1. Purpose of policy

Company Statement:

eEnergy recognizes and embraces its legal and moral responsibility regarding Modern Slavery and Human Trafficking

and will take reasonable steps to ensure that no such activities arise within or in support of its business.

eEnergy aims to ensure that no modern slavery or human trafficking exists in any form within its business, subsidiaries

or within our partners and suppliers. We will comply with all recognized codes of practice and legislations regarding

human rights, working conditions and employment/organisational practices and will implement measures to ensure that

our partners and suppliers reach these standards also.

2. What is Modern Slavery?

Human trafficking is to illegally move individuals for typical purposes of forced labour or commercial sexual exploitation.

Someone would be considered as being in slavery if;

  • They are forced to work through the threat of mental or physical injury.
  • They are owned or controlled by an ‘employer’ through the action of or threat of mental or physical abuse.
  • They are dehumanised, treated as a commodity, or bought/sold as though property.
  • They are physically constrained or are restricted in terms of their freedom of movement.


  • Slavery – Where ownership is exercised over an individual.
  • Servitude – Obligation to provide services through coercion, abuse or the threat of abuse.
  • Forced labour – An individual being forced to work against their will due to threat of punishment.

3. Potential Indicators

Should an individual be a victim of slavery or human trafficking, indicators such as the below may be witnessed or

discovered through conversations:

  • Signs of being controlled or dependent on another individual.
  • Fear of police/figures of authority.
  • Signs of physical or psychological trauma.
  • The withholding of wages i.e., paid very little or not paid at all.
  • Malnourishment.
  • Excessive hours or overtime with few breaks.
  • Limited freedom of movement e.g., unable to do things after/before work.
  • Fearful of disclosing too much about their situation.
4. Our Policies

We have a number of internal policies to ensure that we are conducting business in an ethical and transparent way.

These include:

  • Recruitment policy – robust processes are in place to ensure that all eEnergy employees undergo the relevant right to work checks.
  • Whistleblowing policy – to ensure that employees know they can raise concerns about how colleagues are treated, or practices within the business or supply chain, without fear of repercussions.
  • Business code of conduct policy – outlines the organisational standards expected from employees and suppliers.
5. Who to Contact

Should any member of eEnergy staff suspect any instance of modern slavery of any individual, they should

immediately contact their line manager and report their concerns. Line Managers must ensure that any and all

concerns are recorded and immediately passed to a senior member of the HR Team who will involve external

organisations as required in a timely manner.

Should an individual not feel comfortable reporting any of their concerns to their line manager, they should seek to

contact a member of senior management or utilise the confidential global whistleblowing hotline for which

the contact details are clearly accessible in Appendix One at the end of this policy.