Anti-slavery and human trafficking statement

Organisational structure and supply chains

The Fulcrum Group of Companies includes Fulcrum Utility Services Limited and several associated companies in the United Kingdom and Cayman Islands. The Group also includes Fulcrum Utility Investments Limited, Fulcrum Infrastructure Services Limited, Fulcrum Pipelines Limited, Fulcrum Electricity Assets Limited, Fulcrum Group Holdings Limited, Fulcrum Smart Metering Limited, Dunamis Infrastructure Services Limited and Maintech Power Services Limited.

Fulcrum is the UK’s market leading independent energy and multi-utility infrastructure and services provider.

We use a wide variety of local, national and international suppliers to source goods, services and equipment for the operation of our business. In particular, we work with plant and material suppliers as well as engineering subcontractors. We recognise that the nature of our supply chain can make checking for illegal activity challenging. However, as explained below, there are a number of checks and safeguards we will put in place to reduce the risk of modern slavery and human trafficking occurring in our supply chain.

Our policy on modern slavery and human trafficking

We have an absolute zero tolerance policy to modern slavery. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place chains.

We understand that modern slavery encompasses:

Forced work, through mental or physical threat;
Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
Being dehumanised, treated as a commodity or being bought or sold as property; and/or
Being physically constrained or to have restriction placed on freedom of movement.

Commitment

We acknowledge our responsibilities under the Modern Slavery Act 2015 and we are committed to preventing slavery and human trafficking within our businesses and our supply chains. We understand that this requires an ongoing review of our internal practices and continual due diligence of our supply chains.
As part of our zero tolerance policy, we will not enter into business, and will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude or forced or compulsory labour.
We will strive to ensure that no labour provided to us in the provision of our services is obtained by means of slavery or human trafficking. We will strictly adhere to the standards required of us in relation to our responsibilities under relevant employment legislation in the United Kingdom.

Our due diligence processes

To ensure that this policy is adhered to, we will introduce the following processes:

Conducting risk assessments to identify which parts of our businesses and supply chains are most at risk from modern slavery;
Engaging with all our major suppliers to convey the contents of this policy to them, and asking them to confirm they have read and understood our policy and will adhere to it;
Surveying our suppliers to establish what steps, measures and practices they have implemented to prevent modern slavery occurring in their organisations;
Introducing contractual provisions into our supply contracts where appropriate to confirm that our suppliers adhere to and accept our policy; and
Discontinuing business with any first-tier supplier found to have been involved in modern slavery.

To facilitate these processes, we maintain an accurate supplier list including key contact details. We also encourage the use of our whistleblowing policy to report any concerns regarding modern slavery and we will investigate any complaints thoroughly.

Our effectiveness in combating slavery and human trafficking

As our attitude to modern slavery is zero tolerance, we have not adopted any key performance indicators as any instance of modern slavery or human trafficking in our supply chain would be an unacceptable breach of our policy.

However, we will monitor our internal compliance with this policy by recording:

Which of our suppliers have read and agreed to adhere to our policy;
Which of our suppliers have implemented their own policies and procedures with prohibitions against modern slavery;
Which of our suppliers place obligations on their own employees to comply with their modern slavery policies;

Where our suppliers do not yet have modern slavery policies and procedures in place, where appropriate we will ask for confirmation as to the likely timescale for their introduction.

Responsibility for our policy

Our Chief Executive Officer is responsible for compliance with this policy, and is the person to whom all queries or concerns regarding modern slavery should be addressed. The Compliance Team will undertake an annual review of our obligations towards eradicating modern slavery within our organisation and supply chains.

Training

All of our employees are instructed to read this policy and confirm understanding and agreement to comply with our policy to help in the identification and prevention of modern slavery. This policy will be publicised internally to raise awareness. New employees will receive training on this policy as part of their induction process. In addition, all of our employees responsible for compliance or procurement will be trained on the requirements of this policy.

Risk Assessment and Management

Fulcrum has a risk-based methodology in place to ensure its suppliers comply with The Modern Slavery Act 2015. Risks are identified as being low, due to our ‘well-known’ supplier base and the industry sectors in which we are they operate in. It is also recognised that risks are lower for UK employees due to the legislative requirements. The risk assessment process is managed by The Supply Chain Manager and Head of Compliance who also has responsibility for ensuring annual or ad-hoc reviews and audits of all suppliers is undertaken.

Review

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and applies to all companies within and associated to The Fulcrum Group of Companies (“the Group”). It will be reviewed for each financial year.

Effectiveness

Supply chain risk assessments are undertaken, and no issues have been identified during the onboarding process or scheduled audits and reviews.