OVO SOLAR AND HEATING LTD

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits compulsory overtime Prohibits child labour Prohibits discrimination

Training described

Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Civil society organisations Workers within your organisation Workers within your supply chain Businesses in your industry or sector

Social audits

Third party audit arranged by your supplier

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

N/A

Demonstrated progress

OVO recognises the need to assess the effectiveness of the measures that have been taken to tackle modern slavery. In 2023, OVO Retail updated the key performance indicators used to monitor the progress of OVO's modern slavery risk management initiatives. These are as follows: ● Tier 1 suppliers who have signed OVO’s Supplier Code of Conduct (%); ● Tier 1 suppliers with a low level of residual social risk (%); and ● Social value generated from Tier 1 suppliers (£)

Reported risks and mitigations

• Risk: We source solar panels and battery storage via a wholesaler. We recognise that there is a significant risk of forced labour in the production of polyscilicon that is used within solar panels
• Area: Within your supply chains
• Tier: Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Other vulnerable groups
• Mitigation: Interviews with management of our suppliers to understand the processes and practices in place to manage and mitigate this risk. Require evidence to be provided to substantiate claims. Ongoing management of relationship to ensure risk is being prioritised. Not working with suppliers who we aren't comfortable have put sufficient risk management practices in place.
• Risk: Our engineers wear branded uniforms. We recognise that there is a risk in the manufacturing industry of forced labour, particularly when sourcing garments from overseas.
• Group: Women
• Mitigation: Extensive engagement with uniform provider to ensure they don't produce garments under these conditions. For example, we obtained written confirmation from the management that they take the issue of significant overtime seriously and putting in practices to remediate it. We also asked for a log of working hours to ensure that workers did not exceed legal working hours. Requiring all providers to provide social audits over working practices in their supply chain
• Risk: We procure renewable electricity from a range of PPA generators across the UK. We recognise that there is a risk of forced labour in the supply chains of renewable technologies like wind turbines.
• Tier: Tier 3 suppliers and below
• Mitigation: Established a supplier code of conduct that all suppliers are expected to sign and adhere to the practice defined within the code. Engagement with our PPA team to bring to attention the risks with the supply chain and build a bespoke management plan to manage this