Modern Slavery Act | Good Energy

Approved by the Good Energy Group PLC Board on 19 March 2024

Good Energy exists to make it simple for people to generate, use and share clean energy and reduce their contribution to climate change. We supply 100% renewable electricity, carbon neutral green gas and provide services that support households and businesses to be greener.

Our approach to sourcing 100% renewable electricity, along with commitments such as being an accredited Living Wage employer, have led us to be named “best green electricity supplier” and one of the UK’s most ethical companies of the last 25 years by Ethical Consumer Magazine.

As a purpose-led business, we aspire to be as transparent as possible about our activities. You can read more about our business, how we source energy, how we look after our people and how we treat our customers at: goodenergy.co.uk and in our 2023 Annual Report.

Modern Slavery Act Statement

This statement is made on behalf of Good Energy Group plc, Good Energy Limited, Good Energy Gas Limited, Good Energy Works Limited and Good Energy Solar (South West) Limited in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023. It illustrates how we apply our principles and values and represents our public commitment to challenge and confront the use of forced, compulsory, trafficked or child labour within our supply chains.

At Good Energy, our customers are part of a community of homes and businesses that:

buy 100% renewable electricity and/or carbon neutral gas;
generate their own renewable power;
have heat pumps, solar panels and battery storage installed by us; or
invest in our renewable future as shareholders and/or bondholders.

Good Energy Group plc is listed on AIM and has three principal business areas:

Energy services: Services which help homes and businesses generate, use and share their own power.
Transport: Making it simple to own, drive, power and pay for an electric vehicle.
Renewable supply: Fairly priced 100% renewable electricity for committed green customers.

Our suppliers and partners

Our suppliers include large renewable electricity generators and our country-wide network of over 2,000 independent renewable generators and biogas producers. We also work with various electricity distribution network operators and independent gas transporters.

The majority of partners that we work with to deliver our services are either: suppliers of office-based technology including IT platforms, services and telephony systems; providers of services related specifically to the energy industry such as meter agents and energy traders; providers of renewable energy equipment for installation at customer premises, such as heat pumps, solar panels and related products; or strategic partners who share our aspirations and work with us in the mutual pursuit of a cleaner, greener future.

The principles that guide us

At Good Energy, we consider the inherent risk of encountering modern slavery within our business, supply chains and strategic affiliations to be low within the majority of markets that we operate. Nonetheless, it’s an issue that we take very seriously. We have adopted a zero-tolerance approach towards the use of forced, compulsory, trafficked or child labour within our organisation.

Good Energy operates according to its Code of Good Conduct and policy framework which describe the standards we expect to meet to ensure our business and supply chains are slavery free. These provide that we:

have robust, fair and balanced recruitment and employment practices in place that help us create an inclusive, diverse workplace; and
actively assess risks related to modern slavery as part of the approval process for all new or renewed relationships with delivery partners, suppliers and strategic affiliates.

We operate a supplier sustainability monitoring platform to give us the ability to:

consider the alignment of suppliers with our purpose and values;
keep focusing on incrementally improving our processes and procedures for procuring goods and services, including carrying out appropriate due diligence on suppliers and supply chains to assess modern slavery risks and, wherever possible, eliminate them;
set clear expectations that our delivery partners, suppliers, regulator and strategic affiliates meet the same high standards we set for ourselves, including through express contractual terms (and audit rights) wherever feasible; and
periodically assess the risk of modern slavery arising within our business and established supply chains to identify areas that would benefit from further investigation.

We annually review and where necessary update our Code of Good Conduct and policy framework and provide refresher training for those that require it or if there are specific updates. We also have a variety of ways to assess whether our Code of Good Conduct and policy framework are being followed, including internal audit and compliance assurance reviews.

Any risks and exceptions are reported to the Audit & Risk Committee. To date we haven’t had to report on any risks or exceptions related to modern slavery, although we have previously ended relationships with suppliers where we discovered that they were not meeting the standards required by other aspects of our Code of Good Conduct.

Polysilicon in solar photovoltaic modules

The acquisition of Wessex EcoEnergy Limited in June 2023 and JPS Renewable Energy Limited in February 2024 has involved Good Energy engaging with new supply chains for overseas manufactured products which come with an increased risk profile compared to our previous procurement activity.

Good Energy’s entire purpose is to drive the transition away from fossil fuels in a way that benefits both people and planet. Which is why we are gravely concerned about forced labour in the Xinjiang region of China, where a large portion of the world’s polysilicon used in solar panels is produced.

The use of panels containing materials sourced from this region represents a clear conflict with our guiding principles and modern slavery policy. As part of the acquisition of Wessex EcoEnergy Limited and JPS Renewable Energy Limited, we are currently reviewing all of their suppliers to understand the risk of purchasing from solar manufacturers identified as being at high risk of having supply chains containing materials from this region.

This is a significant supply chain challenge as transparency on material sourcing is often unavailable and, as a relatively small installer, Good Energy has little leverage to influence change. However, we are committed to being a positive force in the industry. We are engaging with the programs run by industry bodies Solar Energy UK and SolarPower Europe, to ensure that we only source products from partners who represent the lowest levels of risk and are themselves engaged in improving standards across the industry.

Whilst we are unable to state with 100% confidence that we have no products in our supply chain containing materials from Xinjiang, we are confident that our current suppliers meet our standards and commitments on modern slavery and our Code of Good Conduct.

Nigel Pocklington

Chief Executive Officer

19 March 2024