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Anti-Slavery and Human Trafficking Policy 2019-2020

ERSG Holdings and our affiliates, who include ERSG Limited, ERSG GmbH and ERSG B.V., have relationships with various types of suppliers, the majority of whom are professional contractors working in the energy sector. Following the passing of the Modern Slavery Act in 2015, ERSG  reviewed its existing compliance and risk management processes to determine to what extent measures were already in place and what further measures were required to prevent slavery and human trafficking taking place in any part of our businesses or in our supply chains. This policy underpins our approach and is used to inform our Statement on Slavery and Human Trafficking as updated on a yearly basis.

ERSG has adopted a statement of its corporate values on the prevention of modern slavery and human trafficking. The value statement governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or whom we appoint to act on our behalf.

Whilst we primarily work with suppliers, contractors and clients that are not usually considered at a high risk of modern slavery, we continue to prioritise our responsibilities of preventing and modern slavery with our supply chain and business. We expect all who have, or seek to have, a business relationship with ERSG to comply themselves with this statement and to act at all times in a way which is consistent with our anti-slavery values.


ERSGs Anti-Slavery Commitment

As part of our culture of good ethics and practice ERSG operates a set of values which reflect our relationships with our principal stakeholders: customers, shareholders, suppliers, contractors and employees. In all of its business dealings, ERSG opposes the exploitation of individuals in any form, particularly the offences created by the Modern Slavery Act 2015. ERSG is committed to opposing modern slavery in all its forms and preventing it by whatever means possible. ERSG expects the same of all who work for and with it.


1. Purpose

1.1 Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the "Act"). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of ERSG with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy's use of the term "modern slavery" has the meaning given in the Act.

1.2 ERSG has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensuring modern slavery is not taking place anywhere in its business or supply chain.


2. Steps for the prevention of modern slavery

2.1 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors and suppliers, and we updated our processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude. We expect our suppliers to hold their own suppliers to the same requirements.

2.2 All employees and suppliers are required to comply with ERSG's procedures to prevent modern slavery and to conduct business in a manner such that modern slavery is prevented.

2.3 While ERSG complies with the Modern Slavery Act 2015, it acknowledges that it does not control the conduct of those in our supply chains.

To underpin our compliance with practical steps, ERSG have implemented the following measures:

  1. conducting risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can and are, focused on those areas:
  2. engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses:
  3. introduced supplier pre-screening (for example as part of our tender process) and self-reporting for our suppliers on safeguarding controls.
  4. introduced contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.
  5. conducting a full compliance check on the contractors and the personal service companies (PSC) we engage.

2.4 From financial year 2016, ERSG has included in the directors' report accompanying its annual financial statements a reference to its Slavery and Human Trafficking Statement which is present on our website.


3. Responsibility for the policy

3.1 Responsibility for the prevention of modern slavery rests with ERSG's Directors and senior management. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

3.2 Managers are responsible for ensuring that their staff understand and comply with this policy and are given routine training on it.

4. Actions to report modern slavery or human trafficking

Whistleblowing Procedure - direct access to senior management.
ERSG's Whistleblowing Procedure is intended to provide guidance on how concerns can be communicated to the Company. Concerns about suspected modern slavery associated with the Company or our suppliers may be reported by employees in this manner. The Whistleblowing Procedure applies to all employees.

Employees should raise any concerns with a Director of ERSG or their Country Manager as appropriate.

Concerns should be raised if any employee or any supplier:
- suspects a person acting on behalf of ERSG is seeking to exploit another in a way which could amount to modern slavery;
- suspects that a person acting on behalf of one of ERSG's suppliers is seeking to exploit another in a way which could amount to modern slavery;
- has received an approach from a person acting on behalf of ERSG who has invited you to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed;
- has information which leads to the reasonable conclusion that a person acting on behalf of ERSG or any supplier is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.

Reports are kept confidential except where ERSG is required to pass information to relevant authorities. ERSG ensures full compliance in working with the relevant authorities to assist in the prevention of Modern Slavery.


5. Safeguards

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.
However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against an employee making such claims or allegations.


6. Next Steps

ERSG is working towards the development of a more frequent training process given to staff ensuring that they understand and comply with the policy.


7. Communication and awareness of this policy

We aim to communicate our zero-tolerance approach to modern slavery to all suppliers and contractors and business partners at the outset of our business relationship with them and to reinforce it as appropriate thereafter.

8. Review

This Anti-Slavery and Human Trafficking Policy is reviewed by ERSG's Directors on an annual basis and is updated annually in accordance with any amendments and additions to the Modern Slavery Act.

This policy was published on 2 July 2019 and is approved by the Board of Directors.

Signature - Jim

Signed by Michael James Ryan


 Signature - Lucien

Signed by Lucien Sullivan



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