Modern Slavery Act

Definitions

Enpaas 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

Enpaas acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Enpaas understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Enpaas does not enter into business with any other Organisations, 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 Enpaas in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Enpaas strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and India and in many cases exceeds the requirements of the legal obligations of the Country they work in.

Supply chains

In order to fulfil its activities, other than the employees of the Business in the UK and India described above, the main supply chains of the Enpaas include energy generators, energy brokers and meter operators

Potential exposure

In general, Enpaas considers its exposure to slavery/human trafficking to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business and is currently reviewing the policies of its outsourced partners as well.

Steps

Enpaas carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Enpaas has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Enpaas is currently taking the following steps to ensure that modern slavery is not taking place:

• reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
• putting measures in place to identify and assess the potential risks in its supply chains
• undertaking impact assessments of Enpaas’s services upon potential instances of slavery
• creating action plans to address risk to modern slavery
• We are training and briefing our staff on modern slavery, to ensure a zero-tolerance approach in all areas of the business

Key performance indicators

Enpaas has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the organisation or its supply chains:

• Ensure that all our staff are trained and informed and are aware of the company’s policy in terms of Modern Slavery
• Thorough due diligence throughout our supply chain to ensure our Business does not contract with Businesses who do practice or are suspected of practicing Modern Slavery
• Constant review of our Business activities via risk assessment to minimize the risk of modern slavery
• Engender a culture which encourages staff and stakeholders to speak out if they see anything untoward in respect of Modern Slavery

Policies

Enpaas continually reviews its Policies and procedures to ensure they are compliant with the Modern Slavery Act 2015.