Modern Slavery Statement archive

Below is an archive of Cubico’s Modern Slavery Statements from 2016 to 2022.

Modern Slavery Statement Financial Year 2022

STATEMENT UNDER S.54 OF THE MODERN SLAVERY ACT 2015

1. Introduction

This modern slavery statement is published pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) and covers the financial year 1 January 2022 to 31 December 2022. The statement reinforces our commitment to compliance with the Act and sets out the steps we have taken during 2022 to prevent modern slavery from occurring in our business and supply chain.

2. About Cubico

Cubico is a global independent power provider working in 12 countries on four continents. Headquartered in London, UK, we have regional offices in Australia (Sydney and Melbourne), Brazil (São Paulo), Colombia (Bogotá), Greece (Athens), Italy (Milan), Mexico (Mexico City), Spain (Madrid), Uruguay (Montevideo) and the USA (Austin and Stamford).

We have an operational capacity of over 2,690 MWs, plus 1,970 MW under development (as at 31 December 2022). Our asset portfolio includes solar photovoltaic, onshore wind, concentrated solar power (CSP), and transmission/distribution networks.

Covering the entire energy chain, from development, construction and operation, we add clean energy to local electricity grids, thereby decreasing the world’s reliance on more carbon-intensive coal and natural gas. We are acutely aware of the role we have as ESG stewards in ensuring that our investments meet best practice standards and operating to high ethical standards is central to our organisation.

Our organisation is split broadly between corporate activities and operational activities.

Corporate Activities

Our corporate activities are performed at our regional offices where employees undertake skilled activities including project origination and execution, managing development and construction activities, managing assets on a day-to-day basis and corporate services (finance, tax, legal, HR).

Our corporate activities have only an occasional dependence on temporary workers and contractors and the nature of that work is of a professional service nature.

Development, Construction and Operational Activities

Our development, construction and operational activities constitute the development, construction and operation of renewable energy and transmission / distribution assets ‘on the ground’.  All outsourced construction, operation and maintenance and asset management activities are managed through contracts with the various third parties in commercially agreed forms on a medium or long term basis and include comprehensive ethical compliance and modern slavery obligations and undertakings.

3. Risk Assessment

Corporate Activities

We have assessed that, given our internal operating standards, the risk of modern slavery occurring in our corporate activities is low.  However, we remain vigilant to the risks particularly with respect to the limited low skilled outsourced labour that we engage at our offices (e.g. cleaning services).  All employees in our corporate offices undertake regular Ethical Compliance training, which includes Modern Slavery training, and are regularly reminded how to identify instances of modern slavery were they to arise. Detailed modern slavery e-learning is also provided to the most relevant employees.

Development, Construction and Operational Activities

We have also assessed the risks of modern slavery occurring in our development, construction and operational activities and identified key areas of focus to be:

  • Our high-risk jurisdictions: Cubico has a global footprint and operates in a number of jurisdictions. Some of those jurisdictions pose a higher risk than others and are monitored more closely as a result.
  • Outsourcing of operational activities: Whilst Cubico predominantly contracts with large, well-established suppliers we acknowledge that they do not always have their own directly employed local work forces in the remote locations of some of our projects.
  • The nature of the work undertaken, including:
    • construction of assets and the infrastructure that supports them;
    • outsourcing of operation and management activities associated with finished assets; and
    • outsourcing of low skilled maintenance work at assets, particularly in higher risk jurisdictions.
  • Risks of forced labour in the supply chain of polysilicon (a key component of PV solar panels) originating from Xinjiang, China.

Slavery and trafficking risks are already taken into account in the assessments made when Cubico is deciding whether to acquire or develop assets in a new country.  Cubico’s Compliance team has a central role in advising the organisation on those risks.

4. Controls to Address Risks

We have a number of controls in place to mitigate the risks of modern slavery in our organisation and supply chains, as follows:

Slavery and trafficking policies and governance

Cubico maintains a comprehensive Ethical Compliance Programme, managed by the Compliance Officer. The Programme includes a number of Compliance Policies such as the Code of Conduct, ABC Policy, Procurement & Business Partner Vetting Policy and Supplier Code of Conduct and Corporate Compliance Statements which make clear that good corporate governance and the professional ethics of our employees and suppliers are the pillars upon which Cubico’s activity is based.

Our Supplier Code of Conduct sets the standards that Cubico expects from its suppliers, joint venture partners, sellers, developers, acquisition targets, service providers and other stakeholders with whom we engage (together referred to as “Third Parties”) with respect to forced labour, slavery and similar practices and makes clear that workers employed directly or indirectly should be treated fairly, with respect and in accordance with law.  We place a contractual obligation on all medium and high risk Third Parties to adhere to our Supplier Code of Conduct and include Modern Slavery representations and warranties in contract which give us a right of termination if breached. We also include a contractual right to audit Third Parties where appropriate to ensure they operate in line with our ethical standards.

KYC Reports and Due Diligence

Our Procurement & Business Partner Vetting Policy sets out our approach in assessing whether Third Parties maintain appropriate standards with respect to the prevention of modern slavery in their own operations and supply chains. Prior to engaging Third Parties that are categorised as medium or high risk, we perform KYC screening which assesses of the risks of modern slavery and highlights and adverse media relating to previous modern slavery related incidents. During 2022 no KYC reports were generated which raised specific concerns with respect to modern slavery. Where we acquire a new business or asset, as part of the due diligence process, we request the seller and target to complete a Compliance Questionnaire which includes questions relating to modern slavery and the controls they have in place to mitigate risks.

Whistleblowing Hotline

Cubico is committed to identifying inappropriate and illegal conduct in our business and remedying wrongdoing. To this end Cubico maintains an external, independent whistleblowing hotline which is promoted widely internally and externally to employees and Third Parties who are encouraged to report any ethical concerns they have, including with respect to modern slavery or unfair treatment of workers. No reports relating to modern slavery concerns were received in 2022.

Training

All Cubico employees undertake regular Ethical Compliance Training, which includes Modern Slavery training. Furthermore, certain employees periodically complete Modern Slavery e-learning.

Site Visits

Our Head of HSE regularly undertakes site visits. During such visits he assesses modern slavery risks which enhances our risk management practices and controls. The Executive Committee, including the CEO, CFO, General Counsel and Global Head of Operations and Country Heads do a number of on-site safety walks every year which include an assessment of compliance and modern slavery risks. No areas of specific concern were identified which required further action or investigation with respect to modern slavery.

Supply Chain Exposure Risk Assessment

Polysilicon, a key component in the manufacture of solar panels, which originates from Xinjiang, China has been linked to potential forced labour risk. Consequently, Cubico has taken a number of steps to avoid sourcing solar panels tied to forced labour and to ensure compliance with new forced labour regulations in key markets. We have engaged an independent auditor to conduct a Supply Chain Exposure Risk Assessment of panel manufacturers in Southeast Asia. The results of the assessments enable Cubico to make a more informed decision when selecting panel providers to ensure that there are no forced labour concerns. In addition, we have implemented enhanced governance controls, such as including detailed forced labour contractual protections in panel supply agreements. This extra measure is in place as an additional safeguard to prevent Cubico from obtaining production materials derived using illicit labour practices.

5. Future Actions

We remain committed to combating the risks of modern slavery and it is a key priority for Cubico’s Compliance team, alongside the Internal Auditor and Procurement Manager. In particular, we will:

  • continue to develop our risk analysis and selection of Third Parties by conducting ongoing KYC and reviewing, refreshing and, as appropriate, reissuing our Compliance Questionnaire;
  • continue to conduct Compliance audits of key Third Parties to ensuring they have appropriate modern slavery controls within their business or supply chains;
  • continue to embed employees’ understanding of modern slavery risks through training and so that they remain vigilant and follow the controls that we have in place to reduce these risks;
  • continue to carry out due diligence and audits on Third Parties and our own assets via site visits conducted by our Head of HSE, Executive Committee and Country Heads;
  • continue to enforce the requirements of the Supplier Code of Conduct;
  • continue to liaise directly with our Head of HSE on issues/risks he identifies and make recommendations to Cubico’s Compliance team;
  • refresh our assessment of our suppliers and identify any Third Parties who we deem high risk;
  • continue to review and respond to the results of the ongoing Supply Chain Exposure Risk Assessment to ensure that we only engage with manufactures of solar panels who can guarantee their products are free from the use of forced labour; and
  • continue to advertising our whistleblowing hotline both internally to employees and externally to our Third Parties.

This statement is made by Cubico Sustainable Investments Limited and the board of directors of the company have approved it and will update it annually.

Modern Slavery Statement Financial Year 2021

STATEMENT UNDER S.54 OF THE MODERN SLAVERY ACT 2015

1. Introduction

This our sixth modern slavery statement made in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) and covers the financial year from 1 January 2021 to 31 December 2021. We fully support the aims of the Act and are committed to operating free from any form of modern slavery.

2. Background

Cubico is a global leader in renewable energy, with an operational capacity of over 3 gigawatts (GW), plus more than 2 GW in construction and under development (as at 31 December 2021). Our asset portfolio includes onshore wind, solar photovoltaic, concentrated solar power and transmission line technologies covering the whole energy chain from development and/or construction to operation.

We aim to reshape the future of energy production and we are committed to doing this while protecting the environment and supporting the communities we operate in.

Our organisation is split broadly between corporate activities and operational activities.

Corporate Activities

Our corporate activities are performed at the following offices: London (where we are headquartered), Sydney and Melbourne (Australia), Fortaleza and São Paulo (Brazil), Bogotá (Colombia), Bordeaux (France), Athens (Greece), Milan (Italy), Mexico City (Mexico), Madrid (Spain), Montevideo (Uruguay) and Stamford (Stamford).

Employees in these offices undertake skilled activities including project origination and execution, managing development and construction activities, managing assets on a day-to-day basis and corporate services (finance, tax, legal, HR).

Our corporate activities have only an occasional dependence on temporary workers and contractors and the nature of that work is of a professional service nature.

Development and Operational Activities

Our development and operational activities constitute the development, construction and operation of renewable energy and transmission / distribution assets ‘on the ground’. We predominantly outsource the construction of new assets to contractors experienced in these areas. Once our assets are in service, we predominantly outsource the operation and maintenance work. Our asset management services, which include providing support and resources to the relevant project companies to enable effective supervision and monitoring of the assets and oversight of contractors, and to provide certain corporate, legal and other back-office services are partially outsourced.  All outsourced construction, operation and maintenance and asset management activities are managed through contracts with the various third parties in commercially agreed forms on a medium or long term basis, and include comprehensive compliance clauses.

3. Slavery and trafficking policies

Cubico recognises the inherent role we have as stewards in ensuring that all our investments meet best practice environmental, social and governance (ESG) standards and operating to high ethical standards is central to our organisation. Our General Code of Conduct, Supplier Code of Conduct, Anti-bribery and Corruption Policy and Corporate Compliance Statements make clear that good corporate governance and the professional ethics of our employees and suppliers are the pillars upon which Cubico’s activity is based.

We have welcomed the increased focus brought to bear by the United Kingdom’s Modern Slavery Act 2015 and the Legal and Compliance team implement and review controls to address the risks of modern slavery occurring in our operations and supply chains.

Cubico’s Compliance Policies include explicit references to modern slavery. This includes our Anti-bribery and Corruption Policy, Code of Conduct and Procurement & Business Partner Vetting Policy to which employees can turn for guidance. Our Procurement & Business Partner Vetting Policy has increased the clarity of our approach in assessing whether suppliers, joint venture partners, sellers, developers, acquisition targets and other stakeholders with whom we engage (together referred to as “Third Parties”) maintain appropriate standards with respect to the prevention of modern slavery in their own operations and supply chains.

We continue to commission KYC Reports at certain key points in our relationships with Third Parties that are categorised as medium or high risk.  These reports incorporate an assessment of the risks of modern slavery. During 2021 no KYC Reports were generated which raised specific concerns with respect to modern slavery.

We also have a Supplier Code of Conduct which sets out the standards we expect from all those who work for and with us with respect to combating modern slavery, anti-bribery and corruption and health and safety standards. We continue to place a contractual obligation on all medium and high risk Third Parties to adhere to our Supplier Code of Conduct and periodically send our Supplier Code of Conduct to certain Third Parties and ask them to reconfirm that they will comply with the terms thereof. Furthermore, we conduct Compliance audits of our key Third Parties to ensure they operate in line with our ethical standards.

4. Risk assessment

Corporate Activities

We have assessed that, given our internal operating standards, the risk of modern slavery occurring in our corporate activities is low.  However, we remain vigilant to the risks particularly with respect to the limited low skilled outsourced labour that we engage at our offices (e.g. cleaning services).  Employees in our corporate offices have undertaken modern slavery training as part of our annual Compliance Training and are aware of how to identify instances of modern slavery were they to arise.

Development and Operational Activities

We have also assessed the risks of modern slavery occurring in our development and operational activities and identified key areas of focus to be:

  • Our high-risk jurisdictions: Cubico has a global footprint and operates in a number of jurisdictions. Some of those jurisdiction pose a higher risk than others and are monitored more closely as a result.
  • The high levels of outsourcing of operational activities (as described above): Whilst Cubico predominantly contracts with large, well established suppliers we acknowledge that even they do not always have their own directly employed local work forces in the remote locations of some of our projects.
  • The nature of the work undertaken, including:
  • construction of assets and the infrastructure that supports them;
  • outsourcing of operation and management activities associated with finished assets; and
  • outsourcing of low skilled maintenance work at assets, particularly in higher risk jurisdictions.
  • Risks of forced labour in the supply chain of polysilicon (a key component of PV solar panels) originating from Xinjiang, China.

Slavery and trafficking risks are already taken into account in the assessments made when Cubico is deciding whether to acquire or develop assets in a new country.  The Legal and Compliance team have a central role in advising the organisation on those risks.

5. Due diligence and actions to address risks

We have a number of controls in place to mitigate the risks of modern slavery in our organisation and supply chains, as follows.

  • We commission KYC Reports on medium and high risk Third Parties prior to them being engaged. This helps us identify whether they have previously been involved in, or associated with, any instances of modern slavery.
  • Where we acquire a new business or asset, as part of the due diligence process, we request the seller and target to complete a Compliance Questionnaire which includes questions relating to modern slavery and the controls they have in place to mitigate risks.
  • Our contracts with medium and high risk Third Parties include Modern Slavery and ABC representations and warranties which give us a right of termination if breached as well as an obligation to comply with Cubico’s Supplier Code of Conduct. We also include a contractual right to audit Third Parties where appropriate.
  • We conduct compliance audits of key Third Parties, which includes assessing risks of modern slavery occurring in their business and supply chains.
  • All Cubico employees undertake annual Compliance Training, which includes a section on Modern Slavery. Furthermore, certain employees periodically complete Modern Slavery e-learning.
  • Our Head of HSE regularly undertakes site visits. During such visits he assesses our modern slavery risks which enhances our risk management practices and controls. The Executive Committee, including the CEO, CFO, General Counsel and Global Head of Asset Management do a number of on-site safety walks every year which include an assessment of compliance and modern slavery risks. The Executive Committee and the Head of HSE did not identify any areas of specific concern which required further action or investigation with respect to modern slavery.
  • We maintain a confidential and independent whistleblowing hotline which employees and Third Parties can use to raise concerns in relation to improper, unethical or illegal practices. Cubico is committed to dealing with whistleblowing reports and we ensure that those who speak up are protected from retaliation.
  • In response to allegations of forced labour in the solar industry in Xinjiang, China, we took the initiative to track the origin of polysilicon in our solar panel supply chains by engaging an independent auditor to conduct risk assessments of panel manufacturers in Southeast Asia. The assessments determine manufacturers’ own ability to trace the origin of polysilicon used in their panels and have two phases: (i) a desktop documentation review, based on manufacturers’ declarations as to the source of their polysilicon; and (ii) an evidence-based on-site audit where the auditor verifies declarations of the manufacturers through sampling, collection and a final review of the evidence. The results of the assessments enable Cubico to make a more informed decision when selecting panel providers to ensure that there are no forced labour concerns. In addition, Cubico has implemented enhanced governance controls, such as including detailed forced labour contractual protections in panel supply agreements. This extra measure is in place as an additional safeguard to prevent Cubico from obtaining production materials derived using illicit labour practices. 

6. Our proposals for 2022 and beyond

We are committed to combating the risks of modern slavery occurring within our organisation and supply chains.  Cubico’s Legal and Compliance team, alongside the Internal Auditor and Procurement Manager, have specific remit to further address the risks and will lead initiatives to:

  • continue our work in assessing our high and medium risk Third Parties and to develop our risk analysis and selection of suppliers including by conducting ongoing KYC and reviewing, refreshing and, as appropriate, reissuing our Compliance Questionnaire;
  • continue to conduct Compliance audits of key Third Parties to ensuring they have appropriate controls to ensure there is no modern slavery within their business or supply chains.
  • continue to embed employees’ understanding of modern slavery risks through annual Compliance Training so that they remain vigilant and follow the controls that we have in place to reduce these risks;
  • continue to periodically commission specific modern slavery e-learning for relevant employees;
  • continue to carry out due diligence and audits on suppliers and our own assets via site visits conducted by our Head of HSE and Executive Committee;
  • continue to enforce the requirements of the Supplier Code of Conduct;
  • continue to liaise directly with our Head of HSE on issues/risks he identifies and make recommendations to Cubico’s Legal and Compliance team;
  • refresh our assessment of our suppliers and identify any Third Parties who we deem high risk; and
  • continue to review and respond to the results of the ongoing Supply Chain Exposure Risk Assessment to ensure that we only engage with manufactures of solar panels who can guarantee their products are free from the use of forced labour.

This statement is made by Cubico Sustainable Investments Limited and the board of directors of the company have approved it and will update it annually.

Modern Slavery Statement Financial Year 2020

STATEMENT UNDER S.54 OF THE MODERN SLAVERY ACT 2015

1. Introduction

This our fifth modern slavery statement made in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) and covers the financial year from 1 January 2020 to 31 December 2020. We fully support the aims of the Act and are committed to operating free from any form of modern slavery.

2. Background

Cubico is one of the world’s largest privately-owned renewable energy companies, with an operational capacity of over 2.8 gigawatts (GW), plus more than 1.4 GW under development, across 121 wind and solar assets (as at 31 December 2020).

We are fully committed to playing a significant role in the transition towards a clean energy world optimizing the use of natural resources while respecting the environment and the social development of the communities in which we are present.

Our organisation is split broadly between corporate activities and operational activities.

Corporate Activities

Our corporate activities are performed at the following offices: London (where we are headquartered), Uxbridge (UK), Madrid (Spain), Milan (Italy), Bordeaux (France), Sydney (Australia), Mexico City (Mexico), Stamford (USA), São Paulo (Brazil), Fortaleza (Brazil), Bogotá (Colombia), Athens (Greece) and Montevideo (Uruguay).

Employees in these offices undertake skilled activities including project origination and execution, managing development and construction activities, managing assets on a day-to-day basis and corporate services (finance, tax, legal, HR).

Our corporate activities have only an occasional dependence on temporary workers and contractors and the nature of that work is of a professional service nature.

Development and Operational Activities

Our development and operational activities constitute the development, construction and operation of renewable energy and transmission / distribution assets ‘on the ground’. We predominantly outsource the construction of new assets to contractors experienced in these areas. Once our assets are in service, we predominantly outsource the operation and maintenance work. Our asset management services, which include providing support and resources to the relevant project companies to enable effective supervision and monitoring of the assets and oversight of contractors, and to provide certain corporate, legal and other back-office services are partially outsourced.  All outsourced construction, operation and maintenance and asset management activities are managed through contracts with the various third parties in commercially agreed forms and are generally on a medium or long term basis.

3. Slavery and trafficking policies

Operating to high ethical standards is central to our organisation. Our General Code of Conduct, Supplier Code of Conduct and Anti-bribery and Corruption Policy make clear that good corporate governance and the professional ethics of our employees and suppliers are the pillars upon which Cubico’s activity is based.

We have welcomed the increased focus brought to bear by the United Kingdom’s Modern Slavery Act 2015 and the Legal and Compliance team have responsibility for implementing and reviewing controls to address the risks of modern slavery occurring in our operations and supply chains.

Cubico’s Compliance Policies include explicit references to modern slavery. This includes our Anti-bribery and Corruption Policy, Code of Conduct and Procurement & Business Partner Vetting Policy to which employees can turn for guidance. Our Procurement & Business Partner Vetting Policy has increased the clarity of our approach in assessing whether suppliers, joint venture partners, sellers, developers, acquisition targets and other stakeholders with whom we engage (together referred to as “Third Parties”) maintain appropriate standards with respect to the prevention of modern slavery in their own operations and supply chains.

We continue to commission KYC Reports at certain key points in our relationships with Third Parties that are categorised as medium or high risk.  These reports incorporate an assessment of the risks of modern slavery. During 2020 no KYC Reports were generated which raised specific concerns with respect to modern slavery.

We also have a Supplier Code of Conduct which sets out the standards we expect from all those who work for and with us with respect to combating modern slavery, anti-bribery and corruption and health and safety standards. We continue to place a contractual obligation on all medium and high risk Third Parties to adhere to our Supplier Code of Conduct and periodically send our Supplier Code of Conduct to certain Third Parties and ask them to reconfirm that they will comply with the terms thereof.

4. Risk assessment

Corporate Activities

We have assessed that, given our internal operating standards, the risk of modern slavery occurring in our corporate activities is relatively low.  However, we remain vigilant to the risks particularly with respect to the limited low skilled outsourced labour that we engage at our offices (e.g. cleaning services).  Employees in our corporate offices have undertaken modern slavery training and are aware of how to identify instances of modern slavery were they to arise.

Development and Operational Activities

We have also assessed the risks of modern slavery occurring in our development and operational activities and identified key areas of focus to be:

  • Our high-risk jurisdictions: Cubico has a global footprint and operates in a number of jurisdictions. Some of those jurisdiction pose a higher risk than others and are monitored more closely as a result.
  • The high levels of outsourcing of operational activities (as described above): Whilst Cubico predominantly contracts with large, well established suppliers we acknowledge that even they do not always have their own directly employed local work forces in the remote locations of some of our projects.
  • The nature of the work undertaken, including:
  • construction of assets and the infrastructure that supports them;
  • outsourcing of operation and management activities associated with finished assets; and
  • outsourcing of low skilled maintenance work at assets, particularly in higher risk jurisdictions.
  • Risks of forced labour in the supply chain of polysilicon originating from Xinjiang, China.

Slavery and trafficking risks are already taken into account in the assessments made when Cubico is deciding whether to acquire or develop assets in a new country.  The Legal and Compliance team have a central role in advising the organisation on those risks.

5. Due diligence and actions to address risks

We have a number of controls in place to mitigate the risks of modern slavery in our organisation and supply chains, as follows.

  • We commission KYC Report on medium and high risk Third Parties prior to them being engaged. This helps us identify whether they have previously been involved in, or associated with, any instances of modern slavery.
  • Where we acquire a new business or asset, as part of the due diligence process, we request the seller and target to complete a Compliance Questionnaire which includes questions relating to modern slavery and the controls they have in place to mitigate risks.
  • Our contracts with medium and high risk Third Parties include Modern Slavery and ABC representations and warranties which give us a right of termination if breached as well as an obligation to comply with Cubico’s Supplier Code of Conduct. We also include a contractual right to audit Third Parties where appropriate.
  • All Cubico employees undertake annual Compliance Training, which includes a section on Modern Slavery. Furthermore, certain employees completed Modern Slavery e-learning and this will be repeated going forwards.
  • Our Global Health and Safety Manager regularly undertakes site visits. During such visits he assesses our modern slavery risks which enhances our risk management practices and controls. The Executive Committee, including the CEO, CFO, General Counsel, Global Head of Asset Management, Head of Americas and Head of EMEA, do a number of on-site safety walks every year which include an assessment of compliance and modern slavery risks. During 2020 the site visits were conducted virtually due to the impact of COVID-19. The Executive Committee and the Global Health and Safety Manager did not identify any areas of specific concern which required further action or investigation with respect to modern slavery.
  • We maintain a confidential and independent whistleblowing hotline which employees and Third Parties can use to raise concerns in relation to improper, unethical or illegal practices. Cubico is committed to dealing with whistleblowing reports and we ensure that those who speak up are protected from retaliation.
  • In response to allegations of forced labour in the solar industry in Xinjiang, China, we commissioned a consultant to conduct a Supply Chain Exposure Risk Assessment of a number of manufactures of solar panels in China and South East Asia.

6. Our proposals for 2021 and beyond

We are committed to combating the risks of modern slavery occurring within our organisation and supply chains.  Cubico’s Internal Auditor and Procurement Manager alongside the Legal and Compliance team, have specific remit to further address the risks and will lead initiatives to:

  • continue our work in assessing our high and medium risk Third Parties and to develop our risk analysis and selection of suppliers including by conducting ongoing KYC and reviewing, refreshing and as appropriate reissuing our Compliance Questionnaire;
  • via site visits conducted by our Global Health and Safety Manager and Executive Committee, continue to carry out due diligence and audits on suppliers and our own assets;
  • continue to enforce the requirements of the Supplier Code of Conduct;
  • continue to liaise directly with our Global Health and Safety Manager on issues/risks he identifies and make recommendations to Cubico’s Legal and Compliance team;
  • refresh our assessment of our suppliers and identify any Third Parties who we deem high risk;
  • through annual Compliance Training, continue to embed employees’ understanding of modern slavery risks so that they remain vigilant and follow the controls that we have in place to reduce these risks; and
  • review and respond to the results of the 2021 Supply Chain Exposure Risk Assessment to ensure that we only engage with manufactures of solar panels who can guarantee their products are free from the use of forced labour.

Modern slavery will continue to be a standing agenda point in respect of all quarterly risk management meetings which are attended by all heads of country.

This statement is made by Cubico Sustainable Investments Limited and the board of directors of the company have approved it and will update it annually.

Modern Slavery Statement Financial Year 2019

STATEMENT UNDER S.54 OF THE MODERN SLAVERY ACT 2015

1. Introduction

This is a statement made by Cubico in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 January 2019 to 31 December 2019.

2. Background

Cubico is one of the world’s leaders in providing renewable energy, the fastest-growth energy source, across the Americas and Europe. Our portfolio includes onshore wind, solar photovoltaic and solar thermal assets.

We are fully committed to playing a significant role in the transition towards a clean energy world optimizing the use of natural resources while respecting the environment and the social development of the communities in which we are present.

Our organisation is split broadly between corporate activities and operational activities.

Corporate Activities

Our corporate activities are performed at the following offices: London (where we are headquartered), Uxbridge (UK), Madrid (Spain), Milan (Italy), Lyon (France), Sydney (Australia), Mexico City (Mexico), Stamford (USA), São Paulo (Brazil). We have recently opened new offices in Uruguay and Colombia, and these are now operational and have been throughout the financial year in question.  Employees in these offices undertake skilled activities including project origination and execution and corporate services (finance, tax, legal, HR).  We also have an office in Fortaleza (Brazil) where both corporate activities (providing legal, technical and finance/accounting support to the Brazilian projects) and operational activities (providing day-to-day operational support to the Brazilian projects) are undertaken.

Our corporate activities have only an occasional dependence on temporary workers and contractors and the nature of that work is mainly of a professional service nature.

Operational Activities

Our operational activities constitute the building and management of our renewable energy assets ‘on the ground’. We predominantly outsource the construction of new assets to contractor(s) experienced in these areas. Once our assets are in service, we predominantly outsource the operation and maintenance work. Our asset management services, which include providing support and resources to the relevant project companies to enable effective supervision and monitoring of the assets and oversight of contractors, and to provide certain corporate, legal and other back-office services are partially outsourced.  All outsourced construction, operation and maintenance and asset management activities are managed through contracts with the various third parties in commercially agreed forms and are generally on a medium or long term basis.

3. Slavery and trafficking policies

Operating to high ethical standards is central to our organisation. Both our General Code of Conduct and our Anti-bribery and Corruption Policy make clear that good corporate governance and the professional ethics of our employees are the pillars upon which Cubico’s activity is based.

We have welcomed the increased focus brought to bear by the United Kingdom’s Modern Slavery Act 2015 and the Legal and Compliance team have responsibility for implementing and reviewing controls to address the risks of modern slavery occurring in our operations and supply chains.

Building on the work we did during 2017 to update policies and make more explicit reference in them to modern slavery, we now have a single Cubico Procurement & Business Partner Vetting Policy to which our employees can turn for guidance.  This has  increased the clarity of our approach in assessing whether suppliers, joint venture partners, sellers, developers, acquisition targets and other stakeholders with whom we engage (together referred to as “Third Parties”) maintain appropriate standards with respect to the prevention of modern slavery in their own operations and supply chains.

We continue to commission KYC Reports at certain key points in our relationships with Third Parties that are categorised as medium or high risk.  These reports incorporate an assessment of the risks of modern slavery. During the course of 2019 no KYC Reports were generated which raised specific concerns with respect to modern slavery.

During 2017 we introduced a Supplier Code of Conduct which sets out the standards we expect from all those who work for and with us with respect to combating modern slavery, anti-bribery and corruption and health and safety standards. We continue to place a contractual obligation on all medium and high risk Third Parties to adhere to our Supplier Code of Conduct and periodically send our Supplier Code of Conduct to certain Third Parties and ask them to reconfirm that they will comply with the terms thereof.

4. Risk assessment

Corporate Activities

We have assessed that, given our internal operating standards, the risk of modern slavery occurring in our corporate activities is relatively low.  However, we remain vigilant to the risks particularly with respect to the limited low skilled outsourced labour that we engage at our offices (e.g. cleaning services).  The Global Health and Safety Manager has visited our new office based in Colombia, and did not identify any areas of specific concern.

Operational Activities

We have also assessed the risks of modern slavery occurring in our operational activities and identified key areas of focus to be:

  • Our high-risk jurisdictions: Cubico has a global footprint and operates in a number of jurisdictions. Some of those jurisdiction pose a higher risk than others and are monitored more closely as a result.
  • The high levels of outsourcing of operational activities (as described above): Whilst Cubico predominantly contracts with large, well established suppliers we acknowledge that even they do not always have their own directly employed local work forces in the remote locations of some of our projects.
  • The nature of the work undertaken, including:
  • construction of assets and the infrastructure that supports them;
  • outsourcing of operation and management activities associated with finished assets; and
  • outsourcing of low skilled maintenance work at assets, particularly in higher risk jurisdictions.

Slavery and trafficking risks are already taken into account in the assessments made when Cubico is deciding whether to acquire or develop assets in a new country.  The Legal and Compliance team have a central role in advising the organisation on those risks.

Legal Risk and Compliance Health Check – Anti-bribery & Corruption and Modern Slavery

  • During 2018 we carried out an assessment of our risks with respect to (i) bribery and corruption and (ii) modern slavery in conjunction with 22 internal stakeholders across our operations in Mexico, Brazil, Italy and Spain.  As a result of that review we: created the single, unified Cubico Procurement & Business Partner Vetting Policy referenced above; and
  • As we reported previously, we have been following through with our assessment of high and medium risk suppliers based on questionnaires issued to them and an assessment of their responses.

Assessment of the responses to questionnaires received to date have not highlighted the need for further action to be taken or investigations made.

5. Due diligence and actions to address risks

Our procurement practices and controls (which include insisting on a contractual right to audit a supplier where appropriate) have mitigated the risks of modern slavery in our organisation and supply chains.  However, the increased focus that we have placed on modern slavery (as described above), particularly with respect to our procurement practices, further enhances our risk management.

At the start of 2018 we appointed a Global Health and Safety Manager who regularly undertakes site visits. He has undergone modern slavery training and assesses our risks in this area when on site which enhances our risk management practices and controls.  During 2019, the Global Health and Safety Manager conducted site visits at the following locations: Brazil, USA, Italy, UK, Portugal, Colombia, Mexico, Spain, Greece and Uruguay.  Our Global Health and Safety Manager ensured that he visited our recently acquired operations in Colombia before the end of 2019.

The Executive Committee, including the CEO, CFO, General Counsel, Head of Asset Management, Head of Americas and Head of EMEA, have all received training on modern slavery. As part of their role they do a number of on-site safety walks every year which include an assessment of compliance and modern slavery risks.

During 2019 the Executive Committee and the  Global Health and Safety Manager did not identify any areas of specific concern which required further action or investigation with respect to modern slavery.

6. Our proposals for 2020 and beyond

We are committed to combating the risks of modern slavery occurring within our organisation and supply chains.  Cubico’s Internal Auditor and Procurement Manager alongside the Legal and Compliance team,  have specific remit to further address the risks and will lead initiatives to:

  • continue our work in assessing our high and medium risk Third Parties and to develop our risk analysis and selection of suppliers including by reviewing, refreshing and as appropriate reissuing our slavery and trafficking questionnaire;
  • via site visits conducted by our Global Health and Safety Manager, continue to carry out due diligence and audits on suppliers and our own assets.;
  • continue to enforce the requirements of the Supplier Code of Conduct;
  • continue to liaise directly with our Global Health and Safety Manager on issues/risks he identifies and make recommendations to Cubico’s Legal and Compliance team;
  • refresh our assessment of our suppliers and identify any Third Parties who we deem high risk;
  • embed our current and new employees’ understanding of modern slavery risks so that they remain vigilant and follow the controls that we have in place to reduce these risks.

Modern slavery will continue to be a standing agenda point in respect of all quarterly risk management meetings which are attended by all heads of country.

 7. Training

As noted in our 2016 statement we acknowledge that our employees are our ‘eyes and ears’ when it comes to vigilance on the risks of modern slavery.  In 2018 we invested in an e-learning modern slavery module which was rolled out to approximately 50 employees in our procurement, operations, asset management, health and safety and legal functions and to our Country Leads.   In 2020 we will reissue this training to relevant employees to ensure modern slavery risks remain at the forefront of their minds.

This statement is made by Cubico Sustainable Investments Limited and the board of directors of the company have approved it and will update it annually.

 

Modern Slavery Statement Financial Year 2018

STATEMENT UNDER S.54 OF THE MODERN SLAVERY ACT 2015

1. Introduction

This is a statement made by Cubico in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 January 2018 to 31 December 2018.

2. Background

Cubico is one of the world’s leaders in providing renewable energy, the fastest-growth energy source, across the Americas and Europe. Our portfolio includes onshore wind, solar photovoltaic and solar thermal assets.

We are fully committed to playing a significant role in the transition towards a clean energy world optimizing the use of natural resources while respecting the environment and the social development of the communities in which we are present.

Our organisation is split broadly between corporate activities and operational activities.

Corporate Activities

Our corporate activities are performed at the following offices: London (where we are headquartered), Uxbridge (UK), Madrid (Spain), Milan (Italy), Lyon (France), Sydney (Australia), Mexico City (Mexico), Stamford (USA), São Paulo (Brazil). Although not operational in the financial year in question, we do now also have offices in Uruguay and Colombia. Employees in these offices undertake skilled activities including project origination and execution and corporate services (finance, tax, legal, HR). We also have an office in Fortaleza (Brazil) where both corporate activities (providing legal, technical and finance/accounting support to the Brazilian projects) and operational activities (providing day-to-day operational support to the Brazilian projects) are undertaken.

Our corporate activities have only an occasional dependence on temporary workers and contractors and the nature of that work is mainly of a professional service nature.

Operational Activities

Our operational activities constitute the building and management of our renewable energy assets ‘on the ground’. We predominantly outsource the construction of new assets to contractor(s) experienced in these areas. Once our assets are in service, we predominantly outsource the operation and maintenance work. Our asset management services, which include providing support and resources to the relevant project companies to enable effective supervision and monitoring of the assets and oversight of contractors, and to provide certain corporate, legal and other back-office services are partially outsourced. All outsourced construction, operation and maintenance and asset management activities are managed through contracts with the various third parties in commercially agreed forms and are generally on a medium or long term basis.

3. Slavery and trafficking policies

Operating to high ethical standards is central to our organisation. Both our General Code of Conduct and our Anti-bribery and Corruption Policy make clear that good corporate governance and the professional ethics of our employees are the pillars upon which Cubico’s activity is based.

We welcome the increased focus brought to bear by the United Kingdom’s Modern Slavery Act 2015 and the Legal and Compliance team have responsibility for implementing and reviewing controls to address the risks of modern slavery occurring in our operations and supply chains.

Building on the work we did during 2017 to update policies and make more explicit reference in them to modern slavery, during 2018 we identified that we could:

  • increase the clarity of our approach to the need to assess whether suppliers, joint venture partners, sellers, developers, acquisition targets and other stakeholders with whom we engage (together referred to as “Third Parties”) maintain appropriate standards with respect to the prevention of modern slavery in their own operations and supply chains; and
  • make the tools available to employees to address those risks more readily and easily accessible;

by combining our separate Procurement Policy and KYC Business Partnering Vetting Guidelines into one unified policy. We now have a single Cubico Procurement & Business Partner Vetting Policy to which our employees can turn for guidance.

We continue to commission KYC Reports at certain key points in our relationships with Third Parties that are categorised as medium or high risk. These reports incorporate an assessment of the risks of modern slavery. During the course of 2018 no KYC Reports were generated which raised specific concerns with respect to modern slavery.

During 2017 we introduced a Supplier Code of Conduct which sets out the standards we expect from all those who work for and with us with respect to combating modern slavery, anti-bribery and corruption and health and safety standards. We continue to place a contractual obligation on all medium and high risk Third Parties to adhere to our Supplier Code of Conduct.

4. Risk assessment

Corporate Activities

We have assessed that, given our internal operating standards, the risk of modern slavery occurring in our corporate activities is relatively low. However, we remain vigilant to the risks particularly with respect to the limited low skilled outsourced labour that we engage at our offices (e.g. cleaning services).

Operational Activities

We have also assessed the risks of modern slavery occurring in our operational activities and identified key areas of focus to be:

  • Our high-risk jurisdictions: Cubico has a global footprint and operates in a number of jurisdictions. Some of those jurisdiction pose a higher risk than others and are monitored more closely as a result.
  • The high levels of outsourcing of operational activities (as described above): Whilst Cubico predominantly contracts with large, well established suppliers we acknowledge that even they do not always have their own directly employed local work forces in the remote locations of some of our projects.
  • The nature of the work undertaken, including:
    • construction of assets and the infrastructure that supports them;
    • outsourcing of operation and management activities associated with finished assets; and
    • outsourcing of low skilled maintenance work at assets, particularly in higher risk jurisdictions.

Slavery and trafficking risks are already taken into account in the assessments made when Cubico is deciding whether to acquire or develop assets in a new country. The Legal and Compliance team have a central role in advising the organisation on those risks.

Legal Risk and Compliance Health Check – Anti-bribery & Corruption and Modern Slavery

  • During 2018 we carried out an assessment of our risks with respect to (i) bribery and corruption and (ii) modern slavery in conjunction with 22 internal stakeholders across our operations in Mexico, Brazil, Italy and Spain. As a result of that review we: created the single, unified Cubico Procurement & Business Partner Vetting Policy referenced above; and
  • began a process of issuing questionnaires to our high and medium risk suppliers in these jurisdictions.

Assessment of the responses to questionnaires received to date have not highlighted the need for further action to be taken or investigations made. However, during 2019 we will continue to follow up with suppliers who have yet to respond and will continue to risk assess the information received and any ongoing failure to respond.

5. Due diligence and actions to address risks

Our procurement practices and controls (which include insisting on a contractual right to audit a supplier where appropriate) have mitigated the risks of modern slavery in our organisation and supply chains. However, the increased focus that we have placed on modern slavery (as described above), particularly with respect to our procurement practices, further enhances our risk management.

At the start of 2018 we appointed a Global Health and Safety Manager who regularly undertakes site visits. He has undergone modern slavery training and assesses our risks in this area when on site which enhances our risk management practices and controls. During 2018 he did not identify any areas of specific concern which required further action or investigation with respect to modern slavery. However, he did find that a supplier in Mexico was engaging in poor work practices (relating to 12 hour shifts) with respect to a small number of security guards. We worked with that supplier to ensure that those working conditions were improved.

6. Our proposals for 2019 and beyond

We are committed to combating the risks of modern slavery occurring within our organisation and supply chains. Cubico’s Internal Auditor and Procurement Manager alongside the Legal and Compliance team, have specific remit to further address the risks and will lead initiatives to:

  • follow up with Third Parties that have not returned slavery and trafficking questionnaires and assess the responses to develop our risk analysis and selection of suppliers;
  • via site visits conducted by our Global Health and Safety Manager, continue to carry out due diligence and audits on suppliers and our own assets. Our Global Health and Safety Manager will be visiting our recently acquired operations in Colombia before the end of 2019 and we will consider issuing modern slavery questionnaires and carrying our further due diligence on the operations there;
  • enforce the requirements of the Supplier Code of Conduct which we introduced during the course of 2017;
  • liaise directly with our Global Health and Safety Manager on issues/risks he identifies and make recommendations to Cubico’s Legal and Compliance team.

Modern slavery will continue to be a standing agenda point in respect of all quarterly risk management meetings which are attended by all heads of country.

7. Training

As noted in our 2016 statement we acknowledge that our employees are our ‘eyes and ears’ when it comes to vigilance on the risks of modern slavery. In 2018 we invested in an e-learning modern slavery module which was rolled out to approximately 50 employees in our procurement, operations, asset management, health and safety and legal functions and to our Country Leads. Where appropriate new staff will also be required to undertake this training.

This statement is made by Cubico Sustainable Investments Limited and the board of directors of the company have approved it and will update it annually.

 

Modern Slavery Statement 2017

STATEMENT UNDER S.54 OF THE MODERN SLAVERY ACT 2015

1. Introduction

Cubico Sustainable Investments Holdings Limited (“CSIHL”) wholly owns Cubico Sustainable Investments Limited (“CSIL”) and they are referred to collectively hereafter as “Cubico”. This is a statement made by Cubico in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 January 2017 to 31 December 2017.

2. Background

Cubico is one of the world’s leaders in providing renewable energy, the fastest-growth energy source, across the Americas and Europe. Our portfolio includes onshore wind, solar photovoltaic and solar thermal assets.

We are fully committed to playing a significant role in the transition towards a clean energy world optimizing the use of natural resources while respecting the environment and the social development of the communities in which we are present.

Our organisation is split broadly between corporate activities and operational activities.

Corporate Activities

Our corporate activities are performed at the following offices: London (where we are headquartered), Stamford (USA), Madrid (Spain), Milan (Italy), Lyon (France), Melbourne (Australia), Mexico City (Mexico) and São Paulo (Brazil). Employees in these offices undertake skilled activities including project origination and execution and corporate services (finance, tax, legal, HR). We also have an office in Fortaleza (Brazil) where both corporate activities (providing legal, technical and finance/accounting support to the Brazilian projects) and operational activities (providing day-to-day operational support to the Brazilian projects) are undertaken.

Our corporate activities have only an occasional dependence on temporary workers and contractors and the nature of that work is mainly of a professional service nature.

Operational Activities

Our operational activities constitute the building and management of our renewable energy assets ‘on the ground’. We predominantly outsource the construction of new assets to contractor(s) experienced in these areas. Once our assets are in service, we predominantly outsource the operation and maintenance work. Our asset management services, which include providing support and resources to the relevant project companies to enable effective supervision and monitoring of the assets and oversight of contractors, and to provide certain corporate, legal and other back-office services are partially outsourced.

All outsourced construction, operation and maintenance and asset management activities are managed through contracts with the various third parties in commercially agreed forms and are generally on a medium or long term basis.

3. Slavery and trafficking policies

Operating to high ethical standards is central to our organisation. Both our General Code of Conduct and our Anti-bribery and Corruption Policy make clear that good corporate governance and the professional ethics of our employees are the pillars upon which Cubico’s activity is based.

We welcome the increased focus brought to bear by the United Kingdom’s Modern Slavery Act 2015 and have tasked the Legal and Compliance team with implementing controls to address the risks of modern slavery occurring in our operations and supply chains.

During 2017 our organisation furthered its commitment to combating slavery and trafficking, updating policies to make them more explicit about modern slavery as follows:

  • we added specific reference in our General Code of Conduct requiring our employees to ensure that neither Cubico, nor the third parties it engages, are complicit or involved (directly or indirectly) in any practice which amounts to modern slavery;
  • we revised our Business Partner Vetting Guidelines to place increased focus on the need to assess whether suppliers, joint venture partners, sellers, developers, acquisition targets and other stakeholders with whom we engage (together referred to as “Third Parties”) maintain appropriate standards with respect to the prevention of modern slavery in their own operations and supply chains; and
  • we increased the focus in our Procurement Policy on the importance of ensuring that our business is truly sustainable and does not engage in or benefit from (directly or indirectly through our supply chain) modern slavery and the need for those engaged in procurement to be vigilant to the risks. We also provided those engaged in procurement with provisions to be included in contracts with Third Parties which give contractual force to our zero tolerance of modern slavery.

At certain key points in our relationships with Third Parties that are categorised as medium or high risk, we commission KYC Reports which incorporate an assessment of the risks of modern slavery.

During 2017 we have also introduced a Supplier Code of Conduct which sets out the standards we expect from all those who work for and with us with respect to combating modern slavery, anti-bribery and corruption and health and safety standards. All medium and high risk Third Parties are now contractually required to adhere to this policy.

4. Risk assessment

Corporate Activities

We have assessed that, given our internal operating standards, the risk of modern slavery occurring in our corporate activities is relatively low. However, we remain vigilant to the risks particularly with respect to the limited low skilled outsourced labour that we engage at our offices (e.g. cleaning services).

Operational Activities

We have also assessed the risks of modern slavery occurring in our operational activities and identified key areas of focus to be:

  • Our high risk jurisdictions: Cubico has a global footprint and operates in a number of jurisdictions. Some of those jurisdiction pose a higher risk than others and are monitored more closely as a result.
  • The high levels of outsourcing of operational activities (as described above): Whilst Cubico predominantly contracts with large, well established suppliers we acknowledge that even they do not always have their own directly employed local work forces in the remote locations of some of our projects.
  • The nature of the work undertaken, including:
    • construction of assets and the infrastructure that supports them;
    • outsourcing of operation and management activities associated with finished assets; and
    • outsourcing of low skilled maintenance work at assets, particularly in higher risk jurisdictions.

Slavery and trafficking risks are already taken into account in the assessments made when Cubico is deciding whether to acquire or develop assets in a new country. The Legal and Compliance team have a central role in advising the organisation on those risks.

5. Due diligence and actions to address risks

Our procurement practices and controls (which include insisting on a contractual right to audit a supplier where appropriate) have mitigated the risks of modern slavery in our organisation and supply chains. However, the increased focus that we have placed on modern slavery (as described above), particularly with respect to our procurement practices, will further enhance our risk management.

At the start of 2018 we appointed a Global Health and Safety Manager who regularly undertakes site visits. Modern slavery falls within his remit and his ability to assess our risks in this area on site therefore enhances our risk management practices and controls.

6. Our proposals for 2018 and beyond

We are committed to combating the risks of modern slavery occurring within our organisation and supply chains. Cubico’s Internal Auditor and Procurement Manager alongside the Legal and Compliance team, have specific remit to further address the risks and will lead initiatives to:

  • continue mapping of our supply chain so that additional initiatives can be developed in the areas of highest risk;
  • finalise and put into practice our slavery and trafficking questionnaires to develop our risk analysis and selection of suppliers;
  • continue to carry out due diligence and audits on suppliers and our own assets which will continue to have an increased focus on modern slavery risks;
  • enforce the requirements of the Supplier Code of Conduct which we introduced during the course of 2017
  • liaise directly with our Global Health and Safety Manager on issues/risks he identifies and make recommendations to Cubico’s Legal and Compliance team; and

Modern slavery will continue to be a standing agenda point in respect of all quarterly risk management meetings which are attended by all heads of country.

As part of our ongoing commitment to monitoring the risk of modern slavery in our organisation and supply chain, during 2018 we have undertaken a risk assessment through which we have gathered feedback from 22 stakeholders in Brazil, Italy, Mexico, Spain and Italy in the following areas of the business:

  • origination and execution;
  • construction and operations;
  • legal;
  • finance; and
  • the country office.

The results of this assessment will be key to shaping our proposals for 2018 and beyond.

7. Training

As noted in our 2016 statement we acknowledge that our employees are our ‘eyes and ears’ when it comes to vigilance on the risks of modern slavery. We have therefore invested in an e-learning modern slavery module which is being rolled out in 2018.

This statement is made by Cubico Sustainable Investments Holdings Limited for itself and on behalf of Cubico Sustainable Investments Limited and the board of directors of both companies have approved it and will update it annually.

 

Modern Slavery Statement 2016 

STATEMENT UNDER S.54 OF THE MODERN SLAVERY ACT 2015

1. Introduction

Cubico Sustainable Investments Holdings Limited (“CSIHL”) wholly owns Cubico Sustainable Investments Limited (“CSIL”) and they are referred to collectively hereafter as “Cubico”. This is a statement made by Cubico in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 January 2016 to 31 December 2016.

2. Background

Cubico is one of the world’s leaders in providing renewable energy, the fastest-growth energy source, across the Americas and Europe. Our portfolio includes onshore wind, solar photovoltaic and solar thermal assets.

We are fully committed to playing a significant role in the transition towards a clean energy world optimizing the use of natural resources while respecting the environment and the social development of the communities in which we are present.

Our organisation is split broadly between corporate activities and operational activities.

Corporate Activities

Our corporate activities are performed at the following offices: London (where we are headquartered), Stamford (USA), Milan (Italy), Mexico City (Mexico) and São Paulo (Brazil). Employees in these offices undertake skilled activities including project origination and execution and corporate services (finance, tax, legal, HR). We also have an office in Fortaleza (Brazil) where both corporate activities (providing legal, technical and finance/accounting support to the Brazilian projects) and operational activities (providing day-to-day operational support to the Brazilian projects) are undertaken.

Our corporate activities have only an occasional dependence on temporary workers and contractors and the nature of that work is mainly of a professional service nature.

Operational Activities

Our operational activities constitute the building and management of our renewable energy assets ‘on the ground’. We predominantly outsource the construction of new assets to contractor(s) experienced in these areas. Once our assets are in service, we predominantly outsource the operation and maintenance work. Our asset management services, which include providing support and resources to the relevant project companies to enable effective supervision and monitoring of the assets and oversight of contractors, and to provide certain corporate, legal and other back-office services are partially outsourced.

All outsourced construction, operation and maintenance and asset management activities are managed through contracts with the various third parties in commercially agreed forms and are generally on a medium or long term basis.

3. Slavery and trafficking policies

Operating to high ethical standards is central to our organisation. Both our General Code of Conduct and our Anti-bribery and Corruption Policy make clear that good corporate governance and the professional ethics of our employees are the pillars upon which Cubico’s activity is based.

We welcome the increased focus brought to bear by the United Kingdom’s Modern Slavery Act 2015 and have tasked the Legal and Compliance team with implementing controls to address the risks of modern slavery occurring in our operations and supply chains.

To further our organisation’s commitment to combating slavery and trafficking, we have updated certain policies to be more explicit about modern slavery as follows:

  • we have added specific reference in our General Code of Conduct requiring our employees to ensure that neither Cubico, nor the third parties it engages, are complicit or involved (directly or indirectly) in any practice which amounts to modern slavery;
  • we have revised our Business Partner Vetting Guidelines to place increased focus on the need to assess whether suppliers, joint venture partners, sellers, developers, acquisition targets and other stakeholders with whom we engage (together referred to as “Third Parties”) maintain appropriate standards with respect to the prevention of modern slavery in their own operations and supply chains; and
  • we have increased the focus in our Procurement Policy on the importance of ensuring that our business is truly sustainable and does not engage in or benefit from (directly or indirectly through our supply chain) modern slavery and the need for those engaged in procurement to be vigilant to the risks. We have also provided those engaged in procurement with provisions to be included in contracts with Third Parties which give contractual force to our zero tolerance of modern slavery.

At certain key points in its relationships with Third Parties that are categorised as medium or high risk, Cubico commissions KYC Reports which incorporate an assessment of the risks of modern slavery.

4. Risk assessment

Corporate Activities

We have assessed that, given our internal operating standards, the risk of modern slavery occurring in our corporate activities is relatively low. However, we remain vigilant to the risks particularly with respect to the limited low skilled outsourced labour that we engage at our offices (e.g. cleaning services).

Operational Activities

We have also assessed the risks of modern slavery occurring in our operational activities and identified key areas of focus to be:

  • Our high risk jurisdictions: Cubico has a global footprint and operates in a number of jurisdictions. Some of those jurisdiction pose a higher risk than others and are monitored more closely as a result.
  • The high levels of outsourcing of operational activities (as described above): Whilst Cubico predominantly contracts with large, well established suppliers we acknowledge that even they do not always have their own directly employed local work forces in the remote locations of some of our projects.
  • The nature of the work undertaken, including:
    • construction of assets and the infrastructure that supports them;
    • outsourcing of operation and management activities associated with finished assets; and
    • outsourcing of low skilled maintenance work at assets, particularly in higher risk jurisdictions.

Slavery and trafficking risks are already taken into account in the assessments made when Cubico is deciding whether to acquire or develop assets in a new country. The Legal and Compliance team have a central role in advising the organisation on those risks.

5. Due diligence and actions to address risks

Our procurement practices and controls (which include insisting on a contractual right to audit a supplier where appropriate) have mitigated the risks of modern slavery in our organisation and supply chains. However, the increased focus that we have placed on modern slavery (as described above), particularly with respect to our procurement practices, will further enhance our risk management.

6. Our proposals for 2017 and beyond

We are committed to combating the risks of modern slavery occurring within our organisation and supply chains. Cubico’s Internal Auditor and Procurement Manager has specific remit to further address the risks and will lead initiatives to:

  • better map our supply chain so that additional initiatives can be developed in the areas of highest risk;
  • use slavery and trafficking questionnaires to develop our risk analysis and selection of suppliers;
  • carry out due diligence and audits on suppliers and our own assets which include an increased focus on modern slavery risks;
  • enforce the requirements of the Supplier Code of Conduct which we are proposing to introduce during the course of 2017;
  • make recommendations to Cubico’s Legal and Compliance team which can then be assessed at risk management meetings.

7. Training

We acknowledge that our employees are our ‘eyes and ears’ when it comes to vigilance on the risks of modern slavery. We are therefore planning a programme of training focused on modern slavery which is appropriate to the tasks that our employees undertake for us.

This statement is made by Cubico Sustainable Investments Holdings Limited for itself and on behalf of Cubico Sustainable Investments Limited and the board of directors of both companies have approved it and will update it annually.