Modern Slavery Statement

3ti Energy Hubs Ltd (3ti) has a zero-tolerance approach to any form of modern slavery and is committed to ensuring that it does not take place in our supply chains. This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. 3ti commits to developing and adopting a proactive approach to prevent, respond to, and remediate the risks of modern slavery, forced and debt-bonded labour, human trafficking, and hidden exploitation within its workplaces.

Definitions

Modern slavery is a broad term used to encompass offences that involve one person depriving another person of their liberty, in order to exploit them for personal or commercial gain. Forced labour is all work or service that is exacted from any person under the menace of any penalty and for which the said person has not offered themselves voluntarily. Debt-bonded labour is where a person’s labour is demanded as a means of repayment for a loan or service. Human trafficking is the recruitment and transportation of persons by threat, force, coercion, or other abuse of power or vulnerability to achieve the consent of a person having control over another person for the purpose of exploitation. Hidden labour exploitation involves the exploitation of workers and job applicants by internal or external individuals without the sanction or explicit knowledge of the employer or labour provider.

Commitment

3ti is committed to acting ethically, with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. This policy applies to all persons working for 3ti or on our behalf in any capacity, including employees at all levels, directors, contractors, third-party representatives, and business partners, including recruitment agencies.

Responsibility

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Our Business

• 3ti Energy Hubs Ltd operates primarily from its Head Office in Leatherhead, Surrey. • 3ti designs, finances, installs, and maintains solar car parks in the UK only. • 3ti imports products from worldwide suppliers.

Our Policies

We operate a number of internal policies to ensure that we conduct business in an ethical and transparent manner. These include: • **Anti-Slavery & Human Trafficking Policy** – outlines our stance on modern slavery. • **Recruitment Policy** – ensures a robust recruitment process. • **Prevention of Illegal Workers Policy** – prevents illegal migrant working as governed by the Immigration, Asylum, and Nationality Act 2006. • **Anti-Corruption & Bribery Policy** – ensures all business is conducted in an honest and ethical manner. • **3ti Suppliers Code of Conduct** – establishes professional, ethical, and impartial business practices. • **National Minimum Wage & Living Wage** – adheres to government wage rates. • **Whistleblowing Policy** – provides a safe mechanism for reporting concerns confidentially.

Due Diligence Processes

We have in place policies and systems across our business and supply chains to: • Identify inappropriate employment practices. • Assess and monitor potential risk areas. • Mitigate the risk of slavery and human trafficking. • Protect whistleblowers. • Investigate reports of modern slavery. We have undertaken an initial high-level risk assessment of our contracts, identifying where supply chains extend into high-risk sectors or territories. 3ti requires high-risk suppliers to provide assurances that they have undertaken appropriate due diligence to ensure their supply chains are free from slavery and human trafficking.

Our Suppliers and Risks

3ti operates a supplier policy and maintains a preferred supplier list, reviewed annually. Due diligence on all suppliers includes an online search to ensure they have never been convicted of offences related to modern slavery. All suppliers must confirm that: • They have taken steps to eradicate modern slavery within their business. • They hold their own suppliers accountable for modern slavery compliance. 3ti actively identifies and assesses potential risk areas in its supply chain.

Training

We conduct regular training for procurement colleagues to help them recognise the signs of modern slavery and understand the appropriate actions to take. Policies are accessible on our company SharePoint and covered in our induction program. We also provide updates through internal briefings and reminders of good practice.

Our Initiatives and Next Steps

• Raising awareness of the Anti-Slavery and Human Trafficking Policy and Supplier Code of Conduct. • Additional training for employees as necessary. • Developing a system for supply chain verification. • Reviewing existing supply chains.

Our Performance Indicators

We measure the effectiveness of our efforts in combating modern slavery through: • No reports from employees, the public, or law enforcement agencies indicating modern slavery practices. • Regular audits by Directors and Managers. • Labour monitoring and payroll system reviews. • Ongoing communication and verification with supply chain partners.