Modern Slavery Act

Introduction

From 1st October 2023, SONI Ltd has operated with an independent Board of Directors, management and staff.  Prior to 1st October 2023, SONI Ltd was included within EirGrid plc’s group modern slavery statement.

This is SONI Limited’s (“SONI” or “the Company”) first Modern Slavery Statement in accordance with section 54 of the Modern Slavery Act 2025 which applies to the financial year ending 30^th September 2024.

SONI is the licenced electricity transmission system operator for Northern Ireland.  We operate the electricity transmission system in Northern Ireland and plan for its future.  We do not generate or sell electricity.  Our role is to ensure that power can flow safely, securely and reliably from where it is generated to where it is needed.

SONI is a subsidiary of EirGrid plc and is an independent business with its own Board of Directors, management and staff in accordance with its Transmission System Operator Licence. 

SONI is also the licenced Single Electricity Market Operator (SEMO) in Northern Ireland.  The SEM is the all-island wholesale electricity market jointly operated by SONI and EirGrid plc as a contractual joint venture.

Additionally, SONI is a designated Nominated Electricity Market Operator (NEMO) for Northern Ireland and through a contractual joint venture between the Company and EirGrid plc, implement the NEMO services in the SEM through SEMOpx, and administers the Capacity Market Code, through the Capacity Market Code joint venture.  SEMOpx provides day-ahead and intraday electricity market trading for Ireland and Northern Ireland as part of the Single Electricity Market. 

SONI’s customers include electricity demand and generation suppliers, wholesale market participants, customers seeking demand or generation connection to the grid and landowners and the communities in which the infrastructure is located.

As all the Company’s business is undertaken in Northern Ireland, SONI considers that the risk of modern slavery is more likely to arise from its supply chain than from its own operations.  Suppliers of goods/services to the Company are predominantly based in the UK and EU and are not considered to be at risk of modern slavery or human trafficking.

The Board recognises the key role suppliers play in ensuring the Company delivers its strategy with the provision of essential goods and managed services to the business.  The Company’s procurement practices are governed by the Utilities Contracts Regulations 2016.

The Board, the Chief Executive and the Executive Team are committed to upholding and respecting all aspects of human rights including ensuring that slavery and human trafficking is not taking place in our business or any of our supply chains.

SONI.’s Anti-Bribery & Corruption Policy sets out the Company’s “position on bribery, corruption (including modern slavery/human trafficking) and provides guidance on recognising bribery and corruption in its various guises” and is applicable to “all persons working for SONI or on its behalf in any capacity, including employees at all levels, Board Members, employees, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with SONI, wherever located.”

SONI takes a zero-tolerance approach to modern slavery, bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever the Company operates and implement and enforce effective systems to counter bribery and corruption.

Additional Company Policies which are considered relevant to the management of modern slavery related risks faced by SONI include:

All the above policies are available on the staff intranet.

During 2024, SONI has continued to take the following steps to mitigate the risk of modern slavery/human trafficking from occurring within its supply chains:

The continued application of the Company’s Enterprise Risk Management Framework enables the Company to continually identify, assess and respond to any risks associated with slavery/human trafficking and continue to assess the risk environment to ensure our controls remain fit for purpose.

KPIs used within the Company during the year to assist in measuring the risk of modern slavery related exposure are:

The above KPIs were reported to the Audit & Risk Committee on a quarterly basis.

During the year, the SONI Board reviewed and approved the following ethics-related policies in support of embedding an appropriate ethical culture:

The suite of ethics related policies was communicated to all employees by the Company’s GRC function.
 

This statement was approved by the SONI Board on 11^th March 2025.