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Modern Slavery Statement

Introduction

The United Kingdom’s Modern Slavery Act 2015 (the “Act”) requires commercial organisations operating in the United Kingdom, providing goods or services and having an annual turnover above £36m to produce a statement setting out the steps they are taking to address and prevent the risk and/or occurrence of modern slavery in their operations and supply chains. This statement is made pursuant to section 54 of the Act and relates to the financial year ending 28 March 2018 (the “Financial Year”).

Bord na Móna PLC is Ireland’s leading environmentally responsible integrated utility service provider encompassing electricity, heating solutions, resource recovery, horticulture and related services. Bord na Móna PLC is incorporated in Ireland and has subsidiaries both nationally and internationally that supply goods and services both in Ireland and abroad, including the United Kingdom (together the “Bord na Móna Group”).

Bord na Móna is subject to the Act as it has UK and Irish subsidiaries providing goods within the UK and has an annual global turnover in excess of £36m. As best practice and to show the Company’s commitment to tackling modern slavery, the requirements of the Act will be implemented across the entire organisation and not just the subsidiaries that are affected by the Act.

 

Commitments

The Bord na Móna Group has always taken pride in giving back to local communities through active and direct involvement. This ethos is extended to international communities where the Bord na Móna Group has direct dealings, whether through itself, supply chains, suppliers and/or contractors.

Bord na Móna Group is committed to upholding and respecting all aspects of human rights. This is enforced at both the parent company level and at the subsidiary level.

 

Actions

Over the relevant Financial Year, Bord na Móna Group has reviewed, considered and initiated the process of complying with the Act. To begin with, the Group has identified horticulture and biomass as the areas most at risk for human trafficking and slavery as they both do business with suppliers in “at-risk” countries. Procurement and Legal were also identified as functions which would need to assist in ensuring compliance with the Act due to the nature of the services they provide.

Over the Financial Year, the following actions have been taken:

  • The Legal department has included a clause in its Requests for Tenders which requires tenderers to adhere to the provisions of Council Directive 2011/36/EU of 5 April 2011 on preventing and combating trafficking in human beings and protecting its victims. This clause has also been inserted into all contracts for services.
  • The biomass business unit has robust due diligence systems in place which are audited and certified by an independent monitoring organisation to, among other matters, minimise the risks of instances of modern slavery in the Bord na Móna Group and its supply chain.
  • A Supplier Code of Conduct has been amended to include a modern slavery clause. It is undergoing the approvals procedure. All suppliers will be asked to adhere to this Code.
  • The Procurement department has amended its pre-qualification questionnaire to include pass/fail questions in relation to human trafficking. This is issued as part of the sourcing exercises and tender processes, prior to any contracts being entered into.

The Bord na Móna Group is continuing to work on various measures to ensure compliance with the Act. The aim is to have the following measures in place over the next financial year:

  1. Approve and communicate a Modern Slavery Policy to provide transparency to employees as to the Group’s approach and commitment to protecting against instances of modern slavery and human trafficking.
  2. Put in place due diligence mechanisms for all business units to utilise to ensure compliance with the Act.
  3. Formally approve the draft Supplier Code of Conduct (including a modern slavery clause) which suppliers will be asked to sign up to prior to doing any business with the Bord na Móna Group.
  4. Organise and set up training sessions for relevant employees to understand, recognise and report instances of modern slavery.

This Modern Slavery Statement will be published on the Bord na Móna website and will be updated on an annual basis as Bord na Móna continues to work towards preventing occurrences of modern slavery both within the Bord na Móna Group and across the Group’s supply chain.

 

____________________________

Michael Barry

Managing Director of

Bord na Móna PLC

 

Please find signed version of the Modern Slavery Statement Here.