Anti-Slavery and Human Trafficking Policy

  1. Policy Statement

Spire Renewables Limited is committed to conducting business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery and human trafficking and are committed to ensuring that these practices do not occur within our business operations or supply chain.

We recognise our responsibilities under the Modern Slavery Act 2015 and support the protection of human rights in all aspects of our business.

We expect the same high standards from our employees, suppliers, subcontractors, installers, consultants and all other business partners.

 

  1. Scope

This policy applies to:

  • All employees of Spire Renewables Limited
  • Directors and officers
  • Temporary and agency workers
  • Contractors and consultants
  • Suppliers and subcontractors
  • Any person acting on behalf of the company

 

  1. Our Business

Spire Renewables Limited supplies and supports renewable heating, energy efficiency and related building services products and solutions throughout the United Kingdom. We work with manufacturers, distributors, installers, contractors, homeowners and service providers and are committed to ensuring ethical business practices across our operations and supply chain.

 

  1. Our Commitments

Spire Renewables Limited will:

  • Operate in compliance with all applicable employment and human rights laws.
  • Prohibit all forms of forced labour, bonded labour, child labour, slavery, servitude, and human trafficking.
  • Ensure employees are employed voluntarily and are free to leave employment in accordance with their contractual terms.
  • Promote fair treatment, equality, and respect in the workplace.
  • Assess and manage risks of modern slavery within our supply chain.
  • Take appropriate action where concerns are identified.

 

  1. Supply Chain Standards

We expect our suppliers, subcontractors and business partners to:

  • Comply with all applicable employment, labour, and human rights legislation.
  • Provide safe and healthy working conditions.
  • Pay wages and benefits in accordance with applicable laws.
  • Prohibit the use of forced, compulsory, trafficked, or child labour.
  • Maintain policies and procedures that support ethical employment practices.

Where appropriate, we may request suppliers to confirm their compliance with anti-slavery legislation and ethical sourcing requirements.

 

  1. Due Diligence

To minimise the risk of modern slavery, Spire Renewables Limited may:

  • Evaluate suppliers before entering into commercial relationships.
  • Review supplier practices where risks are identified.
  • Seek assurances regarding labour standards and employment practices.
  • Monitor and review supply chain risks periodically.

 

7. Our Organisation, Structure and Supply Chains

Spire Renewables Limited is a private limited company operating throughout the United Kingdom. The company supplies and supports renewable heating, energy efficiency and related building services products and solutions to domestic and commercial customers.

Our supply chain includes manufacturers, distributors, wholesalers, logistics providers, subcontract installers, contractors, consultants and service providers. We recognise that modern slavery risks can exist at various levels of domestic and international supply chains and are committed to taking reasonable steps to identify and address such risks.

 

8. Risk Assessment and Management

Spire Renewables Limited regularly considers the potential risk of modern slavery and human trafficking within its operations and supply chains.

Areas where risks may arise include:

• Procurement of products and materials from multi-tier supply chains.
• Engagement of subcontractors and temporary labour providers.
• Suppliers operating in sectors or geographical regions that may present elevated labour exploitation risks.

To assess and manage these risks, the company may:

  • Review supplier information prior to engagement.
  • Consider supplier location, sector and labour practices as part of supplier selection.
  • Request confirmation of compliance with employment, labour and human rights legislation.
  • Investigate any concerns or allegations relating to labour standards.
  • Review supplier relationships where concerns are identified and take corrective action where appropriate.

 

9. Effectiveness and Performance Monitoring

Spire Renewables Limited monitors the effectiveness of its approach to preventing modern slavery through appropriate measures, which may include:

  • Completion of supplier due diligence reviews.
  • Number of modern slavery concerns reported and investigated.
  • Number of supplier compliance confirmations obtained.
  • Completion of staff awareness and training activities.
  • Periodic reviews of company policies and procedures.

The Directors review any reported concerns and assess whether additional controls or actions are required to strengthen the company’s approach to preventing modern slavery.

 

10. Training and Capacity Building

Spire Renewables Limited is committed to ensuring that employees and relevant personnel understand the risks associated with modern slavery and human trafficking.

Training and awareness activities may include:

  • Induction information for new employees.
  • Periodic policy awareness briefings.
  • Guidance on recognising indicators of forced labour, human trafficking and exploitation.
  • Information on reporting concerns and whistleblowing procedures.
  • Updates where legislative or business requirements change.

Relevant employees involved in procurement, supplier management and contractor engagement will receive additional guidance where appropriate to support the identification and management of modern slavery risks.

Modern Slavery Governance

Responsibility for implementing and monitoring this policy rests with the Directors of Spire Renewables Limited.

The Directors will review this policy annually and oversee actions taken to identify, assess and manage modern slavery risks throughout the business and its supply chains.

 

11. Reporting Concerns

Any employee, contractor, supplier, or stakeholder who suspects modern slavery or human trafficking is encouraged to report their concerns immediately.

Concerns should be reported to:

The Directors
Spire Renewables Limited
Email: [email protected]

All concerns will be investigated appropriately and confidentially where possible.

 

12. Protection for Those Raising Concerns

Spire Renewables Limited will not tolerate retaliation against anyone who raises a concern in good faith regarding suspected modern slavery or human trafficking.

 

13. Training and Awareness

The company will ensure that relevant personnel understand:

  • The risks associated with modern slavery.
  • How to identify warning signs.
  • How to report concerns appropriately.

 

14. Breaches of this Policy

Any employee found to be in breach of this policy may be subject to disciplinary action, up to and including dismissal.

Suppliers, contractors, or business partners who fail to comply with this policy may have their business relationship with Spire Renewables Limited reviewed and, where appropriate, terminated.

 

15. Review and Approval

This policy will be reviewed annually by the Directors of Spire Renewables Limited to ensure it remains effective and compliant with legal requirements.

Approved by: Director, Spire Renewables Limited

Date: 4 June 2026

Next Review Date: June 2027