Modern Slavery Statement

 

This statement is made by BioticNRG Limited and subsidiaries (the Company) pursuant to Section 54 of the UK Modern Slavery Act 2015 (the “MSA”). It sets out the steps that the Company has in place or has taken during the financial year ending 31^st December 2024, to combat and prevent all forms of modern slavery and human trafficking in its direct business operations and supply chains.

 

The Company adheres to and promotes strong professional ethics and is committed to conducting business activities according to the highest standards of honesty and fairness. This commitment to observe such ethical standards is designed, not only to ensure compliance with applicable laws and regulations in the various jurisdictions where the Company operates, but also to earn and keep the continued trust of its clients, shareholders, personnel, and business partners. We believe that success and reputation depends on the quality of our products and services provided and the way we do business. This includes a strong commitment to human rights, and we welcome the transparency promoted by the MSA.

 

1. Company structure and business

 

The Company and its subsidiaries are incorporated in the UK.  As a responsible asset owner and operator we actively invest for the long-term to help our clients, shareholders, our employees and the wider community.

 

2. Company supply chains 

 

The Company purchases products and services to undertake internal operations, including IT and administrative, HR and consulting services, waste supply and services, parts supply, gas, electricity, CO2 and bark production and sales. As a renewable energy, haulage and composting business, most of our impacts on society are linked to our choice of suppliers, with a limited impact from our internal processes. The Company integrates both social and environmental dimensions into its procurement selection process. Suppliers we engage with must be committed to sustainability and to protecting human rights including MSA compliance.  These are covered in our third party supplier vetting process.

 

3. Engagements and policies

 

We are committed to respecting all internationally recognized human rights principles including supporting the elimination of all forms of forced and compulsory labour and the effective abolition of child labour.   Our Company has numerous policies in place to protect these rights such as an Anti Bribery and Corruption Policy, Outsourcing Policy, Conflict of Interest Policy, Code of Conduct Policy and Whistleblowing Policy.   Our Handbook protects employee rights to dependency leave and protection from all forms of harassment.

 

4. Management of the modern slavery and human trafficking risk in the Company’s operations 

 

The Company acknowledges its responsibility to respect human rights in its operations and conducts its business in compliance with applicable employment regulations in the jurisdictions in which it operates. We respect the rights of our employees and workers to enjoy just and favourable conditions of work, including health and safety protections, and are committed to providing adequate information and training on health and safety and wellbeing issues.

 

We promote diversity and inclusion by prohibiting any form of unlawful discrimination.

 

Staff have been trained on modern slavery and human trafficking risks and are encouraged to report any concerns.

 

We work with suppliers and customers who share the same views on the importance of protecting Human Rights and preventing modern slavery through a documented vetting process.  The majority of operations and services are carried out by our own full time employees.  Full employment checks are undertaken on any new employees to ensure that they have the legal right to work and all staff are paid above the minimum wage. There is therefore a low risk of any modern slavery and trafficking issues within our own staff.  While there is a potential risk that sub contractors or third party service providers who provide labour or services to our company may not share the same ethos as ourselves we mitigate this by generally working with contractors and suppliers with whom we have long term relationships.  This ensures that we are aware of the conditions that their employees work under because of our close working relationship with them.  Any new sub contractors are vetted using our Sub Contractor Questionnaire which includes confirmation of compliance with, among other things, Modern Slavery legal requirements.  Where there are any Modern Slavery concerns or issues, additional auditing and spot check inspections will be undertaken by our General Counsel.

5. Responsibility for this Policy

 

The 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.  On behalf of the Board of Directors the General Counsel (Director) has primary day-to-day responsibility (for ensuring implementation of 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.

 

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

 

6. Compliance with this Policy

 

All Employees and contractors must ensure that 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. All employees and contractors must avoid any activity that might lead to, or suggest, a breach of this policy.

 

Any employee or contractor becoming aware of, or suspecting, a conflict with this policy has occurred, or may occur in the future must immediately inform General Counsel.  Employees and contractors are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.  We will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.

 

If any Employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they must raise it with their line manager or directly with the General Counsel.

 

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 business or in any of our supply chains.  Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

 

If an Employee believes that they have suffered any such treatment, they should inform their line manager immediately. If the matter is not remedied the employee should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.

 

7. 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, sub-contractors and organisations working on our behalf if they breach this policy.

 

8. Further steps

 

The Company will continue to review its current practices to detect and prevent modern slavery and human trafficking within its operations and supply chains and will endeavour to enhance any procedures, policies, or practices, that it deems appropriate.

 

The Boards of Directors of the Company approved this policy on 6^th January 2025, which constitutes each Company’s slavery and human trafficking statement made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31 December 2024.