Mondern Slavery Statement

Anti-Slavery and Human Trafficking Report

Green Frog Connect Limited, and its subsidiary PHD Electrical Contractors Limited, are required to publish an annual statement in line with Section 54 (1) of the Modern Slavery Act 2015 (the Act).  This is completed and published at the end of each financial year (on the 31^st May). 

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes our company’s Anti-slavery and Human Trafficking Statement for our last financial year ending May 2024. This statement has been approved by the Board of Directors.

The Directors feel morally motivated to ensure that no offence is committed by themselves or their suppliers and sub-contractors.  We feel strongly that this is an abhorrent crime, regardless of where this may be practiced, let alone modern-day Britain. We are highly motivated to identify and disclose any potential instances to the appropriate authorities.

General Statement

Green Frog Connect has a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within its business, including its supply chain. The company will impose those same high standards on its contractors, suppliers and other business partners. Forced labour is, therefore, prohibited throughout the company’s operations and supply chain.

Everyone in the company has a responsibility to ensure that we are alert to the risks in our business as well as our supply chain.  As well as publishing our annual statement on our website and via our internal Business Management System we also ensure that all employees are aware of their responsibilities.

 The four areas which are covered by our policy are:

• holding a person in slavery or servitude
• human trafficking
• exploitation by securing services through force
• aiding and abetting any of these crimes

Our Organisation

We are a UK based company provider of high-voltage connections to the electricity grid, specialising in building renewable and conventional power-generation projects. We offer a full turnkey solution from design to project management and through to construction. Our services include civil works, electrical and mechanical works, security systems, generator installation, control systems and final commissioning.  In order to fulfil our obligations we utilise a significant number of suppliers. 

The company’s financial year runs from 1^st June – 31^st May.

Policy

We are committed to ensuring that all of our business activities are carried out ethically and with high levels of integrity.  We believe that this allows us to, so far as is reasonably practicable, ensure that human trafficking or modern slavery is not happening within our company or supply chain. 

In addition to our Modern Slavery Policy we also have an Anti-Bribery Policy which all employees are aware of and understand their responsibilities.  We also have a Whistleblowing Policy which forms part of our management system and is communicated to all employees.  In addition, we have a Sustainability Strategy which encompasses all our aims and objectives relating to sustainability as a whole, including labour standards and human rights. 

Supply Chain

We engage with a number of suppliers and subcontractors to support our business.  Our suppliers provide us with materials and manufactured products to use across our projects. Our subcontractors support us with installation and construction works in order to fulfil our obligations. 

During our last financial year we identified suppliers who were higher risk in terms of possible slavery and/or human trafficking, and also evaluated where overseas labour could potentially be higher risk.  Moving forwards, we aim to utilise a risk assessment process for all suppliers which will categorise them according to any modern slavery risks they pose, as well as other commercial, health, safety and environmental risks.  This should allow us to streamline our existing process and spend time focussing more accurately.  We also ensured that we had an improved level of engagement pre contract with our suppliers to ensure that we had more time to review subcontractors and purchasing agreements, which included checking that pricing was consistent with industry expectations. 

Due Diligence

During the 2024 financial year we made efforts to reduce the number of suppliers on our approved supplier list so that we could improve our due diligence process by focussing more in depth on a smaller number of companies.  As mentioned above this is an evolving area of focus for us as a business.  Many of our suppliers are approved by the Distribution Network Operators and this gives us extra confidence when sourcing from these suppliers.

During the last financial year we had no reports of modern slavery in our business or through our activities with our supply chain

Training

All employees are signposted to our Modern Slavery Policy during their company induction.  However, we have now invested in a Learning Management System which will assist us in rolling out standard Modern Slavery / Human Trafficking training to all employees, including any subcontracted individuals. 

Aims for FYE 2025

During 2025 we aim to ensure that 100% of our employees have completed Modern Slavery Training.  Those who are responsible for approving suppliers will have additional training, knowledge and experience so that they can continue to apply high levels of vigilance across our supply chain.  We will aim to continually improve our supplier onboarding processes to ensure that we are communicating our expectations appropriately.  We will keep clients informed about our supply chain, ensuring that all of our efforts are aligned. 

Tom Drake – Director

Date: 31/05/2024