Modern Slavery Statement

Modern Slavery and Human Trafficking Statement for the Financial Year 2024

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 (the Act) and sets out the steps that AMP 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 relate to Aggregated Micro Power Holdings Limited and each of its subsidiary companies.

AMP 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 by ensuring that there is no slavery or human trafficking in any part of our business or our supply chains. We have implemented systems and controls to safeguard against modern slavery taking place within the business or our supply chain which we continue to actively monitor and improve.

Our business

AMP is a distributed energy company which develops, funds and operates low carbon energy centres across the UK, including non-domestic biomass heat installations, flexible generation energy plants which include electricity generation and storage assets, and battery energy storage system projects within the UK. AMP also has a large biomass fuel supply business and operation and maintenance business that operates throughout the UK. AMP aims to source the bulk of the materials associated with its operations from suppliers based in the UK and Europe with whom we maintain a close working relationship.

AMP 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.

Our policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner. Our policies are regularly reviewed, and we encourage comments and engagement on these policies from all employees.

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. This policy reflects our commitment to acting ethically and with integrity in all our business relationships.

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.

Training and reporting

To ensure a high level of understanding of the risks of modern slavery and compliance with our policies, all AMP employees have now received training on modern slavery. This training is mandatory for all new joiners. Refresher training is scheduled and carried out as beneficial in the circumstances, for example, if there are changes to the Act or changes in staff roles. AMP has implemented clear lines of reporting across the business for reporting any concerns or risks around modern slavery.

Our suppliers

AMP operates a zero-tolerance attitude to modern slavery and trafficking and this includes with all our suppliers. 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; 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:

  1. They have taken steps to eradicate modern slavery within their business.
  2. They hold their own suppliers to account over modern slavery.
  3. (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate).
  4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
  5. We may terminate any contract at any time should any instances of modern slavery come to light.

We continue to keep our supply chains under constant review to monitor and identify ongoing and any future potential risks. We draw on best practice, regulatory requirements and industry guidance and knowledge to help assist in our detection measures to prevent human slavery and trafficking.

Due to the controls placed on our own business and supply chain, we consider the risk of modern slavery to be very low.

Board approval

The Board of Directors is responsible for the corporate responsibility of the AMP group, including issues such as slavery and human trafficking. The Board of Directors and its committees review the group’s approach and policies in this area to oversee and monitor the policies themselves, as well as procedure in place and to address any specific issues if they arise.

This statement is made pursuant to s54(1) of the Act and constitutes AMP’s modern slavery and human trafficking statement for the financial year ending 31 March 2023. This statement has been approved by our Board of Directors and via our appropriate governance structure on 08 May 2024.

Mark Tarry
Chief Executive Officer
May 2024