Last updated: June 2024
Statkraft presents its statement made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 (the “Act”). This statement describes the steps taken by Statkraft with a view to preventing and combatting modern slavery in our business and our supply chain. Statkraft AS, Bryt Energy Limited, Statkraft UK Limited and Statkraft Markets Gmbh, which maintains a branch in the UK, are the relevant reporting entities for the purposes of this statement.
ABOUT STATKRAFT
Statkraft AS, a Norwegian state-owned enterprise, is the parent company of the Statkraft Group. The Group produces hydropower, wind power, solar power, gas-fired power and district heating and is a global player in energy market operations. By providing renewable and sustainable energy solutions, Statkraft carries out activities that support a global transition towards a low-carbon climate-resilient economy. Statkraft has over 6,000 employees in more than 20 countries.
Statkraft is committed to sustainability and responsible business practices. The company’s business conduct is guided by globally supported initiatives and standards such as the UN Global Compact (UNGC), the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines), the UN Guiding Principles for Business and Human Rights (UNGPs), and the IFC Performance Standards on Social & Environmental Sustainability. In its efforts to improve, Statkraft is also part of the Nordic Business Network for Human Rights.
Statkraft’s fundamental commitments are summarised in its Code of Conduct, which sets out expectations applying to Statkraft’s employees as well as its business partners. In addition, requirements that suppliers are expected to meet throughout their relationship with Statkraft are summarised in Statkraft’s Supplier Code of Conduct. Depending on the nature of the delivery, additional contractual obligations complement the requirements contained in the Supplier Code of Conduct.
More information can be found on Statkraft’s website (www.statkraft.com).
HUMAN RIGHTS, LABOUR RIGHTS AND MODERN SLAVERY
Statkraft respects human rights as set out in the UNGPs and the OECD Guidelines (i.e., those expressed in the International Bill of Human Rights and the International Labour Organization’s eight core Conventions and its Declaration on Fundamental Principles and Rights at Work). We work to identify and manage our human rights impact. This has also become a legal requirement through the Norwegian Transparency Act, which entered into force in July 2022, and which applies to Statkraft’s activities.
Statkraft’s Supplier Code of Conduct establishes requirements relating to respecting human and labour rights, including on forced labour and child labour. Our Supplier Code of Conduct has been updated to align with the requirements of the Norwegian Transparency Act and reflects the company’s human rights commitment statement. It prohibits unethical and illegal business practices, requires suppliers to cater to a healthy, safe, and secure workplace, and to commit to responsible business conduct.
Our codes of conduct address modern slavery, both through a general policy commitment on human rights as well as specific human rights provisions in the Supplier Code that cover the aspects of modern slavery that are assessed as being most relevant, or at risk given Statkraft’s activities and supply chain.
HUMAN RIGHTS MANAGEMENT
Statkraft’s approach to human rights management is based on the principles of integration and mainstreaming of its human rights policy commitments into existing governing documents, processes and systems, for instance those related to procurement, social sustainability management, human resources and security. Human rights considerations are also an integral part of our decisionmaking processes for project development, mergers and acquisitions, and divestment.
Human rights are identified as a material topic for the company, and labour rights are among Statkraft’s salient human rights both within our own activities and in the supply chain. Ambitions and goals have been adopted on human rights. These goals, alongside status updates relating to the implementation of the goals, are described in the sustainability chapter of the Annual Report. Continuous improvement, including on labour rights and relevant aspects of modern slavery as well as supply chain management, will continue to be described in annual reports.
Procedures are in place to identify and assess potential impacts on human rights arising from our key activities, such as in the development of new greenfield projects, in our transactions and in our supply chain. Through specific risk and impact assessments of our key activities we aim to prevent and/or mitigate when possible, or remediate, if necessary, negative human rights impacts.
We regularly review the implementation and results of the agreed or planned measures through internal reporting and quality control and assurance routines, in an effort to address human rights risks and impacts in our main processes.
Our corporate-level human rights impact assessment has identified four key priority areas with the highest risks. This is where we focus our human rights efforts:
- Community relations and social licence
- Health, safety and security
- Labour conditions in the workplace
- Decent work in our supply chain
Systems are in place to provide all employees with training, guidance and advice about interpretation of Statkraft’s Code of Conduct and desired behaviour.
Statkraft’s Code of Conduct emphasises that employees have both the right and duty to report breaches of legal or ethical obligations through the line organisation or the Group’s Independent Reporting (Whistleblowing) Channel. Reporting can be made anonymously, and the channel is also available for external stakeholders via Statkraft’s web site.
SUPPLY CHAIN MANAGEMENT
Sustainable Development Goal 8 – Decent work and Economic Growth receives particular focus in our sustainability strategy. The UNGP and OECD Guidelines set the direction for how we work.
Statkraft continuously works to improve how sustainability is integrated in procurement practice and seeks to avoid buying from entities linked to negative impacts on people, society, and the environment. Sustainable supply chain management is an integrated part of the procurement process. Statkraft’s aim is to identify, prevent, mitigate, and account for actual and potential adverse impacts on human rights in our supply chain.
Statkraft’s standard supplier agreements include sustainability clauses, a prohibition on the use of forced labour and an expectation on suppliers to comply with Statkraft’s Supplier Code of Conduct.
During the procurement process, suppliers respond to questions on human rights, health and safety, working and employment conditions, including a specific question related to forced labour, modern slavery and human trafficking (in accordance with the UK Modern Slavery Act). All suppliers are integrity checked using the Dow Jones Risk Center, and suppliers with any clear indications or clear suspicions of human rights violations identified are subject to a review and approval process administered by our Corporate Compliance team. Supplier reviews are limited in validity and are periodically updated in accordance with a risk-based model.
Statkraft maps human rights and other sustainability risks related to our primary technologies – hydropower, wind power, solar power and battery energy storage. The procurement team address identified risks in the tender phase, and contracts are adapted to address specific risks and to include obligations to mitigate such risks.
Statkraft implements a ‘Sustainable Supplier Program’ with selected suppliers to develop an understanding of how they identify, prevent, mitigate, and account for potential adverse human and labour rights impacts in their own business and supply chains. Dialogues are held throughout the year with selected suppliers to improve transparency and share best practice to avoid negative impacts on people, society and the environment. In 2023 the sustainability rating tool EcoVadis was implemented, and more than 70 suppliers from across our key technologies and IT procurement are now rated in EcoVadis.
Statkraft’s Group Procurement has a dedicated Sustainable Procurement team who are responsible for developing and maintaining policies and requirements, contract templates and frameworks for the management of sustainability in the supply chain. The unit provides training on sustainability to procurement personnel across Statkraft and cooperates closely with category and contract managers.
OUR SUPPLY CHAIN
Most of Statkraft’s procurement activities are related to equipment and services for production of electricity and construction of powerplants. The supplier base is diverse and includes more than 14, 000 suppliers world-wide, including small and large suppliers from sectors such as the electromechanical industry, civil construction, business consulting and engineering. Some suppliers are small local companies with short supply chains, while others are global industrial groups with long supply chains stretching across different geographies.
The supply chain for equipment used for power production stretches internationally from mining of minerals, production of metals, manufacture to assembly of components, including the transportation between sub suppliers, sometimes located across different continents. Risks identified in our key supply chains include, for hydropower: a risk of poor working conditions and inequality at sub-supplier workshops, for wind turbines: a risk of forced labour and discrimination against women related to production of GRP parts, for solar panels: a risk of forced labour in the production of polysilicon and for battery energy storage systems: human and labour rights risks, including risk for use of forced labour in refining/processing of lithium and graphite as well as for manufacture of battery cells.
Statkraft strongly opposes the use of forced labour and seeks to avoid purchasing from companies that use forced labour by emphasising human and labour rights commitments at each stage in the procurement process, and through specific traceability measures and chain-of custody audit rights to verify adherence to our requirements. Further, Statkraft works with industry associations and peers to raise awareness, increase transparency, and improve industry standards through relevant sector initiatives including the Wind Energy Initiative and the Solar Stewardship Initiative.
The supply chain is relatively short for business consulting and engineering, and the work is usually performed by suppliers in countries where Statkraft is located. Statkraft considers the risk of forced labour and modern slavery in these supply chains to be low.
Statkraft acknowledges that there is an inherent risk of unreasonable working time, inadequate leave periods arid wages below living wage for workers during construction and installation at our sites.
UPDATE ON PROGRESS
During 2023, Statkraft has continued to work proactively to understand and address the potential risks of modern slavery (including forced labour) in our supply chains for our key technologies. Ongoing risk management and improvement measures in 2023 have included:
- Engaging with key suppliers to secure improvements in transparency and traceability
- Enhanced qualification processes for relevant suppliers
- Framework agreements with vertically integrated suppliers
- Securing a contractual right to trace silica-based materials in our solar panels via an independent third party traceability audit.
Other improvement measures during 2023, related more broadly to labour rights on Statkraft sites, have included efforts aimed at securing a living wage for on-site supply chain workers and efforts aimed at ensuring decent working conditions. This has included training programs for project teams, developing new governance and tools related to supplier follow-up, grievance management and on-site checks.
A more comprehensive update of Statkraft’s progress and improvement measures during the course of 2023 can be found in our 2023 Annual Report (at pages 70 to 80).
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Statkraft reporting entities’ slavery and human trafficking statement for the financial year ending 31.12.2023.
This Statement was approved by the Board of Directors on 06.05.2024.
Birgitte Ringstad Vartdal – President and CEO of Statkraft
Alexandra Bech Gjørv – Chair of Statkraft’s Board of Directors
This Group Statement on Modern Slavery has been adopted and approved by the Board of Bryt Energy Limited on 14th June 2024. Signed for and on behalf of Bryt Energy Limited by Duncan Forsyth – Financial Director.