Modern Slavery Act Transparency Statement 2025

Snetterton Renewable Power Holdings Limited

Statement issued in accordance with the Modern Slavery Act 2015 (“the Act”) in relation to the period 1 July 2024 to 30 June 2025 (“the Statement Period”).

Introduction from the Board of Directors

We remain committed to improving our practices to combat slavery and human trafficking, with a view to ultimately achieving the best possible practices in this regard.

Our business

We are the parent company of the Snetterton Renewable Power group (the Group). The Group’s principal activity is that of renewable power generation from the Snetterton Renewable Energy Plant located at Chalk Lane, Snetterton, Norwich, Norfolk. The Group has no employees.
 

Operation and maintenance of the power station is carried out pursuant to a long-term contract with Burmeister & Wain Scandinavian Contractor A/S (BWSC A/S).
 

Oversight of the business including finance, fuel procurement and governance is provided by Melton Renewable Energy UK Limited (MRE) pursuant to a Management Services Agreement.

The Group includes, and this statement is made in respect of each of the following companies:

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• Snetterton Renewable Power Holdings Limited – principal activity being that of holding company for the Group;

• Snetterton Renewable Power Limited (owner of Snetterton Renewable Energy Plant) - principal activity renewable power generation; and

• Snetterton Renewable Power Fuels Limited – counterparty to fuel and haulage contracts relating to Snetterton Renewable Energy Plant.

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In the Statement Period the Group had an annual turnover of £44.15m (unaudited at this stage), all of which was generated from within the United Kingdom.

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Our supply chains

 

Aside from services provided to the Group by regulated advisors, which services we consider to be low risk in the present context, our supply chains include:

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• Biomass fuel suppliers, hauliers and loaders: we have a large number of contracts in place which provide for the sale and purchase of biomass products (principally straw, miscanthus and wood chips) for use as fuel in our power station, and the collection, loading and delivery thereof.

• Engineering and construction contractors: As noted above, BWSC A/S is the operator of the plant under a long-term operation and maintenance contract. BWSC A/S may engage other contractors from time to time as required.

• Ash off-take contractors.

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Our policies on slavery and human trafficking

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We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy (see link below) reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Anti-Slavery and Human-Trafficking Policy

 

Due diligence processes for slavery and human trafficking

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As part of our initiative to identify and mitigate risk we have raised this as a particular issue with relevant members of MRE, BWSC A/S, and the biomass fuel supply chain (suppliers, loaders and hauliers). We have carefully considered our various supply chains and identified particular areas of risk, it being noted that our fuel supply involves agriculture and transportation both of which have been identified as industry sectors presenting a potentially higher risk.

 

Supplier adherence to our values

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We have zero tolerance to slavery and human trafficking. To ensure those in our supply chains as well as our contractors comply with our values, we have put in place a supply chain compliance programme.
 

In this regard, all of our standard form contracts include a positive obligation requiring compliance by the supplier or contractor with our Anti-Slavery and Human Trafficking Policy (or, in certain cases, with the Act) and provide that an entitlement to terminate shall arise in our favour if the supplier or contractor is found to be in breach of the Policy (or the Act, as the case may be).Ongoing compliance with the Act is monitored on behalf of the Group by MRE’s senior management team (specifically the CEO, Legal Counsel and Fuel Team) pursuant to its Management Services Agreement.

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Training

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To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, MRE has provided training to such of its staff members and those of our contractors as are likely to be affected by the Act and its requirements to ensure that we continue to be able to:

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• Identify and assess potential risk areas in our supply chains.

• Mitigate the risk of slavery and human trafficking occurring in our supply chains.

• Encourage vigilance as to potential risk areas in our supply chains.

• Encourage whistleblowing and protect whistle blowers.

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In addition, in the Statement Period MRE has engaged Slave-Free Alliance with whom it has developed a bespoke training programme. This has been delivered in person to the relevant individuals.

 

Further steps taken in the Statement Period

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In addition to the above, during the Statement Period we have continued to monitor compliance with the Act generally across our supply chain and specifically issued compliance statements to our contractors and suppliers, requesting their confirmation that no slavery or human trafficking has taken place in their business or supply chains in the 12-month period ended 30 June 2024 and followed up any contractors and suppliers that failed to provide this confirmation in a timely fashion.

 

Further steps to be taken

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During the 12-month period to 30 June 2026 we shall:

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• issue targeted due diligence questionnaires to BWSC A/S and key members of the biomass fuel supply chain suppliers (suppliers, loaders and hauliers) with the aim of obtaining a better understanding of their internal processes in relation to this issue; and

• follow-up on any actions that were agreed with Slave-Free Alliance during the recent in-person training.

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This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the 12-month period ended 30 June 2025.