Modern Slavery Statement.

This statement is published in compliance with Section 54 of the Modern Slavery Act 2015 and in alignment with the UK Government’s Modern Slavery Assessment Tool (MSAT). It sets out Carbon3 Ltd’s approach to identifying, preventing, and addressing modern slavery, human trafficking, forced labour, and all forms of exploitation within our operations and supply chain.

Carbon3 Ltd recognises that modern slavery is a serious global issue affecting millions of people. We take our responsibilities seriously and are committed to ensuring that our business and supply chain reflect our values of integrity, fairness, and accountability. We aim not only to comply with legal requirements but to demonstrate leadership within the renewable energy and construction sectors.

Carbon3 Ltd is a UK-based renewable energy and decarbonisation specialist. Founded in 2019, we deliver a wide range of services including:

• Solar PV installations
• Air Source and Ground Source Heat Pumps
• EV charging infrastructure
• Battery storage systems
• Retrofit and new-build housing projects
• Energy efficiency and ESG consultancy

We operate across multiple regions in the UK, employing a diverse workforce in both office-based and field-based roles.

Supply chain overview:

• Subcontracted engineers and operatives
• Construction materials suppliers (UK and overseas)
• Training providers and academic partners
• Specialist consultants and professional service providers

We acknowledge that our supply chain, particularly in areas involving subcontracted labour and overseas materials sourcing, may present potential risks, and therefore requires robust oversight.

Carbon3 has embedded modern slavery prevention into its governance framework:

• Board responsibility: The Carbon3 Board of Directors has ultimate accountability for modern slavery compliance.
• Day-to-day oversight: The Director of People & Culture leads implementation, supported by HR, Procurement, and Operations teams.
• Reporting: Progress is reported quarterly to the Board, with an annual review and update of this statement.
• ISO alignment: Our approach is integrated into our ISO 9001 (Quality), ISO 14001 (Environment), and ISO 45001 (Health & Safety) management systems.
• Anti-Slavery Policy: Establishes clear standards for identifying and responding to risks of modern slavery and unethical practices.
• Recruitment Policy: Enforces rigorous eligibility-to-work checks and promotes fair treatment and non-discrimination in all hiring processes.
• Whistleblowing Policy: Empowers employees and stakeholders to report concerns safely and confidentially.

We conduct annual supply chain risk mapping to identify areas of heightened vulnerability.
Risks are assessed based on:

• Sector risk: Construction and renewable energy sectors often use temporary labour, which can create vulnerability.
• Geographic risk: Some materials may be sourced from regions with weaker labour protections.
• Workforce risk: Migrant workers, agency staff, and subcontracted operatives are recognised as potentially at higher risk.
• Commercial risk: Projects under tight deadlines or cost pressures can increase vulnerability to exploitation.

The outcomes of risk assessments are used to prioritise supplier due diligence and shape training and monitoring programmes.

Carbon3 requires all suppliers and subcontractors to uphold the highest ethical standards.
Our approach includes:

• Pre-qualification checks: All suppliers complete a due diligence questionnaire covering modern slavery, labour standards, and ethical compliance.
• Contractual safeguards: Standard contracts include clauses requiring compliance with the Modern Slavery Act and giving Carbon3 the right to terminate for breaches.
• Ongoing monitoring:
  • Risk-based supplier audits and site visits
  • Annual compliance declarations
  • Requests for evidence of workforce protections (e.g., payroll records, working hours, grievance procedures)
• Corrective actions: Where non-compliance or risk is identified, corrective action plans are agreed and monitored. Persistent breaches will result in termination of contracts.
• Supplier engagement: We encourage open dialogue with suppliers to build capacity and share best practice.

Carbon3 is committed to providing a safe, fair, and respectful workplace:

• Recruitment:
  • Rigorous eligibility-to-work checks in line with UK law
  • No recruitment fees charged to workers
  • Equal opportunities policy applied consistently
• Working conditions: All staff and contractors are entitled to fair pay, safe working conditions, and respect for their rights. We comply with UK wage laws and aim to exceed minimum standards where possible.
• Worker voice: Employees are encouraged to share concerns through HR and line managers. Regular engagement surveys and open forums ensure feedback is heard.
• Whistleblowing: We maintain a confidential whistleblowing procedure for employees, subcontractors, and supply chain workers to report concerns safely.

Raising awareness is key to prevention. Carbon3 ensures:

• Mandatory training: All staff receive annual training on modern slavery, human trafficking, and ethical labour practices.
• Specialist training: Procurement, operations, and site managers receive tailored training to recognise and respond to risks within supply chains and worksites.
• Supply chain engagement: We provide awareness materials to subcontractors and encourage them to cascade training through their own operations.

Carbon3 measures effectiveness through the following key performance indicators:

• % of employees completing annual training (target: 100%)
• % of Tier 1 suppliers risk-assessed annually (target: 100%)
• % of supplier corrective action plans completed within timeframe (target: 90%+)
• Number of whistleblowing or grievance reports relating to labour exploitation (target: zero, with appropriate action taken if raised)
• Number of audits conducted and compliance rates achieved

KPIs are reviewed annually, and results are reported to the Board.

We recognise that modern slavery cannot be addressed in isolation. Carbon3 therefore seeks to:

• Work with industry partners: Engage with sector associations, NGOs, and training bodies to share knowledge and strengthen collective action.
• Community engagement: Support local skills and training programmes to reduce vulnerability to exploitation.
• Supply chain development: Help suppliers improve their practices by sharing templates, policies, and training resources.
• Future initiatives:
  • Extend audits to include second-tier suppliers
  • Develop a digital supplier compliance tracker
  • Establish a cross-departmental Modern Slavery Working Group to review progress and set new objectives

Carbon3 Ltd strives to lead by example, partnering with industry bodies, NGOs, and suppliers to champion labour rights and ethical practices. By embedding sustainability and ethical considerations into our procurement processes, we ensure that every project reflects our values of fairness, integrity, and transparency.

This statement has been approved by the Board of Directors of Carbon3 Ltd.