1. Business Organisation, Structure and Supply Chain
EV Charged B.V. is the parent company of 15 direct subsidiaries, including EVBox UK & Ireland, and is part of a group of 20 affiliates active in the field of design, manufacturing and supply of charging solutions for electric vehicles. We were acquired by the Engie group in 2017 and we have in excess of 600 employees, spread over 16 offices in Europe and North America.
Our supply chain involves suppliers providing goods and services in relation to the products and services we offer as well as those in relation to our office needs and more generally those of 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 the Engie group, we adopt Engie’s commitments on ethics, social and environmental policy as our Ethics policy and this includes, 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.
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. Due to rapid growth of the business, we are equally increasing the number of employees and our HR team is currently looking into putting in place robust policies and procedures concerning employment screening and employment conditions.
As noted above, our suppliers supply goods and services for our products and services as well as for our office/business needs. We recognise there are supplies involving potentially higher risk (for example, supplies of food and drink or cheap raw materials) and some services involving relatively high levels of contracted labour. We also recognise that there are potentially higher risks where the suppliers operate in high risk countries such as China, Vietnam, Tunisia and Ukraine.
When taking on new suppliers, our current practice is to conduct a due diligence search and ensure that there are no negative reports before agreeing to engage them. We are currently working on a comprehensive supplier onboarding programme where suppliers will be risk assessed and categorised by taking into account the nature of their business, their country of operation, the goods or services supplied and the industry characteristics. Suppliers categorised as presenting a significant risk of modern slavery will be subject to further due diligence, based on the availability of information through public sources including their own policies and procedures relating to modern slavery and human trafficking. Where, following further due diligence and checks, a supplier is still assessed as presenting a significant risk of modern slavery or failing to meet our standards, they will be required to complete a modern slavery questionnaire. If the completed questionnaires confirm our assessment of the suppliers presenting a significant risk or failing to meet our standards, and the risk or failure cannot be remedied, we will not enter into a relationship with them until such time we are satisfied that such risk or failure is no longer present. We are working towards putting the programme in place by Q4 of 2020.
To supplement this, we are also looking into putting in place a Supplier Code of Conduct which sets out the standards we expect suppliers to observe, including in respect of modern slavery risks. We are working towards having this in place by end of Q3 of 2020.
Since the end of 2018, when contracting with suppliers, we ensure that the contracts either contain an obligation to comply with our Ethics policy or where they contain suppliers’ policies, such policies are at least comparable to our Ethics policy. 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. For legacy agreements before the end of 2018, we have identified a small number of relevant suppliers with whom there is an ongoing relationship and are working on obtaining their agreement to comply with our Ethics policy.
For existing suppliers, we are working on an auditing process for supply chain verification which will involve, amongst other things, ensuring their commitment and compliance to our Ethics policy in relation to human rights and individual fundamental freedoms. We are working towards defining the auditing process by the end of Q1 of 2021.
4. Training, audits and next steps
In addition to the Ethics course that is mandatory for all our employees, we are currently working on rolling out a course that focuses specifically on modern slavery and human trafficking which will be an addition to the existing Ethics course. The course will be modelled closely in line with our Ethics policy and will be mandatory for all employees within the supply chain department as well as key personnel in our UK office. We are working towards having the course rolled out in Q2 of 2021.
In parallel, as mentioned above, we are also working on a supplier onboarding programme which will include requiring supplier commitments towards, amongst other things, prohibition of child labour and any other form of forced or compulsory labour. For suppliers without appropriate resources and/or those in high risk areas, we will also include information for them on how to recognise the risks of modern slavery and human trafficking in the supply chain, the consequences for failing to ensure that there is no modern slavery and human trafficking in their supply chains, as well as further guidance on how to handle potential violations. We are working towards putting these in place by Q1 of 2021.
We are committed in ensuring that we stay vigilant and we will periodically review and audit our business and supply chain to identify risks and implement any actions appropriate or necessary in counter modern slavery and human trafficking.
5. Board Approval
This statement has been approved by the management board of EV Charged B.V..
Peter Van Praet
Designated member on behalf of EV Charged B.V. management board.