Modern Slavery Statement

npower Modern Slavery and Human Trafficking Statement 2021

1. Introduction

npower is committed to ensuring that modern slavery is not present within its business and supply
chains. This is npower's fifth slavery and human trafficking statement and sets out the actions we have taken
during our financial year 2020 (and which continue into 2021) to operate processes to support the
elimination of slavery and human trafficking risk.

THIS DOCUMENT REPRESENTS THE SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR EACH OF
THE FOLLOWING COMPANIES WITHIN THE NPOWER GROUP OF COMPANIES:

  • Npower Group Limited (and the following companies, all being subsidiaries of that company)
  • Npower Limited
  • Npower Northern Limited
  • Npower Commercial Gas Limited
  • Npower Gas Limited
  • Npower Direct Limited
  • Npower Yorkshire Limited
  • PS Energy UK Limited

collectively ("npower" or the "npower companies", "we", "our").
During 2019, as part of the majority acquisition by E.ON SE of innogy SE (then npower's ultimate
parent company), npower became part of the E.ON SE Group of companies. On 2 June 2020, E.ON SE
acquired 100% ownership of innogy SE (and npower). Since then, npower has become subject to the
E.ON SE group's Code of Conduct and is part of the E.ON compliance management system.
Npower Direct Limited is now part of the E.ON UK plc group so is included for the period of npower
ownership in 2020 (until 2nd June 2020). As this company is no longer owned by npower, it is not a
signatory to this Statement and will sign E.ON UK group's Statement.

2. Background to our supply chain

npower is a British energy company and is currently very close to having completed migrating its 3
million residential and small business gas and electricity customers into the E.ON Next portfolio, and
combining its industrial and commercial customer and related services business (I&C) with that of
E.ON UK. As part of this transition, we are working to wind down npower's operational activities and
infrastructure and, as a result, our supply chain.

In 2020 npower had a supply chain spend of circa £370m per annum with around 500 suppliers. Of our
spend 95% sits within the service sector and 80% of that spend sits within our top 10% of suppliers.

We have a diverse supply chain that spans a wide variety of goods and services from suppliers that are
both national and international. As such, npower requires human rights to be respected and
environmental standards to be maintained throughout the entire supply chain. To this end, npower
has introduced various policies and management processes.

3. E.ON Policy relating to Modern Slavery and Human trafficking

npower's approach to business reflects the wider E.ON group's commitment to acting ethically and
with integrity in all business relationships and to implementing processes, policies and controls that
seek to eliminate slavery and human trafficking in all business and supply chains.
We support the ten principles of the United Nations Global Compact, including the protection of
internationally proclaimed human rights and the elimination of all forms of forced and compulsory
labour.

For further information about npower's policies and management processes and responsible business
practices, please see below table:

E.ON Code of Conduct

E.ON Code of Conduct
Innogy Code of Conduct
The E.ON Code of Conduct has applied in npower since 2nd June 2020 and
reflects the above principles and defines how we conduct our business.
There are three primary objectives to our Code of Conduct:
  • It encourages all employees to take responsibility for their own actions and supports employees with the necessary guidance to meet this
  • It defines the goals and principles that guide our business activities
  • It sets the standards for collaborating with contractual partners and provides a common basis on which to build contractual relationships.
Prior to June 2nd 2020 npower was subject to the Innogy group Code of Conduct.
E.ON Human Rights Policy The E.ON human rights declaration, sets out the principles of human rights diligence in our activities towards our employees and towards our partners and suppliers. The declaration includes in particular a commitment to
freedom of association and a strict rejection of forced, compulsory and child labour. We also demand the same from our suppliers.
The Executive Board of E.ON SE is responsible for ensuring that all business activities of the company are in accordance with human rights.
Internal HR Policy Our HR policies, processes and practices for employees, agency workers or
fixed term contractors adopt the core values of our Code of Conduct with all policies detailing npower's approach to modern slavery. Our key HR policies
include but are not limited to:

Speak Up Policy - we encourage all workers to report any concerns related to our direct activities or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our Speak
Up Policy is designed to make it easy for workers to make disclosures without fear of retaliation. Employees or others who have concerns can use our confidential helpline and email operated by an external provider.**

Grievance/Bullying and Harassment - these policies are designed to enable employees to raise and resolve personal concerns that are affecting them, including those relating to slavery or human trafficking.

Disciplinary Procedure - our Disciplinary Procedure provides a mechanism for dealing with matters of misconduct or breach of our group's applicable Code of Conduct which relate to slavery or human trafficking.
Procurement Policy * The Innogy Business Services UK*** Procurement Policy sets out our standards and expectations and forms the baseline from which we seek to achieve compliance and drive continuous improvement in our supply chain.
Our Procurement Policy embeds the ten principles of the United Nations Global Compact and the requirements of the UK Modern Slavery Act 2015. A key element to securing compliance in relation to modern slavery risk is our
Sustainability Procurement Policy which is the main vehicle for achieving contractual compliance.
Sustainability Procurement Policy * The Innogy Business Services UK Sustainability Procurement Policy captures our commitment, and the commitment of those with whom we do business, to the respect of and adherence to the principles of Sustainability, Corporate Responsibility, Human Rights, Labour Standards, Anti-Corruption, Respect for the Environment and Health & Safety, as well as the commitment against all forms of modern slavery and human trafficking.

* Whilst some of the above documentation refers to Innogy rather than E.ON, this is due to the fact that E.ON currently haven't changed the npower policies and practises relating to these documents, this may happen as we progress through 2021 but still remains the same currently.
** npower's Speak UP Policy was replaced in January 2021 with a new Whistleblower Policy together with a new whistleblower hotline and website but the broad effect of the Policy is the same.
*** Innogy Business Services UK Limited (IBS UK) is the internal service company used by the npower group for providing corporate services and activities such as procurement. IBS UK has issued its own Modern Slavery And Human Trafficking Statement.

4. Due Diligence Processes For Slavery And Human Trafficking

Procurement Contracts
On entering into any agreement placed by IBS UK Procurement, the Supplier agrees to comply with the values set out in the Sustainability Procurement Policy in addition to the law and, in particular, to support and enact the principles established in the Global Compact Initiative of the United Nations in the areas of Human Rights, Labour Standards, the Environment and Anti-Corruption, as set out at www.unglobalcompact.com

Procurement Due Diligence Process
Pre-Qualification – All suppliers taking part in tender exercises undergo a mandatory pre-qualification process that evaluates their compliance with the Modern Slavery Act and explores the policy and practices in place to ensure that modern slavery and human trafficking is not taking place in their own business and supply chains. Failure to pass the assessment will result in the supplier being excluded from the tender process. We will then liaise with the supplier to discuss how we can support them in
making improvements so that they can be invited to take part in future procurement exercises.

In defining a list of tenderers, we reserve the right to exclude any supplier that appears on the World Bank Sanctions Lists and the EU/UN Sanctions Lists. Once a supplier is appointed, our Accounts Payable team checks these lists on a regular basis to identify any supplier subsequently added, in which case an investigation is carried out. Our due diligence process excludes procurements of low risk and those not of material value.

Risk identification, mitigation and monitoring - Risks relating to modern slavery are identified and
assessed at pre-tender and post tender stage, and are mitigated in our contracts. As appropriate, risks
are monitored throughout the life of the contract.

5. Our Effectiveness In Combating Slavery And Human Trafficking

We believe that effective management of the risks of modern slavery and human trafficking within the supply chain is effectively managed through the pillars of: good governance, risk management, team development and collaboration and close working with our supply chain partners.

Good Governance – Good governance of our supply chain starts with selecting the right suppliers to work with from the outset. Our Pre-Qualification Process was launched in September 2018 and in 2019 the process was extended to apply evaluation of all suppliers. In 2020 this continued to be applied to all areas of supplier evaluation. We evaluate potential suppliers on the basis of their ability to demonstrate robust processes in the management of modern slavery and human trafficking. This means, that every supplier must complete this process, which requires the suppliers to pass a compliance check and accept our Supplier Code of Conduct. Where suppliers fail to demonstrate adequate provision we exclude them from the process.

We share our concerns with all excluded suppliers and offer to support them in addressing our issues so that they might be more successful in future procurement exercises.

Risk Management – As npower migrates customers to E.ON UK, combines its I&C business with its equivalent in E.ON UK and closes down suppliers in line with the wind down project, we continue to incorporate risk identification and assessment for individual tender exercises in our day to day procurement process. We have maintained a variety of actions to deepen our business relationships with suppliers and improve our ability to assess risks along our supply chain, especially in the area of corporate social responsibility. These actions included audits conducted at its suppliers' facilities. Identified risks are monitored and appropriate action taken where identified risks exist.

We continued to trial a programme of Strategic Supplier Health checks through 2020. Through these we were able to conduct a deep dive analysis into some of our key suppliers, and evaluate (amongst other things) their effectiveness at managing modern slavery risk in practice. A selection of strategic suppliers have undergone a desktop assessment against a range of key issues including modern slavery compliance. Any resultant concerns have undergone further investigation/potential site audits
with the supplier.

Team development – npower continued to provide training to both its new and existing supply chain employees with the aim of enhancing knowledge of all sustainability issues, including social welfare and human rights topics. We continue to operate within the guidelines and ethical standards set out by the Chartered Institute of Procurement and Supply (CIPS). These set out the values, business culture and practices that organisations must demonstrate such as:

  • committing to conducting business with respect, honesty and integrity
  • eradicating unethical business practices including bribery, fraud, corruption and human rights abuses, such as modern slavery
  • mandating education and training of all staff
  • taking steps to prevent, report and remedy unethical practices

We operate in compliance with the Ethical Code of Conduct of CIPS as we believe that it encapsulates our business values and provides us with a standard against which we can create and apply process for the management of potential modern slavery risks.

On an annual basis, the procurement team complete in-house compliance training. We have also worked on our induction process to ensure that all new members of the team gain an understanding of the risks of modern slavery and human trafficking in our supply chains. We also provide awareness training for new procurement staff.

Collaboration and close working with our supply chain partners. We recognise that our sphere of influence in the supply chain reduces as we move down the tiers of our supply chain. To gain greater confidence we believe that we need to work with our key supply chain partners to gain control further down the tiers of our supply chain.

Our strategy is to continuously work on our collaboration with our key partners through both our bilateral engagements and through more joint working across the whole supply chain.

6. Tracking Our Performance

Our key performance indicators (KPIs) measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.

We use the following to monitor the effectiveness of the steps that we are taking:

  • Monitoring the frequency of internal escalation in relation to potential suppliers involved in any tender process. During this statement period (2020), no supplier questionnaire responses were referred to the Compliance Team for assessment.
  • Monitoring the instances of current suppliers found to be in breach of requirements relating to the Modern Slavery Act. During this statement period, no suppliers were identified as being at risk of a potential breach of the Innogy Code of Conduct and therefore no investigations were carried out.
  • Monitoring the number of new staff who receive training in relation to the requirements of the Act. During this statement period, there were no new starters.

7. What Measures Will We Take In 2021?

During 2021 we will:

  • Deploy current procurement policy and process in order to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.
  • Continue to operate in compliance with the CIPS Ethical Code of Conduct for 2020 to 2021 in consultation with E.ON
  • Align with E.ON procurement policy and process as directed

8 Authorisations

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement of each of the Npower Companies for the financial year ending 31st December 2020.

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Director: Simon Stacey
npower Limited
Date: 26 May 2021

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Director: Simon Stacey
npower Northern Limited
Date: 26 May 2021

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Director: Jason Scagell
npower Commercial Gas Limited
Date: 26 May 2021

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Director: Simon Stacey
npower Gas Limited
Date: 26 May 2021

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Director: Simon Stacey
npower Yorkshire Limited
Date: 26 May 2021

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Director: David Winter
PS Energy UK Limited
Date: 26 May 2021

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Director: Simon Stacey
npower Group Limited
Date: 26 May 2021

 

 

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