Modern slavery and human trafficking statement

Statutory statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Flow Energy Ltd’s slavery and human trafficking statement for the financial year ending 2017. 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.

Introduction

Flow Energy Ltd is 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

Flow Energy Ltd supplies home energy and is incorporated in the UK. Our supply chains include: • The procurement of electricity and gas; and • The procurement of goods and services to support our business (eg/ outbound sales)

Relevant policies and further steps taken since 1 January 2017

The organisation operates a whistleblowing policy and a supplier code of conduct. Flow Energy Ltd 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.

Due diligence

Flow Energy Ltd 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 our business and do not consider that there are any instances of slavery or human trafficking taking place within our business. However at 31 December 2017 we had not commenced the review of our supply chains in line with the formal Anti Slavery Policy.

Training

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.