Opening Statement from the Leadership Team
Zest Eco Ltd is dedicated to preventing modern slavery and human trafficking from taking place within its business and supply chain and we place the same expectation on our suppliers. At Zest, we have a zero-tolerance policy to modern slavery both within our own business and wider supply chain. Zest Eco Ltd will implement policies and procedures in line with best industry practice to ensure our continual commitment to playing our part in ending modern slavery.
Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
At Zest, we have a zero-tolerance policy to modern slavery both within our own business and wider supply chain. Zest Eco Ltd will implement policies and procedures in line with best industry practice to ensure our continual commitment to playing our part in ending modern slavery.
Structure and Supply Chains
Zest Eco Ltd, founded in 2021 is a national firm in the UK within the electric vehicle infrastructure market and is a subsidiary of Zouk Capital.
The nature of our business requires that we work in conjunction with a range of suppliers, including manufacturers of hardware, providers of software solutions and installation specialists. All of our providers are based within the UK or EU.
Our main supply chains are:
• EV charge point manufacturers
• EV charge point installers
• Professional services
• Utilities Companies
• IT equipment and services
Within these categories we believe that the following types of goods and services are likely to carry the highest risk in relation to modern slavery and human trafficking
• EV charge point manufacturing if outside of the EU
• EV charge point component manufacturing (outside of our supply chain)
• IT
Our policies to prevent Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or any part of our business.
Zest’s procurement policy reflects our commitment to act with integrity and ethically in all our business relationships and to implement and enforce effective systems and controls to combat modern slavery and human trafficking.
Similarly, to our procurement policy, our ethics policy reflects our commitment to conduct our business responsibly, legally, professionally and with integrity defining the way that employees interact with one another as well as customers and suppliers ensuring that should they become aware of any instance of modern slavery and human trafficking that they report it immediately.
Zest has a whistleblowing policy in place intended to provide a process for protection to any employees who wish to raise genuine concerns regarding, amongst other things, issues related to modern slavery and human trafficking.
Due Diligence Processes Relating to Slavery and Human Trafficking
As part of our efforts to monitor, manage and reduce the risk of slavery and human trafficking occurring within our business or supply chains, we adopt the following due diligence procedures:
• Identify, monitor and manage areas of potential risk in our business and supply chains.
• Scrutinise any identified areas of risk within our business and supply chains.
• Adopt a zero-tolerance approach to slavery and human trafficking throughout the organisation and our supply chains.
• Standard terms and conditions of purchasing, which include provisions concerning compliance with applicable modern slavery laws.
• Requirement for appropriate due diligence for all new suppliers with whom we contract, which will include modern slavery checks.
• Provide support and protection from detriment or disadvantage to any person who, in the public interest, raises genuine concerns amounting to a protected disclosure.
Risk and Compliance
Our organisation regularly evaluates the nature and extent to which our business and our supply chains are exposed to the risk of modern slavery occurring. The following list of risk management activities and/or procedures demonstrates our commitment to compliance:
• Only working with suppliers and contractors who have undergone our rigorous tender process when reviewing new suppliers.
• Assessing the risk profile of the countries in which our suppliers are based, using the Global Slavery Index (GSI)
• For higher risk supplier Zest will carry out ownership audits to ensure the organisation and their supply chain is funded and operated without contravention with the Modern Slavery Act (2015).
We do not consider that we operate in high-risk sectors or locations because modern forms of slavery are not prevalent in the countries in which our supplier are based. Where we have identified a potential risk, we prioritise any risks and take appropriate action to put remedial measures in place. We ensure our suppliers are aware of our policies and encourage them to adopt our high standards. We adopt a zero-tolerance approach to slavery and human trafficking throughout the organisation which extends to our supply chains. Upon discovery of a breach of our policies relating to slavery and human trafficking we will terminate any relationship with the relevant supplier with immediate effect.
Next 12 Months
Zest is still in the process of creating and refining our policies as such we will be looking at:
• Continuing to identify and assess potential risk areas in our supply chains.
• Continuing to establish how to mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Continuing to commit to the protection of whistle blowers and to encourage reporting of genuine concerns, including in the respect of slavery and human trafficking • Inserting modern slavery sections into our pre-qualification questionnaires for all suppliers.
• Assess the viability to contract a 3rd party to ensure supply chain visibility and carry out audits.
• Development of training materials that can be distributed among our employees to deliver effective and proportionate ways of raising staff awareness.
• Monitor and implement any changes to best industry practice.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Zest Eco Ltd.’s slavery and human trafficking statement for the financial year ending 31 December 2021
