Modern Slavery Act 2015 (the "Act"):

npower Slavery and Human Trafficking Statement

 

This document represents The Slavery and Human Trafficking Statement for each of the following companies within the npower group of companies (all being subsidiary companies of npower Group PLC):

  • Npower Limited
  • Npower Northern Limited
  • Npower Commercial Gas Limited
  • Npower Gas Limited
  • Npower Direct Limited
  • Npower Yorkshire Limited

collectively (“npower” or the “npower Companies”, “we”, “our”).

Introduction1

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and to making improvements to our practice where appropriate to meet this commitment. We support the ten principles of the United Nations Global Compact, including the protection of internationally proclaimed human rights and the elimination of all forms of forced and compulsory labour. In npower we apply the innogy Code of Conduct which reflects these principles.

1 (from the respective boards of each of the Npower Companies)

Our business and organisation structure

Across the npower companies we are a leading supplier of electricity, gas and related goods and services to homes and businesses in the UK. We are a part of the innogy SE (“innogy”) group of companies, a European energy group which has its head office in Germany. With its three business areas of Renewables, Grid and Infrastructure and Retail, it addresses the requirements of a modern, decarbonised, decentralised and digital energy world.

Our UK retail business is supported in its supply chain activities by innogy Business Services UK Limited, an innogy group company that manages procurement activity for the UK retail business.

Our policies on slavery and human trafficking

Our business approach reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing processes, policies and controls that seek to eliminate slavery and human trafficking in our supply chains.

What are we doing to ensure that there is no modern slavery or human trafficking in our own business?

Our HR policies, processes and practices for employees, agency workers or fixed term contractors adopt the core values of the innogy Code of Conduct. Our key HR policies include but are not limited to:

  • Speak Up Policy - We encourage all workers to report any concerns related to our direct activities or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our Speak Up Policy is designed to make it easy for workers to make disclosures without fear of retaliation. Employees or others who have concerns can use our confidential helpline and email operated by an external provider.
  • Recruitment and Selection/Agency Workers/Fixed Term Contract/Contractor Principles Policy - We contract with reputable employment agencies to source labour and, by means of a pre-contract Sustainability Questionnaire (which requests confirmation of policy and process relating to the requirements of the Act) verifies the practices of any new agency it is contracting with before accepting workers from that agency in line with our supply chain processes.
  • Grievance / Bullying and Harassment - These policies are designed to enable employees to raise and resolve personal concerns including those relating to slavery or human trafficking which is affecting them.
  • Disciplinary Procedure - Our Disciplinary Procedure provides a mechanism for dealing with matters of misconduct or breach of the innogy Code of Conduct which relate to slavery or human trafficking.

Our supply chains

Our supply chains span a wide variety of goods and services from suppliers that are both national and international.

What are we doing to ensure that there is no modern slavery or human trafficking in our supply chain?

We have zero tolerance to slavery and human trafficking. Consistent with the principles of the UN Global Compact, and in order to identify and mitigate risk of slavery and human trafficking, we have put in place processes in relation to our suppliers to identify, assess and monitor potential risk areas in our supply chains:

  • For several years, our Procurement Function has imposed obligations on all suppliers it sources and contracts with on our standard procurement terms, relating to compliance with our Code of Conduct (now the innogy Code of Conduct).
  • In addition, we now apply a Procurement Policy under which our suppliers must meet the requirements of the Act and the innogy Code of Conduct.
  • References to the requirements of our Procurement Policy are now included in our Sustainability Questionnaire and our standard procurement terms and conditions.
  • Our Sustainability Questionnaire requests confirmation of policy and process relating to the requirements of the Act. This Questionnaire is used in relation to every new supplier contracted via our Procurement Function except for low risk suppliers and relationships which are not of material value.
  • Where we contract with suppliers on our standard procurement terms and conditions, we now include provisions requiring compliance by the supplier with the requirements of the Act.
  • Where we carry out formal tender processes, in defining a bidder group, we now ensure that we do not involve any potential bidder that appears on the World Bank Sanctions Lists (subject to very limited exceptions), or the EU Sanctions Lists. Once a supplier is appointed, our Accounts Payable team checks these lists on a regular basis to identify any supplier subsequently going onto a list in which case an investigation is carried out.
  • We now obtain bidder confirmation during formal tender processes, that there is no risk of slavery in their organisation or their supply chain.
  • Our Procurement and Corporate Responsibility Teams have now introduced regular meetings to review policy, process and issues arising in relation slavery and human trafficking.
  • We will continue to look at how we can better identify and mitigate risks of slavery and human trafficking in our supply chains.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have introduced awareness training to new procurement staff.

Our effectiveness in combating slavery and human trafficking

We are developing key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.

Our performance indicators

We will use the following to monitor the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain:

  • Monitoring the number of new staff who receive training in relation to the requirements of the Act
  • Monitoring the frequency of internal escalation to our Corporate Responsibility Manager in relation to potential suppliers involved in any tender process
  • Monitoring the instances of current suppliers found to be in breach of requirements relating to the Act

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement of each of the Npower Companies for the financial year ending 31st December 2016.

 
 
Pete Sharman's signature

Director: Peter Sharman

Npower Limited

Date: 9/5/2017

Pete Sharman's signature

Director: Peter Sharman

Npower Northern Limited

Date: 9/5/2017

Pete Sharman's signature

Director: Peter Sharman

Npower Commercial Gas Limited

Date: 9/5/2017

 
 
Pete Sharman's signature

Director: Peter Sharman

Npower Gas Limited

Date: 9/5/2017

Pete Sharman's signature

Director: Peter Sharman

Npower Direct Limited

Date: 9/5/2017

Pete Sharman's signature

Director: Peter Sharman

Npower Yorkshire Limited

Date: 9/5/2017