Modern Slavery Statement

Genpower Ltd has a zero-tolerance approach to modern slavery and in our organisation and our supply chains. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

Slavery and human trafficking – No employee shall be subject to slavery or have been the victim of human trafficking. Guidance issued by the UK Government explains what is meant by the terms “slavery” and “human trafficking” as follows:

(a) “Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behavior on the part of the offender as if he/ she did own the person, which deprives the victim of their freedom.”

(b) “An offense of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offense can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offense to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation.”

We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain. We take a risk based approach to our contracting processes and keep them under review.

Consistent with our risk based approach we may require:


  • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our policy.
  • As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our policy.
  • All suppliers must hold accurate records of the ages and working hours of all employees who in all cases must not be less than the legal minimum age as required under the relevant national Law.
  • All suppliers must hold accurate records of the working hours of all employees and such hours must not exceed the legal maximum. All employees must receive a reasonably acceptable number of breaks, days off and holidays.
  • All wages must meet or exceed legal minimum levels and any deductions must be reasonable, agreed and understood by the employees.
  • There must be no discrimination in the hiring of employees, who should all be provided with a written contract of employment and disciplinary rules in a language they can understand.
  • There must be no physical or verbal abuse of employees.All suppliers must employ a Health and Safety Manager who is empowered to deliver a safe working environment, where all risks of injury through exposure to fire or flood, materials, power, equipment, machinery or hazardous activities have been assessed and minimised. All working conditions should be clean, hygienic and meet all legal standards and all employees should have ready access to clean drinking water at all times.

If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Where our staff have concerns around issues of forced labor, human rights, recruitment practices or exploitation, they are encouraged and expected to report concerns to our HR department. All reports will be investigated fully.