Modern Slavery and Human Trafficking Transparency Statement for the financial year end 28 February 2022
This statement, made pursuant to section 54 (1) of the Modern Slavery Act 2015, demonstrates our commitment to tackle modern slavery and sets out the approach taken by Esken Limited to understand whether slavery, servitude, forced labour and/or human trafficking (together ‘’Modern Slavery’’) exist in our supply chain. The statement covers Esken Renewables which meets the criteria for publishing an annual modern slavery statement under the Act, (the ‘Covered Subsidiary’). This statement demonstrated the actions undertaken to eliminate Modern Slavery during the financial year ended 28 February 2022.
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 was prepared by our Modern Slavery Working Group and has been approved by the Board of Directors of Esken Limited and the Boards of Directors of the Covered Subsidiary. 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.
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 2022, Esken Limited had approximately 780 employees operating across two main operating divisions at sites throughout the United Kingdom.
The operating divisions can be summarised as follows:
Our Aviation division aims to deliver a first-class passenger experience through its ownership of London Southend Airport and Carlisle Lake District Airport.
Star Handling is a leading provider of global logistics operations, ground handling, passenger and airside services for airports and airlines. It provides its services at Manchester Airport, London Stansted Airport and London Southend Airport.
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 and Procedures
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.
Our Modern Slavery Working Group and representatives from all areas of the business lead our efforts in this area, including meeting on a monthly basis to review, assess and drive actions. 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.
- Supplier Code of Conduct. This was introduced during 2021 and sets the standards by which we judge our suppliers and require them to adhere to. Further details about how this code deals with Modern Slavery is set out below.
- 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.
- Dignity at Work Policy: Esken is committed to promoting a working environment that encourages inclusiveness and which is free from discrimination, harassment, bullying and intimidating behaviour.
We continually review our policies and processes to ensure they achieve the right results. Our immediate focus is on ethical standards, to ensure that they are embedded into our organisation and direct value chains.
Our Commitment – What We Do
Supply Chain Adherence to the Group's Values and Ethics
Without the appropriate checks and procedures, we recognise that there is the potential for modern slavery to occur within our recruitment processes. Therefore, when recruiting new team members, we ensure that a robust selection process takes place – which is managed by a trained recruitment team.
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 term 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.
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. We have updated our Supplier Code of Conduct during the year.
The Group will monitor 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.
Internal Audit and Assurance
Environmental, Social and Governance (ESG) standards is a risk area on our Corporate Risk Register. This helps to ensure that from a strategic point of view, ESG risks are regularly monitored and are key factors used to inform our annual internal audit plan and assurance work.
Risk Assessment and Management
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. However, the risk is not ignored and features on our Group risk register. Whilst we have not yet seen reason to consider our previous formal assessment of risk in this area, we will undertake a review during the year to provide assurance.
Training on Modern Slavery and Human Trafficking
We provide training by way of e-learning to all our employees about the risks and possible indicators of modern slavery and human trafficking. For our new starters, this training is mandatory and must be completed within the first month after their start date. Thereafter this training will be repeated annually. Compliance is monitored centrally.
As part of the training, we encourage employee vigilance and willingness to challenge a situation. Through our mandatory e-learning programme, we aim to help people understand how to work together, internally and externally, if they encounter something that raises concerns.
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 2021/2022
In 2021/2022, the Group took the following action:
- Reviewed 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.
- Implemented a revised Code of Conduct for suppliers which sets out, amongst other things, our expectations for suppliers as follows:
- All employment to have been freely chosen by each employee
- Workers must be free to choose their own employment. There must be no slavery, servitude, forced labour or human trafficking.
- Esken has a zero-tolerance approach to modern slavery, and we are committed to tackling modern slavery throughout our supply chains.
- Wherever we work we ensure that nobody is exploited, we expect suppliers to share this commitment. This means Esken will refuse or cease to do business with any individual, company or organisation that fails to uphold the standards and principles of basic human rights.
- The Group has implemented a training programme for all of its employees with regard to slavery and human trafficking.
What We Will Do In 2022/2023
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 2022/2023:
- Continue to raise awareness amongst employees of modern slavery and human trafficking issues through our new training programme.
- Continue to implement our new Code of Conduct for our suppliers which reflects the Group’s values.
- As part of our ongoing review of our standard terms for doing business, implemented new conditions of use for London Southend Airport which commit airlines to compliance with our policy and which require them to make warranties with regard to their own compliance with relevant legislation.
- 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.
- Further 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.
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.
Esken’s Modern Slavery Statement was prepared by our Modern Slavery Working Group and approved by the Board of Directors of Esken Limited.