Zenobe Main Logo

Modern Slavery Statement

1. Organisation structure and supply chains

 Zenobē is an EV fleet and grid-scale battery storage specialist, headquartered in the UK. The company began operations in 2017 with three founders and has over the past 6 years increased its staff to >250 FTEs with a wide range of leading skills including electrical engineering, software development, computer sciences and financing. We currently operate in Europe and Australasia, and we are expanding into North America.

Zenobe has around 25% market share of the UK EV bus sector and over 1,000 electric vehicles supported globally. The company is the largest owner and operator of EV buses in the UK, Australia and New Zealand.

Zenobē has 735MW of battery storage in operation or under construction. We aim to commission 1.2GW of storage in the UK by 2026 and 2.5GW in North America and Australia by 2030.

We have secured investment from some of the world’s leading strategic investors in energy storage and electric transport, including KKR and Infracapital. These organisations have set up comprehensive, regularly-reviewed policies and processes to ensure that their supply chains are not linked to modern slavery and human trafficking. These requirements flow down to us through their organisational structure.

Zenobe has an extensive supply base of over 30 key suppliers in the following areas: bus supply, charger supply, battery supply as well as the delivery of key components and software. We have established policies and processes to ensure compliance with the Modern Slavery Act 2015 in our supply chains, as set out in more detail below. We require all suppliers to comply with our modern slavery and human trafficking policy.

 

2. Policies in relation to slavery and human trafficking

Zenobe does not accept modern slavery or human trafficking in any form. Our Anti- Slavery and Human Trafficking Policy can be read on our website:

https://www.zenobe.com/anti-slavery-policy

Zenobē fully supports the aims of the Modern Slavery Act 2015. We work actively to eradicate the risk that modern slavery and human trafficking might be present in our operations and supply chains. We implement, and will continue to implement, systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our organisation or in any of our supply chains.

We expect that our suppliers will hold their own suppliers to the same standards. Our anti-slavery and human trafficking policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, and suppliers.

Policy for Zenobē’s Own Business:

The prevention, detection and reporting of modern slavery in any part of our organisation is the responsibility of all those working for us. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy. Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Workers must notify their line manager as soon as possible if they believe or suspect that a breach of this policy has occurred, or may occur in the future. Workers are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, workers must contact the General Counsel.

Policy for Zenobē’s Suppliers:

We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our supply chains. All suppliers must comply with our anti-slavery and human trafficking policy and provide details of measures they have taken to ensure compliance.

We take a risk-based approach to our contracting processes, and we keep all contracts under constant review. We include specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.

On an annual basis, we ask our suppliers to fill in an anti-modern slavery questionnaire. The questionnaire requires them to provide assurance and evidence that their supply chains are not implicated in modern slavery. It requests details about their internal policies and procedures on this matter, and how often these policies and procedures are updated. It also requests information about their relationships with direct and indirect suppliers, including but not limited to the identities and locations of such organisations; where they source raw materials and components from; how they monitor compliance with their internal anti-slavery and human trafficking policies; and who is responsible for monitoring and enforcing such policies.

Our suppliers are obliged to demonstrate that they are implementing measures, such as audits, to eradicate the possibility that their supply chains could be linked to modern slavery.

Consistent with our risk-based approach, we may require:

  • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our
  • suppliers engaging workers through a third party to obtain that third party’s agreement to comply with our standards.

We also assess the merits of writing to suppliers on an individual basis to check their compliance with standards required to combat modern slavery and trafficking. As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant auditing our suppliers to ascertain their level of compliance with our standards. If we find that individuals or organisations working on our behalf have breached these standards, we will take appropriate action, which may include termination of working relationships.

Responsibility for the policy

The board of directors has overall responsibility for ensuring our Anti-Slavery and Human Trafficking policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Chief Operating Officer has primary and day-to-day responsibility for implementing our Anti-Slavery and Human Trafficking policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with our Anti-Slavery and Human Trafficking policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

The following teams are involved in ensuring compliance with Anti-Slavery and Human Trafficking and related policies (see below): legal, procurement, health & safety and marketing/regulation

Related policies

  1. Anti-Corruption and Bribery Policy
  2. Corporate and Social Responsibility Policy
  3. Whistle-Blowing Policy
  4. Environmental Policy
  5. Code of Conduct and Ethics
  6. Mandatory modern slavery training for all Zenobe employees

 

3. Due diligence processes

 

Supply chain management documents and procedures:

All suppliers must confirm compliance with the Anti-Slavery and Human Trafficking Policy and submit satisfactory responses to the modern slavery due diligence questionnaire.

These obligations are implemented through the following ISO-certified procedures and documents:

  • Process for large-scale network infrastructure tenders:
    • The supplier must confirm conformance with environmental policy, anti-corruption policy, anti-slavery and human trafficking policy, health and safety policy.
    • The supplier must submit a satisfactory response to modern slavery and due diligence questionnaire.
    • The supplier must fill in a Capability Assessment, which includes questions on processes and standards.
    • All submissions are then tracked and graded in the Capability
    • Conformity to policies is pass/fail.
  • Supplier onboarding and re-evaluation questionnaire for larger-scale suppliers (over £1m)
    • Suppliers must respond satisfactorily to questions on policies (including modern slavery), relationships, goods/services, compliance, and
    • Suppliers are required to fill in a due diligence
  • Supplier onboarding and re-evaluation questionnaire for smaller-scale suppliers (under £1m)
    • Suppliers must respond satisfactorily to questions on modern slavery
    • Suppliers are required to fill in due diligence

 

4. Risk assessment and management

We assess the risk of modern slavery in our supply chains through the due diligence processes outlined above. This includes a requirement for all suppliers to sign our anti-slavery and human trafficking policy.

We identified an increased risk of modern slavery in our supply chains due to our exposure to the minerals processing industry. As a result, we introduced a requirement for our suppliers to fill out questionnaires on modern slavery on an annual basis.

If suppliers do not meet our requirements, we will either not contract with them, or we will take appropriate intermediate steps.

 

5. Key performance indicators to measure effectiveness of steps being taken

We have a process for evaluating whether our supply chains drive modern slavery and human trafficking.

As part of the creation of this Modern Slavery Statement, we have introduced a new KPI: to measure adherence to our Anti-Slavery Policy by new and legacy suppliers on an annual basis. The new KPI is measured based on the output of our due diligence process outlined above.

 

6. Training on modern slavery and trafficking

We have annual mandatory training on modern slavery and human trafficking for all staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and business.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement and has been approved on behalf of the Zenobe Board.

Peter Smith

Head of Product

Pete leads Zenobē’s growing team of Product specialists across all areas of the business. His team oversee our R&D as well as product development in both hardware and software.

 

He has been working in the European E-Mobility sector from over ten years, specialising in the design, build and delivery of software systems for EV Charging.