Modern Slavery and Human Trafficking Statement


1.1. The Modern Slavery Act 2015 and the Human Trafficking and Exploitation (Scotland) Act 2015 recognises slavery, servitude, forced or compulsory labour and human trafficking as a crime and a violation of fundamental human rights. We are not required by the governing legislation to publish a Modern Slavery and Human Trafficking Statement but do so voluntarily to underscore our commitment to ethical business practices.

1.2. As a new company, this Statement summarises the actions and activities that will be carried out by ETZ Ltd to show our commitment to ethical trading principles, and to explain the steps we will take to identify risks and tackle modern slavery and human trafficking in our business and supply chains. We will review and publish a statement explaining the steps we have taken annually on a voluntary basis.

2. ETZ’s Purpose

2.1 ETZ Ltd is a private sector led, not for profit company, which was incorporated in April 2021 to drive forward the vision of transforming North East Scotland to become a global leader in energy transition activities and a net exporter of energy transition technologies, services, and skills.

3. ETZ’s Statement in relation to slavery and human trafficking

3.1 ETZ Ltd is committed to conducting its activities fairly, honestly and with the highest standards of integrity, in accordance with applicable law. ETZ Ltd does not tolerate slavery or human trafficking in any part of its business. This statement sits alongside ETZ Ltd’s Equality, Whistleblowing, Business Ethics and Fair Work Framework Policies.

4. ETZ’s due diligence processes in relation to its business

Considering supply chains that carry risk

4.1 ETZ Ltd will appropriately evaluate which of its supply chains may be at higher risk of slavery or human trafficking. Regard will be given both to supply chains originating outside the UK, and to areas identified as higher risk such as construction, security, and cleaning sectors.

Appropriate supplier arrangements

4.2 ETZ Ltd fully complies with regulatory and legal obligations with respect to procurement of goods and services and will issue tenders for the significant majority of its goods and services. ETZ Ltd aims to build relationships with trusted suppliers with a reputation for excellence and will make clear its expectations of business behaviour to suppliers.

Communicating expectations and seeking commitments

4.3 For partners, collaborators and contractors, ETZ Ltd will seek their commitment that they comply with the same fundamental principles of not tolerating slavery or human trafficking in any part of their business.

Due Diligence on key partners and suppliers

4.4 Appropriate due diligence will be carried out on new partners, collaborators and suppliers.

Record Keeping

4.5 ETZ maintain appropriate records in relation to the supply chain of all goods and services used for its activities.

Further steps

4.6 ETZ Ltd seeks to continually ensure that its business is free from slavery and human trafficking. As such, ETZ Ltd’s Audit & Risk Committee will [have oversight of and assess, as appropriate]:

i. identification of suppliers at greater risk of slavery and human trafficking

ii. how best to communicate expectations and seek commitments from relevant suppliers and

iii. introducing suitable clauses in future contracts seeking to ensure supplier compliance with the Modern Slavery Act 2015.

5. Training and Awareness for the ETZ Team

5.1 Those ETZ Ltd Team members closely involved in the procurement process for suppliers and staff recruitment will receive appropriate training on ETZ Ltd’s Slavery and Human Trafficking Statement and procedures.

6. Approval

6.1 This statement is made on a voluntary basis for the financial year ending 31 March 2023 and was approved by the Board of Directors, who met on 27 June 2023.

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