OPUS ENERGY LIMITED

Policies described

Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Human resources Procurement staff Other

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Professional auditors Workers within your supply chain Businesses in your industry or sector

Social audits

Third party audit arranged by your organisation Announced audit Unannounced audit

Grievance mechanisms

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

Other monitoring

Quarterly employee surveys. HSE management systems. Biomass certification which mandates that labour, pay and employment conditions are fair, legal and labour rights are safeguarded.

Demonstrated progress

Drax provided proportionate levels of training to colleagues. Drax maintain up to date due diligence information on supply chains that are high risk for modern slavery. In 2025, we updated our Country Risk Matrix identifying eight suppliers in medium risk countries. Our EDD process identified 85 suppliers in high risk sectors. Drax continues engagement with NGOs. The proportion of woody biomass pellets used at Drax Power Station with an SBP compliant claim was 99.9%

Reported risks and mitigations

• Risk: Third Party workers: Outsourced contractors and temporary labour across the business in industries including construction, Facilities, Logistics, Apparel and EV.
• Area: Within your own operations
• Group: Other vulnerable groups
• Location: United Kingdom
• Mitigation: In 2025 we reduced that risk by auditing suppliers in all these focus areas to obtain a greater insight into third-party practices. We also launched our enhanced ethical due diligence questionnaire, to gain greater transparency of suppliers’ commitments to human rights.
• Risk: Goods Not For Resale (GNRF): Poor visibility of potentially long and complex supply chains increases the risk of human rights and worker abuses taking place.
• Area: Within your supply chains
• Tier: Don't know
• Location: China
• Mitigation: In 2025 we reduced that risk with the ongoing Drax program of ethical audits and enhancing our ethical due diligence questionnaire which resulted in greater transparency of suppliers’ commitments to human rights. We plan to build of this progress in 2026.
• Risk: The materials sourced for biomass are mainly from remote locations, where there’s potential for the use of migrant workers. Poor visibility of such suppliers may increase the risk of worker abuses.
• Group: Migrants
• Location: Canada Estonia Latvia United States
• Mitigation: At the end of 2025, 100% of the suppliers of woody biomass to Drax Power Station (DPS) are SBP certified; this accounts for 95.45% of total biomass supplied to DPS. SBP encourages the adoption of standards and due diligence processes, including the promotion of human rights.