Modern Slavery Act Transparency Statement 2017
Melton Renewable Energy UK Plc
Statement issued in accordance with the Modern Slavery Act 2015 (“the Act”) in relation to the period 1 July 2016 to 30 June 2017 (“the Statement Period”).
Introduction from the Chief Executive Officer
We remain committed to improving our practices to combat slavery and human trafficking, with a view to ultimately achieving the best possible practices in this regard.
We are the parent company of the Melton Renewable Energy UK PLC group (the Group). The Group is a renewable power generator operating from a number of sites in England, Wales and Scotland. The Group has around 250 employees.
The Group had an annual turnover of £116m in the Statement Period, all of which was generated from within the United Kingdom.
Our business comprises:
The Energy Power Resources group, which owns and operates five biomass power stations in England and Scotland, the Fibrophos fertiliser business and a 50% share of two windfarms in England; and
The CLP Envirogas group, which owns and operates generation assets at 24 landfill sites across England, Wales and Scotland.
Our supply chains
Aside from services provided to the Group by regulated advisors, which services we consider to be low risk in the present context, our supply chains include:
Biomass fuel suppliers: we have a large number of contracts in place which provide for the sale and purchase of biomass products (including poultry litter, waste wood, straw and meat and bone meal) for use as fuel in our power stations, and the collection and delivery thereof.
Landfill operators: the landfill sites from which we operate are owned and/or managed by either local councils or private waste management companies.Our activities and these relationships are governed by gas supply agreements.
Engineering and construction contractors: each of our sites is subject to planned and unplanned maintenance, repairs, and modifications which require us to engage a number of engineering and construction contractors on a regular basis.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy (see link below) reflects our commitment to acting ethically and with integrity in all 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.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have raised this as a particular issue with relevant members of the management team (including in particular commercial, procurement, and fuel supply departments). We have carefully considered our various supply chains and identified particular areas of risk, it being noted that our fuel supply involves food production, agriculture and transportation all of which have been identified as industry sectors presenting a potentially higher risk.
We have in place systems to:
Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Encourage vigilance as to potential risk areas in our supply chains.
Encourage whistle-blowing and protect whistle blowers.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure those in our supply chains as well as our contractors comply with our values, we have put in place a supply chain compliance programme.
This has involved writing to all existing suppliers and contractors requiring certain amendments be made to relevant contracts. Each such contract variation includes the addition of a positive obligation requiring compliance by the supplier or contractor with our Anti-Slavery and Human Trafficking Policy (or, in certain cases, with the Act) and provides that an entitlement to terminate shall arise in our favour if the supplier or contractor is found to be in breach of the Policy (or the Act, as the case may be).
In addition, all of our standard form template contracts have been updated in line with the variation referred to above.
Ongoing compliance with the Act is monitored by the senior management team and in particular by key representatives from the following departments:
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 provided training to such of our staff members as are likely to be affected by the Act and its requirements.
Further steps taken in the Statement Period
In addition to the above, during the Statement Period we have taken the following steps to further combat slavery and human trafficking:
Following up on any outstanding responses from contractors and suppliers to our initial letters.
Rolling out an updated contractor induction programme at all sites to both existing and new contractors. This programme makes specific reference to the Act, gives a brief explanation of what the Act is designed to combat and asks all contractors to raise any relevant concerns with their contact in the Group or confidentially via our dedicated external whistle-blowing hotline.
Contractors and suppliers have been asked to provide an annual statement confirming that no slavery or human trafficking has taking place in their business or supply chains in the Statement Period.
Further steps to be taken
During the 12 month period to 30 June 2018 we shall follow up on any outstanding annual statements from contractors and suppliers, as referred to above, and will continue to monitor compliance with the Act more generally.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the period ended 30 June 2017.
Director E J Wilkinson
Melton Renewable Energy UK PLC
Date: 19th September 2017
Board approval obtained on 18th September 2017