slavery Statement for the Financial Year 2022
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 (the Act) and sets out the steps that AMP Clean Energy has taken and is continuing to take to ensure that modern slavery or human trafficking does not exist within our business operations or our supply chain. In this statement, references to we, us and AMP Clean Energy relate to Aggregated Micro Power Holdings Limited and each of its subsidiary companies.
AMP Clean Energy has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings. This includes putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Our business
AMP Clean Energy is a distributed energy company which funds and develops low carbon heat and power solutions including biomass heat installations and flexible generation energy plants. AMP Clean Energy also has a large presence in the fuels supply business and operation and maintenance of low carbon energy assets. AMP Clean Energy aims to source most of the materials associated with its operations from suppliers based in the UK and Europe and with whom we maintain a close working relationship.
AMP Clean Energy is committed to ensuring continuous improvement for our industry and supply chains alike; we undertake regular assessments and monitoring of our business operations to report and stop any form of forced labour or modern slavery whilst also gaining a greater understanding of our wider business risks. We do this twofold, first by implementing performance metrics to increase the standards of our supply chain and second by carrying out risk assessments on our strategic partners.
Our policies
We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner.
These include:
1. Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Code of business conduct. This code explains the way we behave as an organisation and how we expect our employees and suppliers to act.
Our suppliers
AMP Clean Energy continues to operate a supplier policy and maintains a preferred supplier list. We conduct due diligence on our supply chain to assess a range of technical and commercial risk areas. Such due diligence includes but is not limited to a detailed prequalification questionnaire; an online search relating to criminal convictions relating to modern slavery; and on-site audits which include a review of working conditions in instances identified as being at higher risk.
We rigorously adhere to our Supplier’s Code of Conduct which requires that all suppliers have in place methods along their own supply chains to demonstrate that any forms of forced labour or modern slavery are prevented. Equally, all suppliers should have adequate systems in place to ensure that any instances of forced labour or modern slavery are reported and stopped immediately.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business.
- They hold their own suppliers to account over modern slavery.
- (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate).
- (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
- We may terminate any contract at any time should any instances of modern slavery come to light.
Due to the controls placed on our own business and supply chain, we consider the risk of modern slavery to be very low.
Training
Greater focus has been placed on training for all AMP Clean Energy employees over the past year. We regularly conduct training for our procurement/buying teams so that they understand the signs of exploitation.
To further assist with our goal of improving employee understanding surrounding ethical and possible slavery situations we have implemented a new online training platform.
Throughout the upcoming year, AMP Clean Energy will be rolling out this eLearning platform to help bring our Business and Ways of Working policies to life by ensuring that we are working to the same consistently high ethical standards.
Our performance indicators
Ongoing compliance with the Act is monitored by the senior management team across each of the business divisions. The following are used to monitor the effectiveness of our policy in ensuring modern slavery and human trafficking is not taking place in our business or supply chains:
- Number of reports received from employees.
- Number of approaches from the public.
- Continuing development and strengthening of the supply chain by auditing and verifying our counterparties and processes used by them.
- Reports by law enforcement agencies to indicate that modern slavery practices have been identified.
- Employee engagement in our eLearning platform, specifically centred around Business and Ways of Working Policies to identify and mitigate modern slavery risks.
Board approval
This statement is made pursuant to s54(1) of the Act and constitutes AMP Clean Energy’s modern slavery and human trafficking statement for the financial year ending 31 March 2022. This statement has been approved by our Board of Directors and via our appropriate governance structure on 12 May 2022.
Mark Tarry
Chief Executive Officer
22 November 2022
