Modern Slavery Policy

Effective Date: 1st August 2025

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

At ADE, we have a zero-tolerance approach to modern slavery, and we are committed to act ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensure there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 and relevant EU regulations.

We expect the same high standards from all our contractors, suppliers, and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

This policy will be reviewed regularly and updated as necessary to conform to current legislation and industry best practice

Our Business

AMPYR Distributed Energy (“ADE”) means AMPYR Idea UK Ltd, AMPYR Idea AssetCo UK Ltd and all its directly held subsidiaries. ADE incorporates the management team and employees providing operational capability, as well as the renewable energy assets under management. We fund, own and operate onsite renewable energy solutions for business customers in the UK and the EU. We work with a range of suppliers and partners across the energy, construction, and asset management sectors — including renewables developers, manufacturers of solar components, construction contractors, engineering firms, and professional service providers.

Our Commitment

We are committed to:

  1. Promoting respect for human rights across our business operations;
  2. Preventing any form of modern slavery in our own operations and in our immediate supply chains;
  3. Working with suppliers and partners who share our values and meet our ethical standards;
  4. Continually improving our processes to assess and manage risks relating to modern slavery.

Our Approach to Risk Management

Risk Areas

We recognise that the greatest risks in our value chain may arise in:

  • The manufacturing of solar panels and components, particularly where raw materials originate from high-risk regions;
  • Labour-intensive activities during the construction phase of solar projects;
  • Outsourced services or subcontracted work across international borders.

Our Approach

While we are still developing a comprehensive framework, we are committed to taking the following steps:

  • Embedding modern slavery considerations into our procurement and onboarding processes;
  • Seeking assurance from key suppliers through codes of conduct or compliance declarations that all parts have been manufactured without the use of slavery;
  • Increasing awareness of modern slavery among employees and contractors, particularly those involved in procurement, project development, and supplier engagement;
  • Encouraging open communication and reporting of any concerns.

The Future

As our business grows, we will continue to develop and refine our approach. This includes reviewing our internal policies, building more robust due diligence procedures, and engaging with our supply chain and industry bodies to promote transparency and accountability.

Policy Approval

This policy was approved by the Directors of the companies trading as ADE and will be reviewed at least annually