Modern slavery statement

Introduction

Power NI Energy Limited (“Power NI or “the Company”) fully supports the aims of the Modern Slavery Act 2015 (“the Act”) and is committed to tackling slavery and human trafficking where it can. This statement is made pursuant to section 54(1) of the Act and constitutes the Company’s slavery and human trafficking statement for the financial year ended 31 March 2024.

Power NI is committed to the highest level of ethical standards and sound governance arrangements and prohibits all forms of slavery and human trafficking in all its different forms in any part of its businesses and in its supply chain.

Organisational structure and supply chains

Power NI’s parent company is Energia Group NI Holdings Limited and is part of the Energia Group which includes Energia Group Limited and its subsidiary undertakings (“the Group”). Energia Group Limited is registered in the Cayman Islands. The Group is the leading independent energy company in Ireland and operates under three business units, Renewables, Flexible Generation and Customer Solutions. The Renewables business owns and operates renewable electricity generation assets as well as purchasing renewable electricity from third party generators throughout Ireland. The Flexible Generation business owns and operates conventional electricity generation assets in the RoI, a battery storage facility in Northern Ireland and an emergency gas generation plant in the RoI. The Customer Solutions business supplies electricity and gas to customers in the RoI and Northern Ireland.

The Company operates in Northern Ireland, supplying electricity to residential and commercial customers through its Power NI business and also purchases renewable electricity from fellow Group subsidiaries and third-party generators in Northern Ireland. The Company had 554 employees at 31 March 2024. Turnover for the year ended 31 March 2024 was £1,070.1m. The majority of the Company’s supply chain is sourced from within the UK and the RoI.

There have been no changes in the principal activities of the Company for the financial year ended 31 March 2024.

The Company Secretary is responsible for the management of modern slavery within the Company.

Relevant policies

We are committed to taking measures to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to mitigate modern slavery and human trafficking risk in our supply chains.

Some of the other Group policies which are considered relevant to the management of modern slavery risks faced by the Company include:

Code of Conduct – formalises the high standards of behaviour and performance expected from employees e.g. to comply with all lawful directions given by or under the authority of the employer and with all company rules, regulations, policies and procedures. Employees are also expected to give due consideration to the safety and welfare of others, including by complying with the provisions of legislation on health and safety and working conditions.
Equal Opportunities Policy – opposes all forms of unlawful discrimination and commits to the operation of fairness and equality at work and in the services provided to customers.
Recruitment and Selection Policy – commits that those involved in recruitment will comply with the principles of equality of opportunity and are appropriately trained in good recruitment practices.
Dignity at Work Policy – supports dignity at work for all employees, provides guidance for the resolution of issues and prevention of recurrence and underlines our commitment to equality and dignity at work for all to promote an environment free from bullying and harassment.
Grievance procedure – procedures which allows for an employee who has a concern, problem or complaint about some aspect of their work to raise a grievance.
Anti-corruption and Bribery Policy – which commits the Group to uphold all laws relevant to countering bribery and corruption in all jurisdictions in which it operates.
Whistleblowing – procedures to allow employees, in the event that they discover serious malpractice or wrongdoing, to voice concerns in a responsible and effective manner without fear of reprisal.

Sustainable development goals (“SDG”)

The Group has aligned its activities with the United Nations SDG 8 Decent Work and Economic Growth and reports on progress against this and other priority SDGs in its Responsible Business Report. Within SDG 8 there is a commitment to take measures to eradicate forced labour, end modern slavery and human trafficking.

Wellbeing initiatives

The Company is committed to ensuring its employees are well looked after, cared for and supported in all that they do. Wellness is a core part of ensuring the Company operates effectively. Our wellbeing programme is underpinned by 3 pillars: Mind, Body and Life and is available to all employees. Employees are encouraged to reach out to our dedicated professional counselling team for support should they wish to do so.

The Company recognises the importance of employee engagement and has a number of established mechanisms to support employee engagement through communication forums and employee groups.

The modern slavery and human trafficking risk

Our Modern Slavery Policy is key for the Company having 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; and
Monitor potential risk areas in our supply chains and consider emerging risks of suppliers located within higher risk countries.

We encourage the reporting of concerns by our employees to their line managers/heads of department. If they are unsure on whether to raise a concern they can contact our confidential advice line managed for us by Public Concern at Work to ensure independence. The public can raise concerns by contacting the Modern Slavery Helpline on 08000 121 700.

Supplier code of conduct

During the year, the Group released a new mandatory Supplier Code of Conduct which supports its Environmental, Social and Governance (ESG) commitments and includes a section on Modern Slavery and Human Trafficking. As part of this section, suppliers are required to have appropriate procedures in place to comply with the Group’s Anti-Slavery and Human Trafficking Policy and all applicable law including the UK Modern Slavery Act 2015.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking and have previously written to our suppliers notifying them of our support for the aims of the Act and provided them with a copy of our Modern Slavery Policy.

The Group’s procurement policy includes cross-references to Modern Slavery and the Modern Slavery Policy.

The Group also employs a Procurement Manager and a Risk Governance Manager who, as part of their roles, ensure that there is a high level of understanding of the risks of slavery and human trafficking in our supply chains and our business.

The Group holds the Business Working Responsibly Mark for responsible and sustainable business practices and achieved recertification during 2023/24. The Mark, developed by Business in the Community Ireland and audited by the NSAI, is based on ISO26000.

During 2023/24 the Company made a £1,000 donation to a human trafficking charity, Invisible Traffick, in an effort to help its volunteers raise awareness and provide education regarding human trafficking and modern slavery. The support from Power NI has been awarded through its Brighter Communities programme for assisting innovative and emerging community groups.

Training

To improve the understanding of modern slavery risks within the procurement supply chain, select Company staff are encouraged to take CIPS Ethical Procurement refresher training. Furthermore, all Group staff receive online Anti Bribery and Corruption training as part of the Group’s compliance training programme. The Company will seek to build on its training programme during 2024/25.

This statement was approved by the Board of Power NI Energy Limited.

William Steele, Director

20 September 2024

Download a copy of our modern slavery statement