Modern Slavery Statement

Low Carbon Limited Modern Slavery and Human Trafficking Statement 2023

This voluntary statement is made on behalf of Low Carbon Limited pursuant to section 54 of the Modern Slavery Act 2015. This statement contains details of the steps that Low Carbon Limited takes to ensure that neither slavery not human trafficking take place in the business or supply chains of Low Carbon Limited.

Definition

According to the Modern Slavery Act 2015, the following definitions are encompassed within the term ‘modern slavery’;

• ‘Slavery’ is where ownership is exercised over a person
• ‘Servitude’ involves the obligation to provide services imposed by coercion
• ‘Forced or compulsory labour’ involves work or service extracted form any person under the menace of a penalty and for which the person has not offered himself voluntarily
• ‘Human trafficking’ concerns arranging or facilitating the travel of another with a view to exploiting them

Our structure, business and supply chains

Low Carbon is a privately-owned investment and asset management company committed to the development and operation of renewable energy power production at scale. Low Carbon invests into both renewable energy developers and projects across a range of renewable energy technologies including solar, wind, waste to energy, energy storage and energy efficiency. The Board of Directors of the company comprises 2 executive and 2 non-executive directors. The Board have oversight of the Modern Slavery and Human Trafficking statement development, implementation and enforcement, with ultimate responsibility sitting with the company Chief Executive. The Low Carbon group comprises over 50 companies.

Low Carbon’s supply chain network supports the production of our renewable energy projects, and our day-to-day business operations. Low Carbon is committed to engaging ethical suppliers that provide high quality products and services. As a minimum, we expect both ourselves and our suppliers to comply with all applicable local laws and regulations providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically and being environmentally responsible where practical.

Policies

Low Carbon recognises both the business imperative and moral obligation to carry out its business activities in a socially responsible and environmentally sustainable manner, with due consideration given to human rights. Various policies have been formalised to demonstrate our commitment to this.

Our Sustainable Sourcing Policy sets out the social, ethical and environmental standards that we use internally to make office procurement decisions and also sets out the commitments that Low Carbon’s suppliers are expected to adhere to. The policy references human rights, fair labour and anti-corruption.

In relation to our employees, Low Carbon’s aim is to attract and retain professionals who share a commitment to our values. Our employees are hired in accordance with robust and fair recruitment procedures and are expected to adhere to Low Carbon’s Code of Ethical Business Conduct which reflects our commitment to acting ethically and with integrity in all our business relationships. In the unlikely event that misconduct is uncovered, including concerns around modern slavery, employees are encouraged to report the misconduct to senior management. Additionally, Low Carbon’s Whistleblowing policy provides guidance to employees on how to raise concerns.

Due Diligence

Where possible Low Carbon builds long standing relationships with its third-party service providers and suppliers and places obligations on these suppliers to comply with all applicable laws, which, where relevant, would include compliance with the Modern Slavery Act.

Low Carbon Investment Management Limited (a subsidiary of Low Carbon Limited) is regulated in the UK by the Financial Conduct Authority (FCA) and is therefore required to have appropriate systems and controls in place to operate a prudent and well-managed business. These controls are also implemented at the Low Carbon Limited level to ensure the whole business is operating responsibly.

As an FCA regulated business, Low Carbon Investment Management Limited is under an obligation to carry out initial and ongoing know your customer and anti-money laundering checks on third parties that it enters into agreements with for goods and services. These controls are also implemented at the Low Carbon Limited level. We believe that this due diligence provides us with an understanding of third parties with whom we enter into arrangements with for the provision of services and suppliers.

Training

We believe that the training of people is an effective way to raise awareness of the issues around modern slavery. We make our Code of Ethical Business Conduct, Sustainable Sourcing Policy and Whistleblowing Policy available on the staff intranet and update these regularly.