VE UK & ROI – MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Vinci Energies UK & RoI Group anti-slavery and human trafficking statement for the financial year
ended 31st December 2020.

Group Overview

Vinci Energies UK Holding Limited and its subsidiaries which are listed below (“VE UK & RoI”) are
a group of companies operating under the worldwide VINCI Group, that contribute to a changing
world by connecting infrastructure, buildings and industrial sites to information and energy
systems to improve your life every day.
With locations in the United Kingdom and Republic of Ireland, VE UK & RoI employ over 1,185
employees across 28 Business Units delivering customised local solutions for each individual
project, from the smallest to the most complex.
VE UK & RoI are comprised of three brands; Actemium, Omexom and Axians. Actemium is
dedicated to the industrial process, helping its clients to improve their competitive advantage
and industrial performance. Omexom specialises in energy transition, from generation to
transmission and distribution grids and the final consumer’s meter. Axians is the ICT brand of
Vinci Energies that specialises in helping organisations to develop carrier-grade network
connectivity that successfully delivers a better end-user experience.
Although not Section 54 companies, VE UK & RoI have voluntarily complied with the provisions of
the Modern Slavery Act 2015 and have produced this Modern Slavery and Human Trafficking
Statement for the financial year ended 31st December 2020.

Policies and Procedures

VE UK & RoI are committed to complying with its obligations under the Modern Slavery Act 2015
and other relevant legislation relating to the prevention and detection of modern slavery and
human trafficking. VE UK & RoI are further committed to ensuring that effective controls are in
place to ensure that modern slavery or human trafficking is not taking place anywhere in its
business or its supply chains.
Within VE UK & RoI, the group is committed to ensuring transparency within each business and in
its approach to tackle modern slavery and upholding human rights within its supply chain by
expecting and requesting that the supply chain meets the same standards.

VE UK & RoI have policies in place which include, but are not limited to:

 VINCI Code of Ethics
 VINCI Guide on Human Rights
 VINCI Anti-Corruption Code of Conduct
 VINCI Manifesto

VINCI, which joined the United Nations Global Compact in 2003, has voluntarily committed to
comply with the 10 principles and communicating annually in the measures taken. In addition to
the Global Compact, VINCI and all its subsidiaries adhere to the following international standards:

 Universal Declaration of Human Rights (UDHR)
 United Nations Guiding Principles on Business and Human Rights
 OECD Guidelines for Multinational Enterprises

Sourcing & Contractual Standards

VE UK & RoI adopt a risk-based approach in selecting and managing its supply chain. This includes
reviews and risk mapping which includes risks relating specifically to modern slavery.
VE UK & RoI contract templates include contractual provisions which require suppliers, subcontractors or other agents to comply with laws and regulations including the Modern Slavery
Act 2015. Where existing contracts do not contain such provisions, VE UK & RoI will issue a
questionnaire to each relevant supplier, sub-contractor or other agent to ensure that such
standards are implemented within the supply chain.

Actions During the Financial Year Ending 31 December 2020

During the financial year ending 31 December 2020, VE UK & RoI took the following steps with
the intention of further ensuing that modern slavery and human trafficking does not take place in
its business or supply chains:

1. Third Party Management & Review

All new third parties who engage with VE UK & RoI are screened to ensure that
contractual controls are in place as well as independent reviews via the Refinitiv Tool
(Thomson Reuters). Regular third party management and review takes place at least
annually to identify and ensure that third parties – including customers – are in
compliance with laws related to modern slavery and human trafficking, including the
VINCI codes listed above.

2. Employment Practices & Financial Controls

VE UK & RoI companies are aware of the responsibilities relating to recruitment and
hiring. This includes ensuring payments to employees are made in to a bona fide bank
account and ensuring no cash payments are made. This applies to staff, fixed-term
employees, temporary staff and contractors.

3. Sourcing Practices and Due Diligence

When goods or services are procured from third parties, VE UK & RoI undertake a risk
assessment based which includes of the geographic indicators of modern slavery. A
riskmapping exercise is done for each company and any mitigation steps are identified.
During the financial year ending 31st December 2020, no issued have been identified
within any VE UK & RoI company.

Approval

This statement is made with the approval of the Board of Directors of Vinci Energies UK & RoI and
is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015 and constitutes the
Modern Slavery and Human Trafficking Statement for the financial year ending 31 December
2020 for the following entities:

VE UK & RoI SubsidiaryCompany Number

Actemium UK Limited 00065493
Powerteam Electrical Services (UK) Ltd t/a Omexom NI034635
Axians Networks Limited 04407184