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Hygen Energy Limited

Modern Slavery Statement

This statement is published in accordance with Section 54 of the Modern Slavery Act 2015. It
sets out the steps taken by Hygen Energy Limited (Hygen) and other relevant group companies
to prevent modern slavery and human trafficking in the year ended 31 December 2022.

It continues to be a priority for Hygen to ensure that we trade ethically, source responsibly and
work to prevent modern slavery and human trafficking throughout our organisation and in our
supply chain. This statement highlights the key activities we have undertaken during this
financial year to combat modern slavery in our organisation and supply chain, including

Business structure

We provide global Hydrogen Gas and clean energy production. Providing production ready and
wholesale distribution sites. The Group operates in the United Kingdom and provides
distribution in the United Kingdom and Europe.

Our business

Our business is organised into a Sales Office based in Oxford and transportation, distribution
and infrastructure business hubs throughout the United Kingdom and Europe.

Our supply chains

Our supply chains are predominately within the United Kingdom and Europe. Distribution is
handled through our own wholly owned network of companies.

We have appropriate policies in place that underpin our commitment to ensure that there is no
modern slavery or human trafficking in our supply chains or in any part of our business. We
continuously review and update all our policies. Our supplier code of conduct specifically refers
to adherence to Modern Slavery policies.

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our
business relationships and to implementing and enforcing effective systems and controls to
ensure slavery and human trafficking is not taking place anywhere in our supply chains. We also
have the following policies in place relevant to modern slavery, which we continuously review
and update:

  • Code of ethics and behaviours.
  • Responsible sourcing / procurement policy.
  • Supplier Code of Conduct
  • Anti-Bribery and Corruption Policy


Due diligence processes for slavery and human trafficking

We understand that the following areas give rise to the highest modern slavery risks:

-Supply chains and

As part of our initiative to identify and mitigate risk we conduct selective due diligence checks
within supply chains and visits to production locations. We also carry risk assessments and due
diligence checks prior to engaging with new suppliers.

We also have in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistleblowers.


Supplier adherence to our values and ethics.

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply
chain and contractors comply with our ethics we have in place a rigorous supply chain
compliance programme. This consists of: Supplier Code of Conduct Policy.

We have a dedicated compliance team, which consists of involvement from the following

  • Legal.
  • Audit and compliance.
  • Human resources.
  • Procurement.
  • Sales.



To ensure a high level of understanding of the risks of modern slavery and human trafficking in
our supply chains and our business, we provide regular training to our staff. We also require our
business partners to provide training to their staff and suppliers and providers. Hygen also carry
out employment checks to ensure that employees have the necessary documentation to work in
the UK (or the country they are employed) and no-one under the legal minimum age of
admission to work is ever employed by Hygen.

Our Commitment

Hygen does not support or deal with any business knowingly involved in slavery or human
trafficking. We understand that Modern Slavery is not static, we actively monitor our supply
chains and undertake selective due diligence, we will immediately implement risk mitigation and
remedial measures should the situation change.

This statement was approved by the board of Hygen Energy Limited.

Jamie Burns
December 2022