Anti-Slavery & Human Trafficking Policy Statement

3ti Energy Hubs Ltd (3ti) has a zero tolerance approach to any form of modern slavery and are 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.

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 himself 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 is action up to and including modern slavery which 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.

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 with 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 have 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 about it, 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 design, finance, install and maintain solar car parks in the UK only
• 3ti import products from worldwide suppliers

Our Policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and
transparent manner. These include (but are not limited to):
• Anti-Slavery & Human Trafficking Policy – this policy sets out the organisations stance on modern slavery
• Recruitment Policy – we operate a robust recruitment policy
• Prevention of Illegal Workers Policy – this policy ensures the prevention of illegal migrant working in the UK as governed by the Immigration, Asylum and Nationality Act 2006
• Anti-corruption & Bribery Policy – this policy explains the manner in which we conduct all of our business in an honest and ethical manner
• 3ti Suppliers Code of Conduct – this code explains how business is conducted in a professional, strictly honest, ethical and impartial manner
• National Minimum Wage & Living Wage – we operate in adherence to the government’s wage rates
• Whistleblowing Policy – this policy explains how colleagues can safely and effectively report any matters relating to the business and/or colleagues in the strictest of confidence and without any detriment

Due Diligence Processes
We have in place policies and systems across our business, our trading partners and our supply chains to:
• Identify inappropriate employment practices
• Identify, assess and monitor other potential risk areas
• Mitigate the risk of slavery and human trafficking occurring
• 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 sectors and territories that are high risk in terms of the potential presence of slavery and human trafficking. 3ti will ask suppliers identified as high risk to provide assurances that they have undertaken appropriate due diligence in ensuring that there is no slavery or human trafficking within the supply chains that serve their contract with 3ti.

We also have a Supplier Code of Conduct which outlines our expectations. We expect our suppliers and other companies that we engage with to ensure their goods, materials and labour-related supply chains are:
• Fully compliant with the Modern Slavery Act 2015
• Transparent, accountable and auditable
• Free from ethical ambiguities

Our Suppliers and Risks
3ti operates a supplier policy and maintains a preferred supplier list which is reviewed annually. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that a particular organisation has never been convicted of offences relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
• They have taken steps to eradicate modern slavery within their business
• They hold their own suppliers to account over modern slavery

3ti will identify and assess potential risk areas in our supply chain.

Training
We regularly conduct training for our procurement colleagues so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

We hold copies of all our policies on our company SharePoint which are accessible to all colleagues and is covered within our induction programme. We also provide updates to our colleagues via internal briefings and by providing both written and oral reminders of good practice.

Our Initiatives and Next Steps
• Raising awareness of the Anti-Slavery and Human Trafficking Policy and 3ti Supplier Code of Conduct with our employees and suppliers
• Additional training for employees as necessary
• Developing a system for supply chain verification
• Reviewing existing supply chains

Our Performance Indicators
We will know the effectiveness of the steps we are taking to ensure that slavery and/or human trafficking
is not taking place within our business or supply chain if:
• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified

We will also use the following performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
• Completion of regular audits by Directors and Managers
• Use of labour monitoring and payroll systems
• Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations