Anti-slavery policy

Purpose

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and is published on behalf of Mercia Power Limited (and its subsidiaries) (the Companies). References in this Statement to “we”, “us” or “our” are to the Companies.

This is our Statement for the financial year ending 31 December 2022 and it details the steps taken by us to ensure that slavery and human trafficking do not occur in our supply chains or any part of our business.

Our business

We are a group that specialises in the provision of flexible power response services to the UK national electrical grid and other UK power market participants, helping to balance the supply of renewable energy with demand. The Group develops and operates advanced power stations that quickly respond when supply from renewables is low, providing energy to communities across the country and ensuring that they have power.

The Group has a large-scale diversified portfolio with both wholly owned sites and those owned by associated companies or managed for third parties. Further capacity is under construction and there is a large pipeline for future development.

These sites sell power on the day ahead and intraday markets at peak times and also through the provision of services to National Grid to help them balance the power network in real-time.

We comply with applicable legislation relating to employee terms and conditions, and none of our staff earn less than the living wage.

Supply chains risk assessment

We recognise that modern slavery is a crime and a fundamental violation of human rights. We are committed to ensuring that there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains.

Our industry is not seen as higher risk for modern slavery and human-trafficking, and are not aware of any incidents of modern slavery within our supply chains or any part of our business to-date.

We seek to ensure that we engage only with those suppliers who uphold the values to which we adhere, and we expect all our suppliers to act ethically and with integrity at all times, sharing our commitment to humane and safe working practices.

Policies, procedures and compliance

We take our responsibilities seriously and aim to demonstrate our commitment to operating fairly, honestly and in compliance with all applicable legislative, regulatory and ethical requirements. We intend to foster a culture in which integrity and responsible and ethical values are at the core of our business and our decision-making process.

Any abuse of human rights, either within our business or anyone employed by our associated with us, will not be tolerated.

We are committed to ensuring that our business operates ethically at every level and that our people and suppliers share and understand this commitment.

Our anti-slavery and human trafficking policy details this zero-tolerance approach to any form of slavery or human trafficking in our supply chain or within our business itself.

Our supply chain broadly fits into two categories: very large energy companies and infrastructure suppliers and much smaller specialist owner-managed businesses. We are carrying out an exercise to evaluate the risk associated with our larger suppliers. For the smaller suppliers we will be alert to any signs of slavery or human trafficking.

Training

All employees are trained and made aware of our commitment to ensuring our business is free of slavery and human trafficking. We will undertake refresher training with our staff in circumstances where there has been a substantial change in the Act or our policies.

Measuring performance

We have not yet adopted any specific modern slavery performance indicators. However as our business grows we will keep the need for such measures under review.

We will continue to keep our supply chains under review to monitor and identify ongoing and future risks. We will draw upon best practice, regulatory requirements and industry guidance to help strengthen our measures to detect and prevent slavery and human trafficking.

Board approval

This Statement for the financial year ending 31 December 2022 has been approved by the Board of Directors of Mercia Power Limited.

Graham White (CEO)

Date: 15 June 2023