Modern Slavery Statement
The Good Fuel Group Modern Slavery and Human Trafficking Statement 2021
This voluntary statement is made on behalf of The Good Fuel Group pursuant to section 54 of the Modern Slavery Act 2015. This statement contains details of the steps that The Good Fuel Group takes to ensure that neither slavery not human trafficking take place in the business or supply chains of The Good Fuel Group.
Definition
According to the Modern Slavery Act 2015, the following definitions are encompassed within the term ‘modern slavery’;
- ‘Slavery’ is where ownership is exercised over a person
- ‘Servitude’ involves the obligation to provide services imposed by coercion
- ‘Forced or compulsory labour’ involves work or service extracted form any person under the menace of a penalty and for which the person has not offered himself voluntarily
- ‘Human trafficking’ concerns arranging or facilitating the travel of another with a view to exploiting them
Structure and supply chains
The Good Fuel Group is a privately-owned advisory and green tech commercialization firm. As a professional services firm, we also procure goods and services from third parties. This policy focuses on the key suppliers of our goods and services which is a part of our internal procurement function, and other business functions dealing with suppliers.
The Good Fuel Group is committed to engaging ethical suppliers that provide high quality products and services. As a minimum, we expect both ourselves and our suppliers to comply with all applicable local laws and regulations providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically and being environmentally responsible where practical.
This policy is owned by the Executive Board of the Good Fuel Group and applies to all employees, partners and suppliers. The Board of the Good Fuel Group is responsible for implementing this policy, monitoring its use and effectiveness, and dealing with any queries about it.
Policies
The Good Fuel Group recognises both the business imperative and moral obligation to carry out its business activities in a socially responsible and environmentally sustainable manner, with due consideration given to human rights. Various policies have been formalised to demonstrate our commitment to this.
Our Sustainable Sourcing Policy sets out the social, ethical and environmental standards that we use internally to make office procurement decisions and also sets out the commitments that The Good Fuel Groups suppliers are expected to adhere to. The policy references human rights, fair labour and anti-corruption.
In relation to our employees, The Good Fuel Groups aim is to attract and retain professionals who share a commitment to our values. Our employees are hired in accordance with robust and fair recruitment procedures and are expected to adhere to The Good Fuel Groups Code of Ethical Business Conduct which reflects our commitment to acting ethically and with integrity in all our business relationships. In the unlikely event that misconduct is uncovered, including concerns around modern slavery, employees are encouraged to report the misconduct to senior management. Additionally, The Good Fuel Groups Whistleblowing policy provides guidance to employees on how to raise concerns.
Due Diligence
Where possible The Good Fuel Group builds long standing relationships with its third-party service providers and suppliers and places obligations on these suppliers to comply with all applicable laws, which, where relevant, would include compliance with the Modern Slavery Act.
The Good Fuel Group aims to tackle modern slavery and human trafficking across its business activities by identifying any existing issues or risks related to it as well as managing and mitigating those.
All of those working for us or under our control are responsible for preventing, detecting and reporting any existing or potential issues of modern slavery and human trafficking at The Good Fuel Group and across its supply chains. Employees and suppliers are encouraged to raise any concerns about any issues or suspicion of modern slavery within The Good Fuel Groups business operations or any tier of our supply chain as soon as they become aware of it.
Whilst we have not identified any occurrences of modern slavery, we have done risk assessments and have identified the following key processes to influence and manage any potential risk of modern slavery and human trafficking within our business and supply chains:
Ensure other relevant policies are updated and aligned: Our Sustainable Procurement policy already covers modern slavery and we will update any related policies to include references to modern slavery and human trafficking.
Continuous risk assessment: Our procurement function will continue to monitor our procurement spend on identified higher risk areas and suppliers, following an initial category and supplier risk evaluation.
Scrutinise and monitor suppliers: Our procurement function, and other business functions dealing with suppliers, will carry out due diligence on specified higher risk suppliers to identify and manage potential risks related to modern slavery and human trafficking.
Effective contract management: Our procurement function, and other business functions dealing with suppliers, will engage with specified higher risk suppliers and their supply chains to make them aware of this policy, and to jointly identify risks of modern slavery and human trafficking and mitigating actions.
We encourage everyone within the business to raise genuine concerns in good faith under this policy regardless of whether these may turn out to be mistaken. No members of staff may be punished, dismissed or be subject to any form of detriment for having taken an initiative that falls within the scope for the Whistleblowing procedures.
We will terminate our relationship with individuals, suppliers, and organisations working on our behalf who breach this policy.
Training
We believe that the training of people is an effective way to raise awareness of the issues around modern slavery. We make our Code of Ethical Business Conduct, Sustainable Sourcing Policy and Whistleblowing Policy available on the staff intranet and update these regularly.