Slavery and Human Trafficking Statement Organisation

This statement applies to Electra Commercial Vehicles (referred to in this statement as ‘the Organisation’).

Commitment

The organisation is committed to and acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking

Our Business

We are the manufacturer of 100% electric commercial and municipal vehicles. The Company has its head office in the UK.

Definitions

The Organisation considers that modern slavery encompasses:
• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse • being dehumanised, treated as a commodity or being bought or sold as property

• being physically constrained or to have restriction placed on freedom of movement.

Our Supply Chains

Our supply chains include sourcing of vehicles and parts principally related to the provision of vehicle manufacturing, supply and maintenance. The products the business sells are sourced from a broad range of national and international suppliers. Many of those international supplier relationships are sourced and managed by our Procurement Department.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• Identify and assess potential risk areas in our supply chains, by requiring new suppliers to certify that they do not engage in slavery or human trafficking, or any activity associated with these offences;

• Mitigate the risk of slavery and human trafficking occurring in our supply chains, by including provisions in our template contract documentation requiring our suppliers to take appropriate steps to ensure that there is no slavery or human trafficking in their supply chains;

• We continue to review our procurement policies regarding tenders and contracts to ensure they reflect best practice and to mitigate against the risk of modern slavery;

Due Diligence Procedures

As part of the Company’s due diligence processes into slavery and human trafficking, the supplier approval process will incorporate a review of the controls undertaken by the supplier. Imported goods from sources from outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored.

We expect our suppliers to have an effective system for implementation of their anti – slavery and human trafficking policies and procedures and maintain appropriate documentation and records for monitoring its own suppliers.

Suppliers Adherence To Our Values

The Company will not support or deal with any business knowingly involved in slavery or human trafficking. We have taken the following steps to measure and monitor the efficiency of the policy.

• Completion of internal audits by the Head of EQHS and HR

• The level of communication and transfer of information between the Company and supply chain, measurement of their understanding of the Company’s expectations

This Policy statement takes into account, and supports, the policies, procedures and requirements documented in our Integrated Management System, compliant with the requirements of ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018.

The implementation and operation of this management system underlines our commitment to this policy. Formal procedures concerning slavery and human trafficking have been established and communicated to all levels of the company.

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Signed for and on Behalf of Electra Commercial vehicles Ltd

Benjamin Smith

Managing Director Feb 2023/issue 4

This was last updated on 23/03/2023.