Modern Slavery Act
Slavery and Human Trafficking Statement for the Year Ended 31 March 2023
- Our Policy
Certas Energy UK Ltd (“Certas Energy”) is opposed to slavery and human trafficking in any part of our activities or our supply chains. We are therefore committed to ensuring that we have adequate policies and procedures in place to identify and prevent these practices.
We met the turnover threshold applicable under section 54 of the Modern Slavery Act 2015 in the period covered by this statement. This is the eighth Modern Slavey and Human Trafficking Statement issued by Certas Energy under the UK Modern Slavery Act 2015.
- Our Business
Certas Energy’s aim is to provide world class energy solutions to our wide range of commercial and domestic customers. As the UK’s largest independent supplier of liquid fuels into the residential, commercial and agriculture markets, we operate 94 depots and 900 trucks in this sector. Certas Energy Lubricants supplies premium branded lubricants for businesses throughout the UK and France. Roadside Services brings together Retail, Fuel Cards, Bunker sites and SNAP Account. We also recognise the importance of energy transition and are looking to accelerate our customers’ net zero journey through the provision of low-carbon energy solutions including lower carbon liquid fuels, electric vehicle solutions, Air Source Heat Pumps and solar, and providing expert advice and solutions to ensure the right energy fit to our customer’s needs.
More information on our business in available at www.certasenergy.co.uk
Certas Energy is part of the DCC Group and sits within its Energy division. DCC is a leading international sales, marketing and support services group with a clear focus on performance and growth. Its headquarters are in Dublin, Ireland. It is listed on the London Stock Exchange and is a constituent member of the FTSE 100 Index.
DCC currently has operations in 22 countries and employs over 16,000 people. Additional information on the Group is available at www.dcc.ie.
- Organisational Structure and Supply Chains
Certas Energy is organised into three business units as outlined below:
We are the UK’s largest fuel distributor, supplying residential, agricultural, industrial, commercial and the public sector nationwide. Delivering billions of litres of high-quality fuel all over the UK each year. We are also driving the energy transition across all our business sectors and partnering with customers as they look to transition to cleaner alternatives. Through introduction of a new Renewable Energy division within Energy Solutions we are committed to building upon the processes in safety and compliance in energy expertise developed in the distribution of liquid energy, transferring them to services in renewable energy. This includes replacement liquid fuels, solar, heat pumps and EV options. We work with customers to provide objective advice on how best to reduce their GHO impact in their business or home.
We are trusted by the world’s leading brands to deliver market leading lubricants across the UK and France. Our customers rely on us for lubricants to maximise efficiency, boost performance and reduce downtime. Our extensive portfolio of products from Shell, Castrol, Q8, Valvoline, Hyperdrive and Vickers Oils covers a wide range of lubricant applications.
We deliver to over 800 retail forecourts across the UK and own and operate a further 100 sites (including in the Isle of Man and the Channel Islands). As well as providing a national network of bunker sites for HGV customers, Fuel Cards and SNAP account for cashless payments for roadside services in the commercial sector. We aim to make every road journey for every customer, safer, easier and more sustainable across the UK and Europe through World Class products, facilities and customer service.
We only source products from reputable suppliers, the majority of whom are based the UK and EEA. We have one supplier based in the USA.
The following table contains a summary of the activities that we consider present the highest risk of slavery and human trafficking in the industries in which we operate, with, in each case, a summary of the steps we have in place to avoid these affecting our activities or our supply chains.
|Industry Risk||Steps Taken|
|Our business identified that workers on manual car washes may be at risk of exploitation. This risk is substantially mitigated by the use of automated car washes on Certas Energy forecourts.||Where the use of automated car washes is not possible, Certas Energy appoints reputable contractors that comply with applicable employment standards to provide manual car wash services. Certas Energy also carry out due diligence on their employment practices. Certas Energy is also a member of the Car Wash Association (CWA) which works closely with the government on modern slavery and human trafficking issues in this sector.|
|Our business identified that workers providing cleaning services at our offices, depots and petrol stations may be at risk of exploitation.||Certas Energy appoints reputable contractors that comply with applicable employment standards to provide cleaning services. Certas Energy also carry out due diligence on their employment practices. All employees in our retail stores have been given training in the last year on spotting signs of modern slavery as part of their Code of Conduct training.|
|Our business provides product and brand to many retail forecourts, where we identified that workers may be at risk||We agree formally with all our retail customers that they will operate in accordance with good trading practices, standards and procedures which reflect a commitment to safety and human rights in the workplace, anti-bribery and anti- corruption.|
|Our business engages some agents and contractors to provide some services including oil tank installation and removal and maintenance services and the installation of renewable technologies such as air source heat pumps and solar panels.||We only use approved contractors who have successfully completed our supplier onboarding process. The Know Your Supplier process includes a risk assessment based upon publicly available information and responses to due diligence questions which relate to areas including commitments to safety and human rights in the workplace, anti-bribery and anti- corruption policies and practices.|
|Our business has identified an emerging risk area relating to the sourcing of some products relating to its energy transition products and service offerings such as solar photovoltaic panels.||This situation is being monitored and additional due diligence is undertaken as appropriate. Specialist due diligence questions have been created for inclusion in any future acquisition projects.|
- Policies in relation to Slavery and Human Trafficking
The DCC Code of Conduct (“the Code”) sets out our Group’s commitment to acting ethically and with integrity towards our employees and in all our business relationships. The Code underpins most of the compliance policies and processes that are in place at Certas Energy.
Specifically, section 2 of the Code sets out our commitment to fair employment practices and section 14 of the Code sets out our commitment to preventing, as far as practicable, slavery and human trafficking in our supply chains.
The DCC Group Supply Chain Integrity Policy sets out the approach taken by every business in the DCC Group to ensuring that all the products we sell meet applicable legal and ethical standards.
In addition, the DCC Human Rights Policy sets out DCC’s specific commitment to operate to internationally recognised standards of human rights, including in relation to forced labour, child labour and unsafe working conditions. These documents are available at http://www.dcc.ie/responsibility/our-policies.
Our policy on slavery and human trafficking is set out in section 1 of this statement.
The requirements of the Code, Group Supply Chain Integrity Policy, Human Rights Policy and our own policy are reflected in the more detailed policies and procedures that we have in place in Certas Energy. These are addressed in more detail in section 5 of this statement. A refresher training program has been provided this year across the entire business on the Code of Conduct with bespoke training given to employees in retail and operations focussing on key areas which are most applicable to them, including the protection of human rights and the identification of and prevention of modern slavery.
- Due Diligence and Assessing and Managing Risk
As part of our compliance with the policies referred to above, we take the following steps:
- Assess potential risk areas in our business and our supply chains evaluating source location, materiality, Product Type and manufacturer and carrying out integrity actions based on overall risk assessment.
- Provide guidance to our Suppliers on our principles via the Supplier Code of Practice
- Mitigate the risk of slavery and human trafficking occurring in our supply chains, including by reviewing, where necessary, the controls that our suppliers have in place and carrying out other suitable checks;
- Monitor potential risk areas in our supply chains on a periodic basis.
Certas Energy sourced the majority of its products from oil majors such as Shell, Essar, Phillips 66 and Valero. Certas Energy purchased less than 1% of its purchases from countries that scored more than 50 on the most recent Global Slavery Index.
- Assurance and Key Performance Indicators
Accountability for ensuring that our procedures are adequate and are adhered to in all areas of our activity rests with the directors of Certas Energy. Responsibility for defining and implementing relevant policies and procedures sits with the Legal and Compliance and HR team teams.
We report on compliance with the DCC Group Code of Conduct and Supply Chain Integrity Policy every six months.
- Training and Awareness
In the period covered by this statement a training program was completed across the business to raise awareness of the Code of Conduct and focus on key topic areas including the protection of human rights and prevention of modern slavery. All employees have access to a copy of the Code of Conduct and it is discussed with new starters and newly acquired businesses as part of the onboarding process. As at the date of this statement across the business, 84% of on network employees have completed the most recent training as part of our new starter and refresher training program with additional face to face training provided to our colleagues in retail and operations.
We provide training to relevant employees on supply chain risks, including the risk of slavery and human trafficking at suitable intervals. Our participation in industry associations and our dealings with suppliers also provide information on where slavery and human trafficking risks may arise in the industries where we are active and best practice in avoiding them. We are also gold level partners of the Supply Chain Sustainability School and make use of the various training and networking events available to enhance awareness generally across sustainability topics, including modern slavery.
During the period, Certas Energy has established its ESG Committee with delegated authority from the Board. This committee is made up of a number of representatives across all divisions of Certas Energy who represent each of the four sustainability pillars – 1) climate change and energy transition 2) Environmental and safety protection 3) People and social 4) Governance and compliance. The ESG Committee overseas the creation of the Modern Slavery statement and all members received specific and targeted training on Modern Slavery during the period.
Certas Energy encourages all employees to “Do the Right Thing” and “Raise a Concern” if they believe that there is something wrong. The Whistleblowing policy and procedure is well documented and publicised, and Certas Energy encourages reports to be made internally, to DCC Group or via an independent whistleblowing service which is available 24 hours a day every day of the year. Certas Energy has a clear policy of non-retaliation against any person who raises a concern and commits to ensuring that any person is fully supported, that concerns are taken seriously and carefully investigated, anonymity will be respected where requested, and appropriate action will taken. No concerns about slavey or human trafficking were raised in the period covered by this statement.
- Nature of this Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 March 2023.
This statement has been approved by the board of directors of Certas Energy UK Ltd