Modern Slavery Act
Our Modern Slavery & Human Trafficking Statement presents the measures EirGrid Group has taken to combat modern slavery in our business and supply chains.
Modern Slavery Statement 2024
Introduction
EirGrid Group operates and develops the electricity system in Ireland (EirGrid) and Northern Ireland (SONI Ltd). Our primary role is to operate, develop and enhance the all-island power system and the wholesale electricity market.
EirGrid Group’s revenue is primarily derived from regulated tariffs. The main revenue is the Transmission Use of System (TUoS) tariff which is a charge payable by all users of the transmission systems in Ireland (EirGrid) and Northern Ireland (SONI Ltd.).
The turnover from our licensed activities for the year ending 30 September 2023 was as follows:
This is EirGrid Group’s Modern Slavery & Human Trafficking Statement setting out the steps taken to combat modern slavery in our business and supply chains in accordance with the UK Modern Slavery Act 2015.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes EirGrid Group’s statement for the financial year ending 30 September 2023.
This statement is made by and on behalf of EirGrid Group.
Approach
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 are not taking place in our business or any of our supply chains.
Our approach is as follows:
Policies
We have a range of group policies and procedures embedded within the organisation which relate to how we do business, specifically:
- Our “Values & Behaviours” articulate the core values we hold as a business and the behaviours we expect all employees and contractors to portray in delivering these values including transparency and acting with integrity
- Employee and Director Codes of Conduct incorporate specific commitments to Modern Slavery and Human Rights, as well as emphasising our zero-tolerance approach to unethical practices and any form of bribery or corruption within the Company and the organisations we work with
- Protected Disclosures Policy provides guidance to our workforce and encourages and sets out our expectation for employees and others to report any concerns relating to a wrongdoing in the workplace and elsewhere in relation to EirGrid’s operations. EirGrid shall not tolerate any employee being discriminated against or suffering any detriment as a result of raising a concern
Due diligence
- During the year we performed a risk assessment review of our key suppliers in both EirGrid and SONI Ltd by value based on both geographical area and information available on their approach to modern slavery/human trafficking to ensure that controls are in place and to understand how effective these controls are to ensure that modern slavery does not exist within EirGrid Group’s supply chain
- Modern Slavery/Human Trafficking monitoring is embedded within our Anti-Bribery & Corruption Policy
- Group Procurement Procedures requiring “that all suppliers who participate in a formal tender process adhere to all statutory obligations under current Occupational Health & Safety, Environmental Management, Employment and Equality Legislation and the Modern Slavery Act"
- Supplier Terms & Conditions which require all suppliers of goods and services to demonstrate compliance with governing laws, anti-bribery and anti-corruption regulations
Risk management and review
Continued application of the Enterprise Risk Management Framework 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.
The steps for this are to:
- Identify risks
- Develop assessment criteria
- Assess risks
- Assess risk interactions
- Prioritise risks
- Risk response
Ongoing review of the application of the above policies and procedures is performed via our three lines of defence model. These are:
- 1st line: Operational functions and support functions such as HR and Finance
- 2nd line: Risk Management, Legal, Security, Quality Assurance, Health & Safety, Compliance
- 3rd line: Internal audit
Continuous improvement
We shall continue to promote awareness of our responsibility through the application of the above policies and processes. In addition, we intend to take the following steps in 2024 to further enhance our commitment to combating modern slavery:
- Monitor our key suppliers to ensure that controls are in place and to understand how effective these controls are to ensure that modern slavery does not exist within EirGrid Group’s supply chain
- Perform a focused risk-based review of a sample of our key suppliers on their approach to modern slavery/human trafficking
- Deliver awareness and refresher training to all employees
This statement was approved by the Board of Directors on 20 March 2024.