Introduction
This is the Modern Slavery Statement for City Energy Network for the financial years ending 31st January 2023 and 31st January 2024. This statement is made pursuant to the Modern Slavery Act 2015 (the “Act”).
The Act creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”).
About City Energy Network
City Energy Network is one of the leading grant funding brokers and energy efficiency project management firms in England, Scotland and Wales.
The firm works with a number of contractors and partners across a range of products, services and sectors. Strong relationships with our contractors and partners, as well as our customers, are fundamental to the success of our business.
City Energy Network’s direct supply chain is entirely derived from small to medium sized enterprises in the UK, including some micro businesses and sole traders. Whilst the firm’s operations and projects are UK based, it recognises that Modern Slavery is not a risk that is restricted to construction projects overseas and that supply chains extend globally.
Policies and Procedures
The firm has a range of policies and procedures setting high ethical standards for the employment of personnel and the assessment of the contracting supply chain. Assessments are carried out during on-boarding and throughout the contractual relationship, assisting in identifying Modern Slavery. They include the following:
- Supplier Management Procedure
- Whistle Blowing Policy
- Human Rights Policy
City Energy Network will assess the requirements applicable for the firm under the Act for each financial year, providing assurances to its partners and supply chain.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. The Company has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will 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 own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Responsibility for the policy
The Company 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 Company 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.
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.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.
Compliance with the policy
You must ensure that you 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 notify your line manager OR a company Director 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 of any supplier tier 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 line manager or company Director OR report it in accordance with our Whistleblowing Policy as soon as possible.
You should note that where appropriate, and with the welfare and safety of local workers as a priority, 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 you are 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, raise it with your line manager or company Director.
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.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook. This Modern (Anti) Slavery Policy and Statement is intended for City Energy Network Employees, subcontractors and staff, interested parties and Partners inc any business or organisation involved within the City Energy Network of operational and or contractual obligation.
Communication & awareness of this policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
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.
Printed and Signed and dated by MG – City Energy Network limited.
Name – Shelley Roberts
Signed –
Dated – 25/05/2023
References
P008 Supplier Management Procedure
POL034 Human Rights Policy
HR017 Whistle Blowing Policy within Staff Handbook
POL021 Whistle Blowing terms within Health and Safety Policy