Modern Slavery & Transparency Statement
This statement sets out the steps that UGS Energy SA (the “Company”) has taken to ensure that neither slavery nor human trafficking are taking place in any of our supply chains or in any part of our business, for the financial year ended 31 December 2020.
Due to the nature of our business, we believe that the risks of slavery and human trafficking in our business are remote. While there are risks inherent in operating in Gdansk, Poland, we have taken the steps described herein to mitigate the risks of slavery and human trafficking in our supply chains. We have mainly focused on our direct suppliers, as this is the level of the supply chain where we believe we can have the most influence and can therefore be most effective.
In order to mitigate the risks of slavery and human trafficking in our supply chains we have added relevant risks to our Directors’ risk register to ensure that any such risks are recognised and closely monitored.
Code of Conduct
We are committed to ensuring that all persons employed by the Company act ethically and comply fully with all applicable laws and regulations.
We have a Code of Conduct (the “Code”) that applies to our employees which, for the purposes of the Code, are stated to include secondees and independent contractors who devote the majority of their working time to the Company’s business. The Code includes a specific provision which states that the physical abuse of employees and the use of any form of forced labour, including prison labour, bonded labour, military labour, slave labour, child labour or any form of human trafficking is prohibited. The Code also indicates that we are committed to a work environment in which all individuals are treated with respect, that we prohibit discriminatory practices or harassment and that we are committed to preventing harm to the health and safety of our people.
Equality and Diversity
In 2018, the Board approved a new Equality and Diversity Policy which, amongst others, applies equally to the treatment of our supply chains. The objectives of the policy are to promote equality of opportunity and to ensure that no individual suffers unlawful discrimination, directly or indirectly, on the grounds of race, colour, ethnicity, religion, sex, gender, identity or expression, gender reassignment, national origin, age, marital status, disability or sexual orientation.
Human Rights
In 2019, the Board approved a new Human Rights Policy which applies to all who work for UGS Energy but also to anyone doing business with UGS Energy or acting on UGS Energy’s behalf. The policy aims to ensure that we conduct our business in a manner that respects the rights and dignity of all people, complying with all legal requirements and internationally recognised human rights.
Whistle-Blowing
We have a Whistle-Blowing Policy which takes account of the Whistle-blowing Arrangements Code of Practice and Public Concern at Work and which applies to all individuals working for the Company at all levels and grades, whether they are senior managers, directors, employees, consultants or contractors. The Whistle-Blowing Policy is also mentioned in the Code and a person who reports any matter in good faith will be protected against any sanctions.