Modern Day Slavery & Human Trafficking Policy
Scope
Envevo is committed to ensuring transparency in our business and our approach to tackling modern slavery
throughout our supply chains which is consistent with our disclosure obligations under the Modern Slavery Act
2015 (the Act). We expect the same high standards from all of our contractors, suppliers and other business
partners, and as part of our contracting processes, we include specific prohibitions against the use of forced,
compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect
that our suppliers will hold their suppliers to the same high standards.
Our company is made up of several subsidiaries, supported by a central group functions. As a provider of EV
charging installation, maintenance and back office services we operate across private and public sectors, primarily
our employees work across our operations in the UK.
This is an Envevo group level policy and applies to everyone employed by Envevo or any company that forms part
of the group. The policy applies to employees at all levels, directors, officers, agency workers, seconded workers,
volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
Definitions
The Organisation considers that modern slavery encompasses:
• Human trafficking
• Forced work, through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• Being dehumanised, treated as a commodity or being bought or sold as property
• Being physically constrained or to have restriction placed on freedom of movement.
Commitment
The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with
the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of
both its internal practices in relation to its labour force and, additionally, its supply chains.
The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which
knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of
slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its
responsibilities under relevant employment legislation in the United Kingdom, and in many cases exceeds those
minimums in relation to its employees.
Steps
The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not
take place in its organisation or supply chains. We interact with our suppliers to obtain their assurance that they
conduct pertinent and suitable due diligence within their companies.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been
found to have involved itself with modern slavery.
COMPLIANCE WITH THE POLICY
Employees must ensure they read, understand and comply with this policy. The prevention, detection and
reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working
for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this
policy. You must therefore notify your manager or HR as soon as possible if you believe or suspect that a conflict
with this policy has occurred or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business
or supply chains at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that
it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as
possible.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this
policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental
treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form, is or may be
taking place in any part of our own business or in any of our supply chains
Policies
The Group has the following policies which further define its stance on modern slavery and support the
implementation and adherence of this policy:
Recruitment Policy: HR-SOP-002
Whistleblowing: HR-SOP-026
Training
The Group provides the following training to staff to effectively implement its stance on modern slavery:
• Individuals to review and sign acceptance of the policy as part of induction training.
• Regular training will be provided as necessary.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct
or gross misconduct. We may terminate our relationship with other individuals and organisations working on our
behalf if they breach this policy.
Date: 07/06/2024