This statement relates to the financial year ending 31 December 2023 and is published pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps that ContourGlobal Limited (“ContourGlobal”) has taken and continues to take to ensure that no modern slavery or human trafficking occurs within our business or supply chain.
ContourGlobal is a power generation company committed to new growth in low and nocarbon technologies. Since our inception in 2005, we have grown to be an internationally recognized company with technologically diverse assets and best-in-class operations.
ContourGlobal supplies electricity principally in the wholesale market, selling it under contract and regulated tariffs to those who then transmit or distribute it or sell it on to households, businesses, and others in the retail market. Our customers include national grids and utilities that supply these grids, as well as commercial and industrial customers that receive electricity, steam, water, or CO2 directly from on-site facilities.
As of 31 December 2023, we operate 131 thermal and renewable power generation assets in 20 countries across Europe, Latin America, North America and Africa, with a total installed capacity of over 6.2 GW.
The energy we generate has a positive impact for people, businesses, and communities around the world – powering cities, providing heat and light, and enabling businesses to run around the clock. Through our social investing program, we invest in making the places where we live and work better. We are proud of our positive impacts and will build on these as ContourGlobal continues to grow well.
We are committed to reducing our carbon footprint including through the increased use of renewable energy sources and technologies. In the last twelve months, we revamped and repowered 35 of our 71 total solar photovoltaic (PV) in Italy, targeting a 43% increase of the installed capacity of the modernized plants while our Austrian wind farms have increased their total output in the last twelve months by 22 GWh through the repowering of one wind farm with capacity of 10.2 MW.
Further details can be found on our website, https://www.contourglobal.com.
We align our business with the Ten Principles of the United Nations Global Compact (“UNGC”) and, have been a signatory since 2010. These principles (“UNGC Principles”) embody our own values and commitment to participate actively and continuously in initiatives relating to human rights, labour, environment, and anti-corruption. We share the United Nations’ objectives of building a sustainable and inclusive global economy. By respecting and supporting the UNGC Principles we believe we can contribute to the Sustainable Development Goals (SDG) that have been set up by the UN 2030 Agenda. We hope to contribute to achieving the SDG targets around responsible consumption and production (SDG #12) and decent work and economic growth (SDG #8) in addition to the core SDGs of affordable and clean Energy (SDG #7) and Climate Action (SDG #13).
We are committed to maintaining the highest ethical standards, and support and respect the protection of internationally proclaimed human rights. Our commitment to human rights extends to all ContourGlobal employees as well as everyone working on our sites, and indigenous and non-indigenous peoples in our communities. We adhere to international standards in all places where we operate, including the principles contained within the United Nations Universal Declaration of Human Rights, the UNGC Principles, and the United Nations Guiding Principles on Business and Human Rights.
Our Human Rights Policy Statement is communicated to our employees and sets out our commitment to assess human rights risks in our businesses and in our social investments, considering risks related to gender equality, repressive regimes, bribery and corruption, child labour, forced labour, indigenous peoples, non-discrimination, land management, health and safety, trade unions and working conditions. Although the risk of human rights breaches can be high in some countries where we operate, we manage these risks responsibly through our adoption of global standards, training, careful supplier selection, and express contractual requirements in our agreements.
In 2023, we continued to apply the principles contained in our Social Responsibility and Environmental Sustainability Policy, our Social Investment Framework, our Human Rights Policy Statement, our Health, Safety and Environment policy, our revised Code of Business Conduct and Ethics (“Code of Conduct”), and our Supplier Code of Conduct (“Supplier Code”). As discussed further below, we also encourage our employees and business partners to raise any concerns about wrongdoing, or potential breaches of law or policy that they may have observed through the appropriate channels, either internally or through our third-party hosted EthicsLine (where concerns may be raised anonymously).
Our Compliance function, with oversight from our Audit and Risk Committee, is responsible for ensuring that effective policies and procedures are in place to manage the risk that modern slavery could occur within our business or supply chain.
We are committed to maintaining the highest ethical standards across our supply chain. We do this, recognizing the critical role our supply chain plays in our business and without compromising quality. All our suppliers must share our commitment. Our Supplier Code, which is aligned with the UNGC Principles, is a foundation for our approach to engagement of suppliers. All our suppliers and service providers must adhere to the terms of the Supplier Code, as a condition to their initial engagement, and must continue to demonstrate compliance throughout the entire engagement lifecycle. We have also adopted a Supply Chain Due Diligence Policy that specifies the steps required to identify and assess supplier risk and creates a risk-based due diligence and approval process for all suppliers. Additionally, suppliers and service providers must satisfactorily complete our due diligence screening.
ContourGlobal uses the Global Slavery Index to identify countries at higher risk for modern slavery concerns. Continuing efforts from prior years, we continue to use a modern slavery and human rights questionnaire where we determine a supplier presents a higher risk as to slavery and labor rights issues. This includes enquiring as to whether the third party has a policy (or policies) addressing human rights, anti-slavery minimum wage, child labour, and forced or compulsory labour. Where an adequate policy is lacking, we will not engage with the vendor until they take steps to impose policies and procedures that ensure respect of, and compliance with, these various human rights (and will not engage them should they refuse to comply). When working with smaller suppliers we will often offer to assist them with the development of these programs to help improve their compliance.
When faced with projects, such as EPC contracts, that present higher risk, we increase our level of diligence. For example, we will require that sub-suppliers or sub-contractors, undergo our internal due diligence process, as well as imposing higher duties of diligence on the prime contractor. We include contractual provisions that allow us to monitor supplier/contractor behavior, such as enhanced audit rights. In some cases, in the past, we have included incentive provisions in contracts to reward suppliers who maintain strong anti-slavery programs and compliance.
We continue to monitor developments related to US and EU trade restrictions impacting imports of polysilicon, a component of photovoltaic solar panels, and to diligence solar panel suppliers to our projects to assure their supplies are not reliant on forced labour in compliance with these measures. In 2023, ContourGlobal increased the number of PV panels as well as upgraded PV panels at several of our sites. We undertook a comprehensive diligence of the supply chain for these PV panels and components, including prequalification, supply chain traceability audits, and site visits for select suppliers. These enhanced procedures allowed us to make informed procurement decisions on essential components.
As reported in our previous statements, ContourGlobal maintains an independent whistleblowing channel, our “EthicsLine”, enabling both employees and business partners to raise concerns, anonymously if they prefer (to the extent permitted under local law). In parallel, employees may also raise concerns internally, to their manager, HR, Legal or Compliance.
Posters advertising the EthicsLine remain permanently affixed in prominent locations throughout our facilities (in the local language of the location). The posters identify human rights violations as a potential concern that employees should be aware of and report. We regularly remind our people of the benefits of raising concerns, as well as our zero-tolerance policy towards any actual or threatened retaliation against anyone raising a concern. Any concerns raised, through the EthicsLine or otherwise, are thoroughly investigated and appropriate action taken.
Additionally, we have formal grievance procedures and whenever issues or concerns are raised by our stakeholders, our commitment is to address and resolve them as efficiently and effectively as possible. We seek to deal with all grievances in a timely manner. Whenever relevant and appropriate, matters arising through this process are shared with senior management. At least quarterly, the Chief Compliance Officer reports to the Audit Committee on ethical concerns received, including the outcome of investigations, any disciplinary action taken, and remedial steps implemented. In 2023, there were no modern slavery, human trafficking or any other human rights concerns reported whether internally or through EthicsLine, nor were any identified through other mechanisms.
ContourGlobal promotes awareness of our commitments to human rights and ethical behaviour through a variety of mechanisms. Employees are provided with our ‘Essential Information’, which includes our Code of Conduct, our Human Rights Policy Statement, our AntiCorruption Compliance Guide, and our Anti-Corruption Policy. Further, we provide regular, targeted training to different categories of personnel.
A Modern Slavery awareness poster is available in ContourGlobal locations reminding employees to remain vigilant to signs of possible modern slavery and the obligation to report any concerns.
ContourGlobal will continue to review the effectiveness of the steps we take to ensure that there is no slavery or human trafficking in our supply chains, and to address emergent risks, should they arise.
On June [30], 2024, this statement was approved by the Board of Directors of ContourGlobal Limited.