Modern Slavery Act 2015 Statement

1. Introduction

This statement is made pursuant to section 51(4) of the Modern Slavery Act 2015 and sets out the steps that IM Power PLC has taken to ensure that slavery and human trafficking are not taking place within the group or its supply chains. The statement covers IM Power PLC as well as all subsidiary companies, including but not limited to IM Power Bangladesh, Bangla Express, Bangla Freight Lines, IM Power Namibia, Namibia Refining Company.

2. About our Business

IM Power PLC provides financing and engineering services for the construction, development and operation of large-scale industrial, energy and transportation projects. Our central corporate division provides human resources, financial controls, compliance, technology, marketing and legal services to our service divisions and subsidiaries.

We operate a zero-tolerance approach to modern slavery and human trafficking. We expect all of our directors, employees, contractors and suppliers to adhere to and comply with our zero-tolerance policy. We ensure that robust procedures are in place to identify and address any risks of modern slavery or human trafficking. These policies and procedures and reviewed annually and approved by our management board.

3. Service Delivery

As part of the development of industrial, energy or transportation infrastructure projects, frequent site visits are made. During these visits, our employees, sub-contractors or partners may witness or suspect the presence of modern slavery, abuse, coercion or human trafficking. It is crucial that if that occurs, these individuals are able to report concerns without delay. We have policies in place (Safeguarding, Whistleblowing) that enable them to do so.

4. Supply Chains

Our supply chains and global and diverse and include raw industrial materials, fuel, machine and plant parts, human resources, technology, design services, architecture services, financial services, vehicles and office equipment. We have implemented a procurement strategy to ensure that our business operations are ethical, effective and contribute to the local economy.

We expect our sub-contractors, partners and suppliers to take appropriate steps to ensure there is no modern slavery or human trafficking within their businesses or supply chains. We also include in our contracts the right to terminate agreements if human trafficking or modern slavery is found to be occurring.

We expect our suppliers and sub-contractors to pay their employees fairly and promptly. Given the global nature of our business we expect that employee pay is benchmarked against a local standard for the specific industry.

5. Policies

We have implemented a number of policies which are designed to identify and address modern slavery and human trafficking issues. These include Whistleblowing, Modern Slavery, Anti-Bribery, Supplier Code of Conduct and Safeguarding. These policies are reviewed and updated annually.

6. Effectiveness and Review

Modern slavery and human trafficking issues would be identified as part of our annual internal audit program. We will continue to review the effectiveness of our policies on a regular basis.

7. Further Steps

We intend to take the following steps to combat modern slavery and human trafficking:

Continue to review and update policies and procedures.
Update our procurement policies to reflect our commitment to sustainable development.
Review and update staff training programs.
Review contractual relationships throughout our supply chains and update where necessary.