Modern Slavery and Human Trafficking Statement and Policy.

1. Introduction

ECOedge Ltd recognises that modern slavery and human trafficking are serious crimes and violations of fundamental human rights. Modern slavery can take many forms, including forced labour, bonded labour, servitude, child labour, human trafficking and exploitation.

Although ECOedge Ltd has an annual turnover below £36 million and is not legally required to publish a statement under section 54 of the Modern Slavery Act 2015, we voluntarily adopt this statement as part of our commitment to responsible business practice and to support clients who are required to comply with the Act.

This policy sets out the steps we take to prevent modern slavery within our own operations and to manage the risk of modern slavery within our supply chain.

2. Our business

ECOedge Ltd is a UK-based retrofit consultancy and delivery business providing professional services across domestic and wider built environment retrofit. Our services include:

• Retrofit Assessment support
• Retrofit Design and Coordination
• Energy modelling, EPC, SAP and RdSAP support
• Technical compliance and TrustMark lodgement support
• Installation delivery and support
• Technical assurance, remediation advice and retrofit consultancy

We operate within the United Kingdom and primarily support local authorities, housing providers, landlords, installers, delivery partners and private clients.

We do not operate in sectors typically considered higher risk for modern slavery, such as overseas labour sourcing, agriculture, manufacturing, extractive industries or high-volume overseas production. However, we recognise that modern slavery risk can exist indirectly within wider supply chains and must be managed proportionately.

3. Our supply chain

ECOedge Ltd’s supply chain may include:

• Professional consultants and energy assessors
• Specialist technical subcontractors
• Retrofit installers and installation partners
• Material suppliers and product manufacturers
• Software, IT and digital service providers
• Office, administrative and professional service providers

Our direct operations are assessed as low risk in relation to modern slavery because our work is primarily professional, technical and UK-based. However, we remain vigilant regarding indirect risk, particularly where labour is provided through subcontracting, installation, site-based works or wider product supply chains.

4. Our commitment

ECOedge Ltd is committed to:

• Preventing forced labour, bonded labour, servitude and human trafficking
• Prohibiting child labour and all forms of labour exploitation
• Ensuring fair, lawful and ethical employment practices
• Ensuring freedom of employment and freedom of movement
• Acting promptly on any concern relating to exploitation or modern slavery
• Operating with integrity and transparency in our business relationships
• Expecting suppliers, subcontractors and delivery partners to uphold equivalent standards

We will not knowingly work with any organisation or individual involved in modern slavery, human trafficking, forced labour or exploitation.

5. Due diligence and supplier expectations

We take a proportionate, risk-based approach to due diligence. Depending on the nature of the supplier, subcontractor or delivery partner, this may include:

• Working primarily with UK-based professional suppliers and established commercial organisations
• Verifying company registration, credentials and relevant professional information
• Checking supplier capability, competence and reputation where appropriate
• Including compliance, ethical practice or modern slavery provisions in contracts where appropriate
• Expecting suppliers to comply with applicable employment, labour and human rights legislation
• Seeking confirmation that key suppliers operate ethical employment practices where reasonably practicable
• Reserving the right to investigate, suspend or terminate supplier relationships where exploitation concerns arise

ECOedge Ltd expects all suppliers, contractors and associated persons to act ethically and to take reasonable steps to ensure that modern slavery is not taking place within their own operations or supply chains.

6. Risk assessment

Given the nature of our business as a UK-based retrofit consultancy and delivery organisation, we assess the risk of modern slavery within our direct operations as low.

However, we recognise that risk may arise indirectly through:

• Labour used by subcontractors or installation partners
• Temporary, agency or site-based labour arrangements
• Material and product supply chains
• Third-party service providers
• Lower-tier supply chains not directly controlled by ECOedge Ltd

We review risk proportionately to the scale, nature and location of the engagement. Where a supplier or subcontractor presents a higher risk profile, we may request additional information or apply enhanced due diligence.

7. Employee and worker practices

ECOedge Ltd is committed to fair and lawful employment practices. We expect that all employees, workers, consultants and associated persons are:

• Engaged voluntarily and free to leave their employment or engagement in accordance with applicable terms
• Provided with clear written terms or contractual arrangements
• Paid lawfully and fairly for the work they undertake
• Treated with dignity, respect and without coercion, intimidation or exploitation
• Protected from abuse, harassment and unlawful discrimination

We do not tolerate threats, coercion, forced labour, withholding of identity documents, debt bondage, unreasonable recruitment fees or any practice that restricts a person’s freedom of movement or choice of employment.

8. Training and awareness

ECOedge Ltd promotes awareness of modern slavery risks among relevant employees, consultants and associated persons. Training and communication may cover:

• Recognising potential signs of modern slavery or exploitation
• Understanding supplier and subcontractor expectations
• Knowing how to report concerns
• Understanding protections for those who raise concerns in good faith
• Responsibilities under applicable modern slavery and employment legislation

We will continue to develop awareness and guidance as our business and supply chain evolve.

9. Reporting concerns

All employees, consultants, suppliers, subcontractors, clients and associated persons are encouraged to report any concern relating to modern slavery, human trafficking, forced labour or exploitation.

Concerns should be reported to:

Reports will be handled confidentially and investigated appropriately. ECOedge Ltd will not tolerate retaliation against anyone who raises genuine concerns in good faith.

If there is an immediate risk of harm, or if a person may be in danger, concerns should also be reported to the relevant authorities. The Modern Slavery and Exploitation Helpline can be contacted on 08000 121 700.

10. Responsibility and governance

The Directors of ECOedge Ltd are responsible for overseeing this policy and ensuring that proportionate measures are taken to manage modern slavery risk.

Responsibility includes:

• Maintaining this policy and reviewing it periodically
• Considering modern slavery risk within supplier and subcontractor relationships
• Ensuring reported concerns are reviewed and acted on appropriately
• Supporting awareness and proportionate due diligence
• Updating this policy to reflect changes in legislation, guidance, business activities or supply chain risk

11. Monitoring and continuous improvement

ECOedge Ltd is committed to continuous improvement in its approach to preventing modern slavery. We will keep our policies, supplier expectations and due diligence processes under review as our business develops.

This policy will be reviewed annually, or sooner if there are material changes to our business, supply chain, legislation or best practice.

12. Approval

This Modern Slavery and Human Trafficking Statement and Policy has been approved by the Directors of ECOedge Ltd.

Contact

For questions about this policy, or to report a concern, please contact:

Matt Carr – Director
matt@myecoedge.com