The Modern Slavery Act of 2015 (the “Act”) defines Modern Slavery as “slavery, servitude and forced or compulsory labour”. So Energy vehemently opposes all forms of modern slavery and human trafficking and was founded with fairness, equality and inclusivity at its core, in line with our Company Values.
So Energy recognises that slavery and human trafficking is a global issue that must be addressed by companies across all industry sectors. So Energy recognises its responsibility to respect and promote human rights standards in everything we do, in line with ESB Group’s Human Rights Policy and Modern Slavery Policy, both of which apply in full to So Energy. So Energy expects all partners, contractors and suppliers of goods, services or works, whether to the company or on behalf of the company, to perform their duties in an honest and ethical manner, within the law and with respect for everyone’s human rights. We are committed to acting ethically in all of our business dealings and relationships and will take all reasonable steps to ensure human trafficking and/or modern slavery is not taking place anywhere in our business or in the organisations with whom we do business.
As per section 54 of the Act, we consider the risk of modern slavery and human trafficking within So Energy’s own operations to be low. There has been no evidence found of modern slavery or forced labour across our organisation, but we remain vigilant and continue to evolve our processes and controls to guard against risk. While unlikely, if we were to discover that any organisation we work with was involved in such exploitation, we would take all appropriate measures, up to and including termination of the relationship and reporting the matter to the appropriate authorities.
We carry out due diligence with our suppliers to confirm that they adhere to the ethical standards we require and will only work with those that meet those standards. This due diligence is currently carried out primarily through supplier questionnaires and contractual assurances; So Energy is reviewing whether more active verification measures, such as targeted audits or site-based checks, would be appropriate for higher-risk parts of its supply chain.
So Energy employs approximately 400 Energists (“our employees”).
So Energy’s in-house Talent team applies fair, consistent and compliant recruitment practices for permanent and temporary appointments. These practices support equal opportunities, fair pay and adherence to current legislation, helping to ensure our workforce is recruited lawfully and is free from modern slavery. We believe that all employees and job applicants must be treated fairly and given the same opportunities regardless of age, sex, race, disability, sexual orientation, culture or any other personal characteristic protected under law. As part of our new starter process, right to work checks are completed and supported by relevant documentation before employment commences. New starters are also subject to relevant pre-employment checks, including third-party vetting, basic criminal record checks and employment history checks where applicable, and are not permitted to commence employment with So Energy until the required checks have been completed. So Energy is also a proud member of the Disability Confident Scheme, which supports employers to improve how they recruit, retain and develop disabled people.
Additionally, certain roles within So Energy may require further third-party vetting measures, depending on the area of the business, the level of the role and any applicable regulatory requirements. This includes additional vetting for individuals with significant control, managerial responsibility or influence, in line with Ofgem requirements.
During 2025, So Energy continued to maintain and review local controls designed to reduce the risk of modern slavery and human trafficking within its own operations. These controls include pre-employment screening, right to work checks, use of approved recruitment partners, clear onboarding processes, and internal policies which support ethical conduct, fair treatment and routes for raising concerns.
So Energy employees are encouraged to raise concerns where they believe wrongdoing, unethical conduct or unsafe practices may be taking place. Concerns can be raised through internal reporting routes, including line management, the People Team and So Energy’s whistleblowing/Your Voice channels, as well as through relevant ESB Group reporting routes where applicable. Any concerns relating to modern slavery, forced labour or human trafficking would be taken seriously and escalated in line with our internal governance processes.
So Energy also continues to review its supplier and third party relationships to ensure, where appropriate, that contractual and onboarding arrangements reflect the standards expected of those working with or on behalf of So Energy. Where suppliers, contractors or agency partners are engaged, So Energy expects them to comply with applicable employment legislation, operate ethically and support the prevention of modern slavery and human trafficking within their own operations and supply chains.
No concerns or incidents of modern slavery or human trafficking were identified within So Energy’s own operations during 2025. So Energy will continue to strengthen its local approach through ongoing policy review, supplier due diligence, recruitment controls and alignment with ESB Group policies and governance frameworks.
ESB Group
So Energy is part of the Electricity Supply Board Group (“ESB Group”). ESB Group’s Modern Slavery Policy and Human Rights Policy apply in full to So Energy.
ESB is a vertically integrated utility operating across electricity generation, transmission, distribution and supply in Ireland and the United Kingdom. Further details of ESB’s business operations can be found at www.esb.ie.
ESB operates a zero tolerance approach to modern slavery and human trafficking and is committed to acting ethically and with integrity in all business dealings and relationships. ESB maintains and enforces policies, procedures and controls designed to reduce the risk of modern slavery occurring within its operations or supply chains.
ESB’s Human Rights Policy sets out its approach across a number of areas, including health and safety, environment and sustainability, cultural diversity, equal opportunities and diversity, anti-bribery, corruption and fraud, whistleblowing and modern slavery. ESB’s Modern Slavery Policy sets out the actions ESB will take to assist in preventing modern slavery, the roles and responsibilities from Board level to individual employees, and the process for reporting suspected incidents. Employees, contractors and suppliers are encouraged to raise concerns through a confidential helpline.
During 2025, ESB undertook a number of actions to assist in preventing modern slavery within its supply chain. These included Contractor Employment Standards audits across ESB-managed sites in Ireland and the United Kingdom, supplier self-assessment questionnaires, a follow-on audit at a key supplier facility in India, periodic supplier risk analysis, updates to ESB’s Modern Slavery Policy, and continued development of its supply chain risk management approach. These activities relate to ESB Group’s own operations and supply chain and, to date, have not specifically included audits or assessments of So Energy’s suppliers or contractors, whose contractual arrangements differ from those of ESB.
ESB also requires tenderers to acknowledge and confirm compliance with ESB’s requirements for third parties, which include contractual obligations reflecting ESB’s approach to addressing modern slavery in supply chains. In 2025, ESB also engaged with suppliers regarding its sustainability objectives, published an updated Supplier Charter, joined the Solar Stewardship Initiative and continued its membership of the Responsible Commodities Sourcing Initiative.
In order to understand how effective these controls are in mitigating the risk of modern slavery, ESB assesses supplier and contractor controls through external audits where appropriate, particularly where suppliers or contractors operate in higher-risk regions or industries. No incidents of modern slavery were identified in 2025.
Signed by Charlie Davies, Chief Executive Officer.