Corporate statements

 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 2024 to 31 December 2024. The statement outlines the steps we have taken during the year to prevent modern slavery from occurring in our business and supply chain.

2. About Cubico

Cubico Sustainable Investments is a global leader in providing renewable energy. We have operations in 9 countries and our diversified portfolio includes solar photovoltaic, onshore wind, concentrated solar power (CSP), battery energy storage systems (BESS), and transmission and distribution networks. We manage the entire project lifecycle from development and construction to operation, delivering clean energy and reducing global dependence on fossil fuels.

We are headquartered in London, UK and have regional offices in Australia, Colombia, Greece, Italy, Mexico, Spain, Uruguay and the USA.

3. Risk Assessment

Our organisation is split between corporate activities and operational activities.

Corporate Activities

Our corporate operations are carried out at our regional offices, where employees engage in skilled work such as project origination and execution, management of development and construction activities, day-to-day asset management, and corporate support functions including finance, tax, legal, and human resources. These activities are professional in nature and rely minimally on temporary workers and contractors.

Given the low level of outsourced staffing, the professional office environment, the highly skilled nature of the work, and our strong internal operating standards, we consider the risk of modern slavery within our corporate operations to be low. Nevertheless, we remain alert to potential risks, particularly in relation to the small number of lower-skilled outsourced roles—such as cleaning and maintenance services—engaged at our offices in higher-risk jurisdictions.

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 commercially agreed contracts on a medium or long term basis and include robust modern slavery undertakings on our counterparties.

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

• Higher-risk jurisdictions: Some of the jurisdictions Cubico operates in pose a higher risk than others due to weaker labour laws, higher levels of corruption and a lack of enforcement for worker protections.
• Raw material sourcing: The procurement of materials used in Cubico’s renewable energy infrastructure, such as solar panels, wind turbines, and batteries, can involve supply chains in regions with higher risks of modern slavery. In particular, the industry risk of forced labour in the supply chain of polysilicon originating from Xinjiang, China.
• Subcontracting in construction: Cubico’s construction projects rely on subcontracted labour, including some low-skilled workers. In certain jurisdictions, these workers are at a higher risk of being subject to modern slavery.
• 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.

4. Our Controls

Our risk management framework includes a number of controls to mitigate the risks of modern slavery throughout our business and supply chain, as follows:

Governance and Policies

Cubico’s Executive Committee sets the tone from the top and promotes a culture of ethical conduct at every level of our organisation, including through regular communications to employees.

Cubico has a dedicated Compliance Officer who is responsible for our Ethical Compliance Programme. The Compliance Officer works closely with other functions, including Procurement, Internal Audit and Legal, and reports periodically to the Audit and Risk Committee.

Cubico’s Ethical Compliance Programme includes a number of Compliance Policies such as the Code of Conduct, ABC Policy, Procurement & KYC Policy and Supplier Code of Conduct. In particular, our Supplier Code of Conduct sets the standards that we expect from our 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 and similar practices, and sets out our zero tolerance approach.

We place a contractual obligation on all medium and high risk Third Parties to adhere to our Supplier Code of Conduct and include forced labour representations and warranties in contracts, giving us a termination right if breached. We also include a contractual right to audit Third Parties where appropriate to ensure they operate in line with our ethical standards.

Speak Up Procedure

Cubico is dedicated to identifying and addressing inappropriate or illegal conduct within our business operations. As part of this commitment, we maintain an independent Speak Up hotline, which is widely promoted both internally and externally. Employees and Third Parties are encouraged to report any concerns related to modern slavery, with assurance that they can do so without fear of retaliation. We display posters promoting our speak up hotline at all our offices, as well as at our project sites. In 2024, no reports regarding modern slavery concerns were received.

Third Party Due Diligence

In order to ensure we only work with those who share our values we perform KYC screening prior to engaging with Third Parties. The screening assesses the legal and compliance risks of our Third Parties, including the risks of modern slavery, and highlights adverse media relating to any previous modern slavery related incidents.  During 2024, no KYC reports were generated which raised specific concerns with respect to modern slavery.

Where we acquire a new business or asset we request the seller and target to complete a Compliance Questionnaire as part of the due diligence process which includes questions relating to modern slavery and the controls they have in place to mitigate risks. Cubico’s Procurement team also requires new suppliers to complete similar Compliance Questionnaires.

Ethical Compliance Training

All Cubico employees undertake annual Ethical Compliance Training, which includes modern slavery training. Furthermore, certain employees periodically complete modern slavery e-learning.

Ethical Compliance Risk Assessments and Audits

A key role of Cubico’s Compliance Officer is to periodically visit the countries we operate in to conduct ethical compliance risk assessments and audits. The scope of these includes a review of modern slavery risks and controls. We also perform high level audits of our key Third Parties, focusing the policies and procedures they have in place to mitigate ethical compliance risks.

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. Cubico’s Executive Committee and Country Heads do a number of on-site safety walks every year which includes an assessment of modern slavery risks. No areas of specific concern were identified in 2024 which required further action or investigation with respect to modern slavery.

Industry Risks relating to Polysilicon

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 took part in a Supply Chain Exposure Risk Assessment of panel manufacturers in Southeast Asia, organized by an independent auditor. We can access the results of the assessments, as required, which enable us to make a more informed decision when selecting panel providers.

Our Compliance Officer, Procurement and Legal teams have also implemented enhanced governance controls, such as including comprehensive forced labour contractual protections in panel supply agreements, which provides an additional safeguard to prevent Cubico from obtaining materials derived using illicit labour practices.

5. Our Commitment

We remain committed to combating the risks of modern slavery and it is an ongoing key priority for Cubico. 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 enforce the requirements of the Supplier Code of Conduct;
• continue to carry out Ethical Compliance Risk Assessment and Audits at our offices to assess the level of modern slavery risks and react accordingly;
• continue to conduct Compliance Audits of key Third Parties to ensure they have appropriate modern slavery controls within their business and 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 at our assets via site visits conducted by our Head of HSE, Executive Committee and Country Heads;
• ensure additional due diligence is undertaken and appropriate controls put in place when entering into panel supply agreements; and
• continue to advertise our speak up hotline both internally and externally to encourage its use.

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.