This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 2016. All commercial organisations that supply goods or services and have a turnover of £36 million or more are required to produce a slavery and human trafficking statement and to publish it on their website.
Flowgroup plc are committed to taking steps where reasonably practical to ensure that modern slavery and human trafficking is not taking place in any part of its own business and in any of its supply chains.
Organisational structure and supply chains
Flowgroup plc and its subsidiaries deliver alternative and efficient energy products and supply home energy. Flowgroup plc is the Group’s ultimate parent company and is incorporated in the UK. The vast majority of the group’s supply chain is resourced from within Europe. Our businesses are: • Flow Products – Smart Home Services sourcing and referring products from partners • Flow Energy – energy supply and services Our supply chains include: • The procurement of electricity and gas; and • The procurement of goods and services to support our business (e.g.outbound sales)
Relevant policies and further steps taken since 1 January 2017
The organisation operates a whistleblowing policy and a supplier code of conduct. The Group has identified that it needs to ensure that slavery and human trafficking is explicitly dealt with within these policies. We have commenced a full review of our supply chains. Monitoring and training activities will be undertaken across the business and its supply chains.
Our policies on slavery and human trafficking
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 business is committed 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 anywhere in our supply chains. A formal policy for Anti-slavery will be adopted in the near future and relevant policies such as our whistleblowing policy will be reviewed.
Flowgroup undertakes due diligence when considering taking on new suppliers , and regularly reviews its existing suppliers. As part of our initiative to identify and mitigate risk we are planning to implement a formal Anti Slavery Policy as part of our supplier code of conduct which will codify our current processes and procedures. This will include: • Identify and assess potential risk areas in our supply chains • Mitigate the risk of slavery and human trafficking occurring in our supply chains • Monitor potential risk areas in our supply chains • Protect whistle blowers
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we are putting in place a supply chain compliance programme.
Our effectiveness in combating slavery and human trafficking
We have informally reviewed the group and do not consider that there are any instances of slavery or human trafficking taking place within our business, however at 31 December 2016 we had not commenced the review of our supply chains in line with the formal Anti Slavery Policy.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business we require our Senior Management team and HR staff to be aware of the occasions where modern slavery and human trafficking could take place. Formal training will be given in the near future. Flow Group plc: Tony Stiff (Group CEO)
Date: 2nd August 2017 This statement has been approved by the organisation’s board of directors, who will review and update it annually.