Modern Slavery Statement

This statement is issued by Esken Limited under the provisions of the Modern Slavery Act 2015 (the Act) and covers the financial year ending 29 February 2020.

This statement has been approved by the Board of Directors and signed by David Shearer, the Chairman of Esken. The information contained in this statement is correct at the date of publishing.

Company Overview

Esken, the aviation and energy infrastructure group, is listed on the London Stock Exchange. As at the end of the financial year to 29 February 2020, Esken had over 1,400 employees operating across five main operating divisions at sites throughout the United Kingdom.

The operating divisions can be summarised as follows:

Stobart Aviation

Aims to deliver a first-class passenger experience through its ownership of London Southend Airport and Carlisle Lake District Airport, along with the provision of ground handling services across other UK airports.

Stobart Energy

Is the number one supplier of biomass in the UK, sourcing, processing and supplying fuel to biomass plants under a mix of short and long-term contracts.

Separately, Esken holds a portfolio of commercial properties and investments in renewable energy plants, as well as an investment of 11.8% in Eddie Stobart Logistics plc.

Further details about our business can be found at https://www.esken.com

Policies

Esken is committed to acting ethically and ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business.

Esken’s internal policies reflect our commitment in all our business relationships to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

All internal policies are reviewed regularly to ensure they are appropriate, well communicated and promote continued compliance with the Act and other applicable legislation.

The following key policies are in place which relate to the controls relevant to the prevention of slavery and human trafficking in our operations:

• Modern Slavery & Human Trafficking Policy. This has been introduced in September 2020 and reaffirms our commitment to tackling modern slavery (MS) and setting out the standards expected of all employees. We also reiterate guidance in relating to reporting concerns to relating to MS via the whistleblowing hotline.
• Whistleblowing Policy. Esken encourage all employees to report any concerns related to the activities of the business, including any worries in relation to modern slavery and human trafficking. Esken’s whistleblowing policy and procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially.

Other relevant Esken policies include:

• Environmental, Social and Governance Policy. We believe that our commitment to the principles of environmental, social and governance (ESG) not only makes good business sense but also complements our Group business strategy and our corporate values. In developing our strategy and setting out our ESG policy, we seek to drive continuous improvement and support our engagement with all stakeholders, internal and external
• Equality & Diversity Policy. Esken is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination, harassment and victimisation on the grounds of race, sex, pregnancy, maternity, martial or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.
• Ethics and Business Integrity Policy. This policy outlines Esken’s requirements for conducting business to the highest ethical standards. Esken demonstrates a clear approach to business integrity and ethics, which underlies Group values.
• Group Recruitment Policy. Esken ensures that the process of recruiting employees is fair, consistent, professional and non-discriminatory to both internal and external candidates.

Our commitment – what we do

Supply chain adherence to the Esken Values and Ethics

Esken considers its supply chain to be at a ‘low risk’ in relation to slavery and human trafficking. Given the nature of the business and how we operate within the sectors within which we work, there is no significant utilisation of overseas or unskilled labour, being key areas identified as posing a higher risk; imports are of a minimal amount, unskilled labour is of a small quantity, and where used, specifically in the construction and waste sectors, we predominantly engage with reputable companies on long terms contracts with regular site visits, and operations of our and our associated companies are UK or EU based meaning suppliers are already under an obligation to comply with UK and EU law on forced labour.

Supplier adherence

Esken demonstrates a zero-tolerance to modern slavery and human trafficking and reserves its rights to terminate any arrangements with any of its suppliers should any modern slavery or human trafficking offence be committed or suspected.

Esken will update its policies and procedures as required to ensure it maintains appropriate safeguards against any mistreatment of persons involved in its supply chain or own business.

Effectiveness in combating modern slavery and human trafficking

Any suspected incidence of slavery or human trafficking within Esken or its supply chain would be immediately reported to the Executive Board in the first instance. It would then be dealt with appropriately, which may include, but is not limited to, terminating commercial relationships, disciplinary action and notifying the relevant authorities.

What we have done in 2019/2020

In 2019/2020, Esken took the following action:

• Delivery of briefing note to all employees identifying the importance of ensuring that modern slavery does not exist in our business and supply chains, providing advise as to how to identify any potential risk areas and ensuring our employees were equipped with the tools to report any such concerns.
• Review current supplier audit processes to assess any modern slavery or human trafficking risks with new suppliers and also to include these reviews as part of continuing assessment and audits of our supplier sites.
• Remaining suppliers within the Energy and Aviation divisions were written to with a briefing identifying our expectations of our suppliers and consequences should any modern slavery or human trafficking offences be committed or suspected.

What we will do in 2020/2021

As part of our on-going commitment to ensuring modern slavery and human trafficking is not present within Esken, we will look to take the following action in 2020/2021:

• Continue to raise awareness amongst employees of modern slavery and human trafficking issues through, e.g. contract provisions and supplier audits.
• Following on from the review of standard supplier Terms and Conditions, continue a further review of our full suite of precedent contracts and terms to ensure all partners, stakeholders and counterparties that we contract with, as applicable, are required to adhere to our relevant policies.
• Finalise and implement an amalgamated single supplier onboarding process to cover all divisions, incorporating modern slavery risk assessment of each supplier.
• As our business continues to grow and we engage with more long term partners, for example, airports, airlines and power plants, work collaboratively to ensure a consistent best practice model is adopted for tackling these issues and ensuring and maintaining compliance.
• Develop an expanded third-party due diligence process to apply to strategic opportunities across Esken to foster a standardised and consistent approach to modern slavery and human trafficking compliance across all acquisitions and investments across the various business units.
• Ensure that Stobart Air, as an associated company, adopts and implements consistent standards to ensure there is no risk of modern slavery within its business and supply chain.

COVID-19

Taking into consideration the nature of Esken’s operations, including within its supply chain, it is not considered that the impact of COVID-19 has created any heightened risk of modern slavery occurring within the business or its supply chain. However, as the wider social and economic impact of this pandemic are known Esken will be monitoring its supply chain more closely in this regard and continues to adopt a zero-tolerance approach to any actual or risk or modern slavery within its supply chain and business.

Measuring our Effectiveness

We recognise that modern slavery and human trafficking is a global and increasing challenge for businesses and we are committed to an ongoing action plan to develop our approach and monitor its effectiveness. To do this we will continue to:

• Review the effectiveness of our Modern Slavery and Trafficking Policy and the Supplier Code of Conduct;
• Ensure all colleagues review our policy annually and confirm they have read and understood it;
• Ensure our supply chain remains under constant review; and
• Continue to monitor any cases reported via our Whistleblowing Policy.

Overall, Esken will continue to focus on understanding further our supply chains, identifying risk areas and increasing awareness amongst employees on the issues of modern slavery and human trafficking and the reporting procedures available to them. We will continue to update policies and procedures as required to ensure appropriate safeguards against any mistreatment of persons are in place.

David Sheerer
Chairman
Esken Limited

September 2020