Modern Slavery and Human Trafficking Statement

Introduction

  • Diversified EfW Management Limited (DEML) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain.
  • DEML is issuing this statement to set out the actions that we are taking to ensure that our business and supply chains are slavery free.

 

Our Structure, Business and Supply Chains.

  • DEML owns interests in five energy from waste (EfW) facilities across the United Kingdom. In addition, it provides management services to an affiliate business which has interests in a further two EfW facilities and is actively involved in the development and/or acquisition of new EfW opportunities. Each of the five EfW facilities has subcontracted its operation and maintenance to a subcontractor which, in each case, is part of the FCC Environmental group. Of the further two facilities, one is operated by an entity within the Veolia group and the other is operated by a Cobalt Energy Limited subsidiary, North Midlands Operations Limited.
  • In order to ensure that DEML’s business and supply chains are slavery free, we have therefore carried out due diligence on the steps taken by the FCC Environmental Group (FCC), Veolia and Cobalt Energy Limited in order to ensure that slavery and human trafficking are not taking place in their own businesses or supply chains. These companies’ commitment to prevent Modern Slavery is outlined in their Modern Slavery and Human Trafficking Policies and Statements which are available on request from DEML and on the DEML SharePoint site.
  • DEML itself has a small number of employees. Its only indirect labour is provided by consultancy firms who are required to contract with DEML on terms which specifically provide for compliance with the Modern Slavery Act 2015.

 

Our Modern Slavery Risk

  • Owing to our size, UK-based assets and the limited number and nature of our direct employees, the inherent risk of modern slavery in the recruitment and engagement of employees is considered to be low. However, we recognise that modern slavery and forced labour does occur in the waste and construction industries across the world and that there is a proportionately higher risk of modern slavery in our supply chain.

 

Due Diligence Processes in Relation to Modern Slavery and Human Trafficking

  • As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted due diligence procedures which are implemented on any procurement of goods or services by DEML.
  • Our procedures are designed to:
    • establish and assess areas of potential risk in our business and supply chains
    • monitor potential risk areas in our business and supply chains
    • reduce the risk of slavery and human trafficking occurring in our business and supply chains
    • provide adequate protection for whistle-blowers
  • We ensure all our suppliers adhere to our Anti-Slavery Policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains.

 

Our Effectiveness In Combating Slavery And Human Trafficking

  • We use the following to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
    • We understand that modern slavery risk is continually evolving, particularly as the DEML business continues to develop, and we will continue to seek to mitigate the risks in the years ahead.
    • We will assess the effectiveness of the measures being taken by monitoring, inter alia, staff training, supply chain audit and verification and investigations into reports of modern slavery.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Diversified EfW Management Limited’s anti-slavery and human trafficking statement for the financial year ending 31st December 2023. This statement was approved by the Board of Directors on 7th February 2024.

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