Modern Slavery and Human Trafficking Transparency Statement for the financial year end 28 February 2021

Esken Limited (and all of its operating divisions and subsidiary companies) (together ‘the Group’) is committed to taking appropriate and proportionate steps to ensure that slavery and human trafficking do not exist within its business and supply chains.

This statement is issued by Esken Limited under the provisions of the Modern Slavery Act 2015 (the Act) and covers the financial year ending 28 February 2021. This statement covers Stobart Energy which meets the criteria for publishing an annual modern slavery statement under the Act, (the ‘Covered Subsidiary’).

This statement has been approved by the Board of Directors of Esken Limited and the Boards of Directors of the Covered Subsidiaries. The statement has been signed by David Shearer, the Executive Chairman of Esken Limited on behalf of Esken Limited and the Covered Subsidiary. The information contained in this statement is correct at the date of publishing.

Company Overview

Esken Limited, the aviation and energy infrastructure group, is listed on the London Stock Exchange. As at the end of the financial year to 28 February 2021, Esken Limited had over 900 employees operating across two main operating divisions at sites throughout the United Kingdom.

The operating divisions can be summarised as follows:

London Southend Airport

Aims to deliver a first-class passenger experience, along with the provision of ground handling services.

Esken Renewables

Is the number one supplier of biomass in the UK, sourcing, processing, and supplying fuel to biomass plants under a mix of short and long-term contracts.

Further details about our business can be found at http://www.esken.com

Policies

The Group is committed to acting ethically and ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business.

The Group’s internal policies reflect our commitment in all our business relationships to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

All internal policies are reviewed regularly to ensure they are appropriate, well communicated and promote continued compliance with the Act and other applicable legislation.

The following key policies are in place which relate to the prevention of slavery and human trafficking in our operations:

  • Modern Slavery & Human Trafficking Policy. This was introduced in September 2020 and reaffirms our commitment to tackling slavery and human trafficking and setting out the standards expected of all employees.
  • Whistleblowing Policy. The Group encourages all employees to report any concerns related to the activities of the business, including any worries in relation to modern slavery and human trafficking. The Group’s whistleblowing policy and procedure is designed to ensure that any matter reported will be investigated thoroughly, promptly, and confidentially.

Other relevant Group policies include:

  • Environmental, Social and Governance Policy. We believe that our commitment to the principles of environmental, social and governance (ESG) not only makes good business sense but also complements our Group business strategy and our corporate values. In developing our strategy and setting out our ESG policy, we seek to drive continuous improvement and support our engagement with all stakeholders, internal and external
  • Equality & Diversity Policy. The Group is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination, harassment, and victimisation on the grounds of race, sex, pregnancy, maternity, martial or civil partnership status, gender reassignment, disability, religion or beliefs, age, or sexual orientation.
  • Ethics and Business Integrity Policy. This policy outlines the Group’s requirements for conducting business to the highest ethical standards. The Group demonstrates a clear approach to business integrity and ethics, which underlies Group values.
  • Group Recruitment Policy. The Group ensures that the process of recruiting employees is fair, consistent, professional, and non-discriminatory to both internal and external candidates.

Our Commitment – What We Do

Supply Chain Adherence To The Group's Values And Ethics

The Group considers its supply chain to be at a ‘low risk’ in relation to slavery and human trafficking and has seen no reported incidents of slavery or human trafficking. Given the nature of the business and how we operate within the sectors within which we work, there is no significant utilisation of overseas or unskilled labour, being key areas identified as posing a higher risk; imports are of a minimal amount, unskilled labour is of a small quantity, and where used, specifically in the energy sector, is obtained from reputable companies on long terms contracts with regular site visits. As the Group operates exclusively in the UK and other Western European jurisdictions the vast majority of our suppliers are already under an obligation to comply with UK and EU law on forced labour as they are also based in the UK and Europe.

Supplier Adherence

The Group demonstrates a zero-tolerance to modern slavery and human trafficking and reserves its rights to terminate any arrangements with any of its suppliers should any modern slavery or human trafficking offence be committed or suspected.

The Group will update its policies and procedures as required to ensure it maintains appropriate safeguards against any mistreatment of persons involved in its supply chain or own business.

Effectiveness In Combating Modern Slavery And Human Trafficking

The Group has not seen any incidences of slavery or human trafficking to date (nor has it received any allegations of Slavery or Human Trafficking). Any suspected incidence of slavery or human trafficking within the Group or its supply chain would be immediately reported to the Executive Board in the first instance. It would then be dealt with appropriately, which may include, but is not limited to, terminating commercial relationships, disciplinary action and notifying the relevant authorities.

What We Have Done In 2020/2021

In 2020/2021, the Group took the following action:

  • Reviewed current supplier audit processes to assess any modern slavery or human trafficking risks with new suppliers and also included these reviews as part of continuing assessment and audits of our supplier sites.
  • A revised Code of Conduct for suppliers which sets out, amongst other things, our expectations is under development and is expected to be adopted for use in the business in the very near future.
  • The Group has started to develop a training programme for its employees with regard to slavery and human trafficking and expects to see this implemented during the coming year.

What We will Do In 2021/2022

As part of our on-going commitment to ensuring modern slavery and human trafficking is not present within the Group or its activities, we intend to take the following action in 2021/2022:

  • Continue to raise awareness amongst employees of modern slavery and human trafficking issues through our new training programme.
  • Finalise and implement our new Code of Conduct for our suppliers which reflects the Group’s values.
  • Following on from the review of standard supplier Terms and Conditions, continue a further review of our full suite of precedent contracts and terms to ensure all partners, stakeholders and counterparties that supply goods services to us are required to adhere to our relevant policies.
  • Finalise and implement an amalgamated single supplier onboarding process to cover all divisions, incorporating a modern slavery risk assessment for each supplier.
  • As our business continues to grow and we engage with more long-term partners, for example, airports, airlines, and power plants, work collaboratively to ensure a consistent best practice model is adopted for tackling these issues and ensuring and maintaining compliance.
  • Develop an expanded third-party due diligence process to apply to strategic opportunities across the Group to foster a standardised and consistent approach to modern slavery and human trafficking compliance across all acquisitions and investments across the various business units.

COVID-19

Taking into consideration the nature of the Group’s operations, including within its supply chain, it is not considered that the impact of COVID-19 created any heightened risk of modern slavery occurring within the business or its supply chain. However, as the wider social and economic impact of this pandemic are known the Group will continue to monitor its supply chain closely in this regard and continues to adopt a zero-tolerance approach to any actual or risk or modern slavery within its supply chain and business.

Measuring Our Effectiveness

We recognise that modern slavery and human trafficking is a global and increasing challenge for businesses and we are committed to an ongoing action plan to develop our approach and monitor its effectiveness.  To do this we will continue to:

  • Review the effectiveness of our Modern Slavery and Trafficking Policy and the Supplier Code of Conduct.
  • Ensure all colleagues review our policy annually and confirm they have read and understood it.
  • Ensure our supply chain remains under constant review; and
  • Continue to monitor any cases reported via our Whistleblowing Policy.

Overall, we will continue to focus on understanding further our supply chains, identifying risk areas, and increasing awareness amongst employees on the issues of modern slavery and human trafficking and the reporting procedures available to them. We will continue to update policies and procedures as required to ensure appropriate safeguards against any mistreatment of persons are in place.

David Shearer
Executive Chairman
September 2021