Modern Slavery and Human Trafficking Statement 2026

1. Introduction and commitment 

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This statement is made by Smarta Energy Limited pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken, and the approach adopted, to seek to prevent modern slavery and human trafficking in its business and supply chains during the relevant financial year.

Smarta Energy is committed to conducting its business with integrity and to acting in a manner consistent with respect for human rights, lawful working practices and ethical supply-chain management. It recognises that modern slavery may take many forms, including slavery, servitude, forced or compulsory labour, human trafficking and related exploitation, and that such risks may arise directly or indirectly in a wide range of sectors and supply arrangements.

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2. Organisation, business and supply chain 

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Smarta Energy Limited is a company registered in England and Wales under company number 12403001. It operates from its registered office at Building 3, Workwell Office, Selby Road, Leeds, West Yorkshire, England, LS15 4LG. The company’s website is at www.smartaenergy.com.

Smarta Energy operates in the energy-related business services sector and engages with suppliers, contractors, consultants and other third parties as part of its operations. Its supply chains may include professional services, technology and software services, business support services, recruitment and labour supply, facilities and office support, marketing and communications, and other operational procurement categories.

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3. Policies and governance

Smarta Energy expects lawful, ethical and responsible conduct throughout its operations and supply relationships. Its approach to modern slavery forms part of its wider governance framework, including supplier management, ethical procurement, compliance, risk management and escalation procedures.

In support of this commitment, Smarta Energy seeks to maintain and apply policies, procedures and controls addressing matters such as:

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(a) ethical business conduct and zero tolerance of unlawful exploitation; 
(b) supplier onboarding, due diligence and contractual standards; 
(c) anti-bribery and corruption controls consistent with the Bribery Act 2010 and adequate-procedures principles; 
(d) whistleblowing and concern-reporting channels; 
(e) employment and recruitment practices intended to support lawful and fair treatment of workers; and 
(f) review of modern slavery risks in the context of procurement and supplier oversight. 

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4. Due diligence and supplier expectations

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Smarta Energy expects suppliers and other relevant business partners to operate in compliance with applicable laws and to maintain standards designed to prevent modern slavery and labour exploitation. Depending on the nature of the relationship, the sector, location, value and risk profile involved, the company may apply proportionate due diligence measures, which may include:

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(a) obtaining information about the supplier’s business, ownership, services and relevant policies; 
(b) considering supply-chain, sectoral, labour-model or geographic risk indicators 
(c) requesting confirmation of compliance with modern slavery, labour, health and safety and anti-bribery requirements; 
(d) including contractual obligations requiring lawful labour practices, cooperation and notification of concerns; and 
(e) taking additional steps where elevated risks are identified.

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Suppliers are expected, as appropriate to their business, to avoid forced or compulsory labour, respect lawful wages and working conditions, verify the status and rights of workers, avoid charging prohibited recruitment fees, and maintain their own reporting and escalation arrangements.

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5. Risk Assessment and management 

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Smarta Energy recognises that modern slavery risk is not uniform and may vary according to supplier category, labour intensity, sub-contracting models, use of temporary or migrant labour, overseas operations, and the maturity of supplier controls. It therefore seeks to adopt a risk-based and proportionate approach.

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Risk assessment may include consideration of: 

• the nature of goods or services procured; 

• the extent to which labour is outsourced or sub-contracted; 

• the countries or sectors involved; 

• the supplier’s governance and policy framework; 

• payment practices and commercial behaviours that may increase vulnerability in the supply chain; and 

• any allegations, red flags or adverse information identified during onboarding or contract performance. 

Where concerns arise, Smarta Energy may escalate the matter internally, request further information, require remediation, review contractual protections, suspend onboarding or continuation, or consider termination and referral where appropriate

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6. Effectiveness and monitoring 

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Smarta Energy seeks to monitor the effectiveness of its approach through proportionate governance and management measures. Depending on scale and operational need, indicators may include:

(a) completion of supplier due-diligence checks for relevant categories;

(b) use of contractual clauses addressing modern slavery and labour standards;

(c) numbers and nature of concerns raised and investigated

(d) completion of relevant staff awareness or training activity; and

e) periodic review of procurement and supply-chain risk areas

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Smarta Energy does not represent that every part of its supply chain is free from risk. Rather, it seeks to identify, assess and respond to risk in a structured and improving manner.

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7. Training and Awareness 

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Smarta Energy expects relevant personnel to remain alert to indicators of modern slavery and human trafficking. It may provide, or require, proportionate awareness measures for those involved in procurement, supplier management, recruitment or compliance. Training or awareness activity may cover the nature of modern slavery risks, common warning signs, reporting routes, escalation requirements and the importance of ethical procurement and payment practices.

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8. Reporting concerns and remediation 

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Smarta Energy encourages employees, workers, suppliers and other stakeholders to report concerns or suspicions relating to modern slavery, forced labour or exploitation. Concerns should be raised promptly through management channels, compliance or whistleblowing arrangements, or other designated reporting routes.

Reports will be treated seriously and, so far as reasonably possible, investigated appropriately. Where an issue is identified, Smarta Energy will consider suitable remedial action, which may include supplier engagement, corrective action requirements, contractual enforcement, safeguarding steps, referral to relevant authorities or withdrawal from a business relationship where necessary.

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9. Publication and review 

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This statement is intended to be approved by the board of directors (or equivalent management body), signed by an authorised director (or equivalent), and published prominently on the organisation’s UK website. Organisations are also encouraged to submit their statements to the Government’s modern slavery statement registry. Smarta Energy intends this statement to be reviewed annually and updated to reflect the relevant financial year and any material changes in business operations, risk profile or legal requirements. ​

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Approval and sign-off

Approved by the Board of Directors on: 30th June 2026

Name: Kieran Dixon

Title: Director

Date: 30th June 2026

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