Modern Slavery Act 2015 Policy And Statement

For Financial Year Ending 2023

INTRODUCTION

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and Community Windpower (Holdings) Limited and its group companies are committed to acting ethically and with integrity in all our business dealings and relationships. We will not tolerate slavery and human trafficking in our

business or our supply chain and are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

OUR BUSINESS AND SUPPLY CHAINS

Community Windpower (Holdings) Limited is a family run company with offices in Frodsham, Cheshire and employs around 50 people across the group companies. The organisation sources and develops land predominantly in Scotland for the purposes of generating renewable wind energy and property development. This statement applies to each of our group companies,

regardless of their turnover.

Our supply chains are fairly limited and includes providers of professional services and contractors.

OUR APPROACH

Our suppliers of goods and services are based predominantly within the UK and EU, as we choose to use local suppliers wherever possible and we therefore expect those suppliers to have applicable anti slavery and human trafficking policies in place. We expect all our suppliers to uphold the same standards and values that we do, and we will not forge relationships with any suppliers who are involved in modern day slavery and human trafficking.

We consider that we have robust employment practices for recruitment and management of our own staff. We ensure that our employees have an employment contract and are paid a salary which at least meets the minimum National Living Wage and are offered the required statutory annual holiday entitlement. Upon starting with the Company each new employee is taken

through an induction process and given a starter pack which includes all of the Company’s policies including the Disciplinary and Grievance Procedures which sets out the process that should be followed a grievance is raised or disciplinary action is required.

We recognise the ongoing need to assess our business and obtain further information on the potential for risk of modern slavery. We are committed to continually developing our due diligence process and internal processes to identify and eradicate any risk of modern-day slavery and human trafficking within our business and our supply chains.

COMPLIANCE

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Everyone is required to avoid any activity that might lead to, or suggest, a breach of the Company’s Anti-Slavery and Human Trafficking policy.

The Anti-Slavery Policy encourages employees to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If anyone believes or suspects a breach of this policy has occurred or that it may occur they must notify their line manager as soon as possible.

The policy also encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be

mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

We also operate a number of internal policies that that reinforce our commitment to conducting our business in an ethical and transparent manner including:
• Anti-Slavery and Human Trafficking Policy
• Anti-bribery Policy
• Whistle-blower Policy
• Equal Opportunities Policy

TRAINING

Training on the Anti-Slavery and Human Trafficking policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training

will be provided as necessary to ensure a high level of understanding of the risks.

MONITORING OUR PROCEDURES

We continue to review our Anti-slavery policy regularly and will provide information and/or training to all our employees on any changes we make. We will also monitor our supply chain to ensure that high standards are maintained and to identify any potential issues with modern slavery and human trafficking.

Disciplinary action, up to and including summary dismissal for gross

misconduct will be taken against any employee that is found to be in breach of our Anti-Slavery Policy.

If any of our suppliers, contractors and other business partners are found to have been involved in modern slavery we will also terminate our commercial relationship with such parties.

GOVERNANCE

This statement constitutes our Modern Slavery Statement for financial year ending 2023 and has been approved by the Board of Community Wind power (Holdings) Limited and each of their principal operating subsidiaries listed below.

Managing Director
This statement applies to the following UK entities:

• Community Windpower Limited
• Sanquhar Community Wind Company Limited
• Sanquhar II Community Wind Co Ltd

• Dairy Community Wind Company Limited
• Dairy Community Wind Farm Limited
• Aikengall Community Wind Company Limited
• Aikengall II Community Wind Company Limited
• Millour Hill Community Wind Co Limited
• Calder Water Community Wind Co Limited
• Sneddon Law Community Wind Company Limited
• Delamere School Limited
• Alvanley Farms Limited
• Crabtree Homes Limited