Introduction
This Modern Slavery Act Transparency Statement (“Statement”) has been published in accordance with section 54 of the Modern Slavery Act 2015 (“Act”) enacted in the United Kingdom. It sets out the steps taken by the Corona Energy group companies in the United Kingdom during the financial year ending 31 March 2024 to prevent modern slavery and human trafficking in its business and supply chain. This is the ninth report under the Act.
Corona Energy supports fundamental human rights as set out in the Universal Declaration of Human Rights and codified in the International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights and core International Labour Organisation Conventions. In line with the UN Guiding Principles on Business and Human Rights, we recognise the duty of states to protect human rights and the responsibility of businesses to respect human rights. We are committed to acting ethically and responsibly in all business relationships and to endeavor to ensure that slavery and human trafficking do not occur in any part of our business or supply chain.
Modern slavery involves the most serious forms of human exploitation and takes many forms, including: trafficking in persons; slavery; servitude; forced marriage; forced labour; debt bondage; deceptive recruiting for labour or services; and the worst forms of child labour. Corona Energy is committed to identifying and mitigating the risk of modern slavery and human trafficking occurring within its business operations or supply chain.
Corona Energy business and supply chain
The Corona Energy group of companies supplies gas and electricity to over 17,000 commercial, industrial and public sector customers throughout the United Kingdom and supplies 14% of the UK commercial gas market. We have a diverse customer base ranging from small and medium sized businesses to multi-site business enterprises, government entities, educational institutions and large enterprises. Corona Energy currently sources both gas and electricity through the trading arm of its parent company, Macquarie Bank Limited. We employ over 275 people in the United Kingdom.
As a supplier of energy, the risk of modern slavery within Corona Energy’s direct business operation is considered to be low. However, Corona Energy recognises that it can be indirectly exposed to these risks, for example through its supply chain or customer relationships. Corona Energy takes a risk based approach to modern slavery risk in its supply chain, business operation and customer relationships.
Governance and Policies on Slavery and Human Trafficking
Corona Energy has an established set of policies and procedures that govern the way it operates. These are relevant to how Corona Energy manages potential human rights related issues with regard to its business operations and supply chain. These include:
- Corona Energy’s Code of Conduct, which incorporates the principles of What We Stand For: Opportunity, Accountability and Integrity. These principles guide Board, management and staff conduct. The Code of Conduct outlines what is expected of employees in relation to managing risks in all business activities and outlines mechanisms to raise concerns, including through Corona Energy’s Whistleblower Program;
- The Supplier Governance Policy and associated framework outlines risk triggers and due diligence requirements for Corona Energy when engaging with suppliers in industries which may be considered high risk for human rights breaches. The Supplier Governance framework includes our Principles for Suppliers which articulate expectations for suppliers, including that they: respect human rights; provide safe, fair and ethical working conditions; seek opportunities to improve environmental performance; promote supplier diversity; and do not use child labour or any form of forced or involuntary labour under any circumstance. The Principles also provide details on how suppliers are able to confidentially report concerns about improper conduct by Corona Energy or the supplier via emailing: vendor@coronaenergy.co.uk;
- The Environmental Policy, which establishes processes for identifying, assessing, managing, mitigating and reporting material environmental risks across the business;
- The Work Health and Safety Policy which outlines Corona Energy’s commitment to operating harm-free environments through maintaining high work, health and safety standards; and
- The Whistleblower Policy and Program, which outlines circumstances under which a person may raise genuine concerns in relation to improper conduct, the avenues for doing so, the protections that are available to those who report improper conduct, and the investigation process. Improper conduct includes any instance or suspicion of modern slavery or human trafficking, breaches of laws and breaches of Corona Energy’s internal policies.
Recognising that there are areas of commonality between human rights and financial crime risk, modern slavery risk is considered in the process and procedures for detecting, mitigating and managing the risks of financial crime. This includes when assessing financial crime risk across customer and third-party onboarding, due diligence, payment and customer screening. In addition to this, Corona Energy has extended its risk register to include Financial Crime Risk, which incorporates Anti-Money Laundering, Anti-Bribery and Corruption, Tax Evasion and Economic and Trade Sanctions and has implemented associated procedures for detecting, mitigating and managing the risk of financial crime, including those potentially linked to human rights violations (including modern slavery). This is reviewed every 6 months as part of Corona Energy’s Risk and Control Self Assessment.
Policies and procedures are reviewed at least annually and updated if needed.
Corona Energy staff and external parties, including suppliers, can confidentially report concerns about improper conduct by Corona Energy or by suppliers to the whistleblowing hotline – SeeHearSpeakUp, an impartial and independent reporting platform. The Whistleblower Program is promoted internally including via the Code of Conduct and the Principles for Suppliers. It incorporates the Whistleblower Policy, and the support and protections available to those who report genuine concerns to ensure that they do not suffer detriment as a result of speaking up. In the year to 31 March 2024, there were no reports of slavery or trafficking through the Whistleblower Program.
Our processes to prevent slavery and human trafficking
Suppliers:
Corona Energy’s Supplier Governance Policy brings under governance all direct suppliers, which meet high inherent risk and / or high value triggers. The relevant Corona Energy department that procures the goods or services (with support from Corona Energy’s Office Manager) owns the supplier relationship and is responsible for assessing all direct supplier relationships to determine whether they meet high inherent risk (which includes Environmental Risk) or high value triggers.
We expect our suppliers to comply with our values and standards set in our company Code of Conduct and Principles for Suppliers.
Under our Principles for Suppliers, we request our direct suppliers to cascade human rights and modern slavery standards down the supplier’s own supply chains.
In the year to 31 March 2024, we continued to undertake the following reviews in order to ensure that slavery and human trafficking was not taking place in our business or supply chain:
- We continued to conduct reviews of all parts of our business and found no evidence of either slavery or human trafficking.
- We continued review of our supply chain and confirmed that, based on sector and supply chain profile, the risk of modern slavery continues to be low.
- Suppliers under governance are required to undergo risk assessment and due diligence with internal approvals obtained prior to contract execution, as well as subject to ongoing governance.
We also continue to undertake screening measures in our supplier on-boarding process in accordance with our Supplier Governance and Supplier Life Cycle Policy to verify that slavery and human trafficking are not utilised by such suppliers and continue to monitor and assess categories of third parties we identify as most at risk in relation to slavery and human trafficking. Corona Energy is committed to maintaining collaborative supplier relationships.
Employees:
We continue to take steps to prevent potential risks within our workforce. We have robust policies and procedures in place concerning employment screening (including work eligibility checks), employment conditions and appropriate work place behavior. These policies and procedures apply across all employment types and are reviewed on a regular basis. We also deploy training of our workforce to raise awareness of the issues relating to slavery and human trafficking.
All employees are expected to abide by the spirit, as well as the strict requirements, of the Code of Conduct and applicable policies and procedures and to adhere to ethical business practices.
Corona Energy is committed to maintaining a safe workplace that values equal opportunity, is free from discrimination, harassment and victimisation. Corona Energy is also committed to maintaining an environment where staff feel comfortable raising issues or concerns and do not experience detriment as a result of speaking up. During the employee onboarding and orientation process, Corona Energy offers a series of learning and development activities (including events hosted by the Chief Executive Officer (“CEO”) of Corona Energy’s group companies).These are designed to communicate and embed Corona Energy’s culture and reinforce the ongoing importance of meeting behavioural expectations and effective risk management across Corona Energy’s business.
We have regular review processes in place to ensure that all policies and procedures are amended as needed to reflect changes to employment legislation and regulation. This review covers all employment legal matters, including working time and remuneration rules. Further, we have robust training framework to ensure all staff are aware of Corona Energy’s expectations and values, including those set out in the Code of Conduct. Processes are in place to monitor staff compliance with training.
Continuous improvement:
Corona Energy will continually review and enhance its approach to addressing modern slavery risks within its supply chain and its business operation by:
- Continuing to embed Corona Energy’s Principles for Suppliers;
- Continuing to assess new suppliers through the on-boarding process and monitor existing suppliers as contracts are renewed;
- Continuing to engage with an external consultant to achieve ISO 14001:2015 accreditation; and
- Continuing to train all staff on Corona Energy’s Code of Conduct
This statement has been approved by the board of directors of each of the Corona Energy group companies as listed below.
Neil Mitchell
Chief Executive Officer
Corona Energy Limited
Corona Energy Retail 1 Limited
Corona Energy Retail 2 Limited
Corona Energy Retail 3 Limited
Corona Energy Retail 4 Limited
Corona Gas Management Limited
September 2024
