1. Business Organisation, Structure and Supply Chain
This statement is made by and on behalf of EVBox B.V. (hereinafter referred to as “EVBox”). EVBox is active in the designing, manufacturing and supplying of charging solutions for electric vehicles and carries on part of its business in the UK. Since 2017, EVBox has been part of the ENGIE group of companies (“ENGIE”).
Our supply chain involves suppliers providing goods and services in relation to the products and services we offer, to our office needs and to running a business.
We are committed to the highest standards of ethical and legal business conduct, and we expect our suppliers to share the same commitment. As part of ENGIE, ENGIE’s commitments on ethics, social and environmental matters are part of our Code of Conduct in Supplier Relations including, amongst others, a commitment towards the prohibition of child labour and any other forms of forced or compulsory labour.
These commitments can be found here.
The Code of Conduct in Supplier Relations is directed at our own employees and sets out the seven principles we expect them to abide by in our relationships with suppliers. This includes a commitment to the ILO conventions on labour rights (e.g., prohibiting child and forced labour, and ensuring the safety and wellbeing of workers. We are also committed to providing fair working conditions and we expect our suppliers to treat their employees fairly and with dignity.
We also have a whistleblowing policy which covers the ability of employees to raise issues (including grievances). We have multiple channels where issues can be reported, such as a dedicated e-mail address supported by our ethics and compliance team and a dedicated hotline where reports of issues can be made both by EVBox employees and by third parties (anonymously if required).
3. Due Diligence and Risk Assessment
We have dedicated resources within our legal and compliance team and more generally throughout the company to identify risks and put in place processes and appropriate measures to assess, manage and minimise the risks of modern slavery within our supply chains.
As an employer of highly skilled and predominantly highly qualified talent, the risk of modern slavery within our business is considered low.
Our supply chain
As noted above, our suppliers provide goods and services for our products and services as well as for our office/business needs. We recognise there are suppliers involving potentially higher risk and some services involving relatively high levels of contracted labour.
We conduct due diligence on new suppliers to ensure that there are no negative reports before agreeing to engage them. We use third-party screening via a web-based platform to detect negative coverage relating to any third parties with whom we do business.
When contracting with suppliers, we endeavour that the contracts either contain an obligation to comply with our ethics principles and applicable policies or where they contain suppliers’ policies, such policies are at least comparable to our ethics principles and the standards set in our codes of conduct, specifically our Code of Conduct in Supplier Relations. We also have a Social and Environmental Responsibility schedule in our standard Purchase Terms and Conditions. The aim is to ensure that our suppliers are compliant with our standards. When accepting our Purchase Terms and Conditions, suppliers make representations and warranties that, in the 6-year period prior to signing our purchase terms, they had complied with all relevant laws relating to (amongst other things), human rights, child labour and forced / compulsory labour. This schedule also guarantees EVBox rights of audit to ensure that suppliers are compliant.
Where there is non-compliance, we expect our suppliers to take and evidence remedial steps to ensure their compliance within a reasonable amount of time. Where they still fail to comply, are unable to remedy the non-compliance to our reasonable satisfaction or where there is material non-compliance, we reserve the right to terminate our relationship with them.
4. Performance Indicators
For the coming FY 2022, we are working towards several goals as a company which we believe will strengthen our compliance in the modern slavery space. We have been raising awareness of our "speak up" culture through training programmes and promoting the use of our new reporting hotline. Through these initiatives we hope to create an environment in which employees will feel comfortable raising issues that they spot in our business.
5. Trainings and Audits
All our new employees complete a compulsory training as part of the onboarding process, which covers topics related to ethical, social and environmental matters. In addition, we have rolled out dedicated company-wide training sessions on ethics and compliance covering such topics such as ethical principles, whistleblowing and grievances procedures, ethics in business relationships with customers, suppliers and other third parties (with an emphasis on the necessity to have a due process and due diligence in place when selecting suppliers).
6. Board Approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2021. This statement has been approved by the management board of EVBox B.V. on 30 June 2022 and signed:
Designated board member on behalf of EVBox B.V. management board.