Introduction

This statement has been published in accordance with the UK Modern Slavery Act 2015 (the “Act”). It sets out the steps taken by Energy Transition Holdings Ltd (“Energy Transition Holdings”) and its subsidiaries (for the purposes of this statement, collectively “OVO”) to manage the risk of modern slavery and human trafficking in its operations and supply chains during the financial year ending 31 December 2024.

OVO fully supports the aims of the Act and recognises that slavery and human trafficking is a global issue that needs to be addressed by all companies within all industries.

OVO is committed to protecting human rights and eradicating the risk of modern slavery in its own operations and supply chain.

OVO’s structure and business

OVO was founded in 2009 as an energy retailer. It has since grown into a group of energy technology companies with a shared purpose to drive progress towards zero carbon living.

OVO Group Ltd is a holding company and does not trade in its own right.

OVO Finance Ltd (“OVO Retail”) is the group company through which the majority of OVO’s retail energy operations are conducted.

Kaluza Ltd (“Kaluza”) is a software platform incubated within OVO, now serving multiple clients in multiple markets. Kaluza is a modular, end-to-end Software as a Service (SaaS) platform that enables energy utilities to manage customer communications, service and billing, as well as offering a distributed energy resource management solution.

The principal activities of the OVO Group are set out below:

OVO Retail

  • the procurement and supply of gas and electricity from the wholesale markets and renewable sources;
  • the installation, repair and maintenance of boilers and the provision of boiler and heating cover;
  • the installation of smart meters and the provision of related services; and
  • the installation of technologies and products like solar panels and heat pumps that help customers to decarbonise or reduce their energy consumption, installed either directly or through a franchise business.

Kaluza

  • the development of technology solutions to enable energy utilities to transform their operations at lower costs, personalise their services, and fast track innovation around low-carbon technologies.

This statement seeks to capture the business activities of all relevant OVO subsidiaries including but not limited to:

  • OVO Finance Ltd
  • OVO Energy Ltd
  • OVO Electricity Ltd
  • OVO Gas Ltd
  • Kaluza Ltd

OVO’s workforce

As of 31 December 2024, OVO directly employed approximately 4,000 people.

Since 2015, OVO has been committed to paying a Living Wage. From 2021 onwards, OVO has paid the Real Living Wage across all of its operating subsidiaries within OVO Group. The Real Living Wage is an hourly rate of pay set independently by the Living Wage Foundation and voluntarily adopted by employers who believe their people deserve a wage that meets everyday needs. It is distinct from the Government's 'National Living Wage' and ‘Minimum Wage’.

Prior to commencement of employment, OVO ensures that the relevant right to work checks are carried out. These checks are conducted by a specialist independent company. All OVO people start with a criminal records check and right to work in the UK. For specific roles, financial records and Director background checks are also carried out. Some roles require further checks depending on the area of the business and/or the level of the role.

All of OVO's direct operations and people are based in countries that are considered to have a low prevalence of slavery according to the Global Slavery Index.

Some services (e.g. facilities management, customer call centre, IT services, meter and device installations, debt collection and the manufacturing of intelligent energy technology devices) are outsourced to third parties. OVO undertakes initial due diligence before deciding to contract with suppliers; and maintains a supplier selection process that includes assessment of risks including product and service type, country and sector risks. More detail on OVO’s supply chain due diligence procedures are detailed below.

OVO’s supply chains

During the 2024 financial year, OVO worked with approximately 1,700 suppliers. The main 2024 supplier spend related to:

  • the procurement of electricity and gas from OVO's wholesale commodity provider;
  • the manufacture, supply and installation of smart gas and electricity meters by third parties;
  • the provision of marketing services, technology platforms and outsourced service partners; and
  • the maintenance of the UK’s electricity distribution network and other standard energy industry costs.

During the same period, Kaluza worked with approximately 200 suppliers. The majority of Kaluza’s spend fell into the following categories:

  • the provision of critical IT infrastructure: including “Tier 1” IT infrastructure providers that perform essential services to support Kaluza’s software products;
  • IT software tooling: SaaS IT software tooling to support Kaluza developers;
  • tools to support Kaluza’s people and offices, sales and marketing activities, and outsourced service partners to support products and business operations.

Nearly all of OVO’s Tier 1 suppliers are located in countries identified as low risk for modern slavery and corruption, according to the Global Slavery Index and the Corruption Perceptions Index. The only exceptions are two suppliers (representing 0.19% of total spend) who were based in Bulgaria, which is considered higher risk by both indices above.

Prior to onboarding these suppliers, OVO conducted thorough due diligence to ensure their practices align with OVO’s Human Rights Policy and all relevant legislation. This process helped to safeguard the business against potential risks and uphold OVO’s commitment to ethical and responsible sourcing. OVO was satisfied with the responses provided by the suppliers but continues to assess any social risks that may arise.

Policies

OVO has several policies that relate to the prevention of slavery and human trafficking, both across OVO's own businesses and within OVO's supply chain.

OVO's Human Rights Policy outlines commitments to respecting and upholding human rights in relation to people, supply chain workers, customers and communities that are embedded across the business.

OVO business policies

Internal policies include the OVO Code of Conduct, which forms part of OVO Retail's commitment to being a sustainable, ethical and responsible business. The Code of Conduct sets out expectations of how OVO Retail people should conduct business activities, treat one another and external stakeholders, and uphold the OVO Values: ‘Find a Better Way’, ‘Do What’s Right’ and ‘Build Something Great’.

The OVO Code of Conduct specifies OVO Retail’s zero-tolerance approach to all types of modern slavery and human rights abuse within the OVO Retail business and supply chains. OVO’s digital learning module on the OVO Code of Conduct policy had over 3,000 completions in 2024.

Distinct from OVO Retail values, Kaluza has its own set of five key values: ‘We’re on a mission’, ‘We build together’, ‘We’re inclusive’, ‘We get it done’ and ‘We communicate with purpose’. These values underpin Kaluza’s commitment to building a collaborative environment that welcomes everyone. In addition, Kaluza has a range of policies that seek to uphold these values and ensure that Kaluza adopts suitably sustainable, ethical and responsible business practices.

OVO maintains and operates whistleblowing policies. This includes OVO Retail’s Speaking Out Policy which aims to ensure that any illegal or improper conduct is dealt with appropriately and is included in the OVO Code of Conduct. People can raise concerns without fear of repercussion, and anonymously via the Vault platform (OVO’s Speaking Out tool) if they choose to.

OVO also maintains and operates grievance policies that outline the process for raising and addressing grievances.

In addition, OVO has progressive policies to protect and nurture the wellbeing of their people, including flexible bank holidays, unlimited bereavement leave and health benefits as standard. This ensures OVO build a positive culture where people thrive at work and are fairly rewarded.

OVO supplier policies

OVO expects all suppliers and business partners to act and behave in a way that upholds OVO’s values.

OVO’s Supplier Code of Conduct sets out the standards, principles and values that OVO Retail expects suppliers and business partners to uphold, including a commitment to eradicating modern slavery. The Code of Conduct includes explicit reference to expecting business partners to respect and uphold human rights in accordance with legal requirements and international human rights standards and ensure that they are taking appropriate steps to prevent modern slavery and human trafficking existing within their business and supply chains.

In 2020, OVO Retail required all of its new suppliers to provide written confirmation that they adhere to OVO’s Supplier Code of Conduct. OVO Retail is also undertaking an exercise to get existing Tier 1 suppliers to sign the Supplier Code of Conduct. Currently, 92% of OVO’s Tier 1 suppliers have signed the Supplier Code of Conduct.

Kaluza’s Supplier Code of Conduct similarly requires business partners to respect and uphold human rights in accordance with legal requirements and international human rights standards, and to take appropriate steps to prevent modern slavery and human trafficking within their business and supply chains.

Risk assessment

Each financial year, OVO Retail completes a desktop modern slavery risk assessment of Tier 1 suppliers based on procurement spend data. This annual assessment assigns a modern slavery and human rights risk rating to each supplier, based on the category of goods and services purchased, and the geographical location of the supplier. This assessment uses publicly available third-party data to determine the level of risk associated with each country and category of goods, such as the Global Slavery Index and Corruption Perceptions Index.

This assessment allows OVO to identify potentially high-risk Tier 1 suppliers for further investigation and, where necessary, the development of improvement action plans. The process is overseen and validated by the OVO Retail Procurement team, including the Senior Supplier Manager with responsibility for Environment, Social and Governance (ESG) risk management.

Due diligence processes

OVO is committed to conducting business in a lawful and responsible manner, including engaging with suppliers to uphold OVO’s values.

OVO Retail has an established sustainable procurement process. Due diligence is performed on potential suppliers that present a higher level of inherent sustainability risk, as per OVO Retail’s Sustainability Risk Criteria. Suppliers are considered to present a higher level of inherent sustainability risk if their product or service, or country of operation, present ESG risks.

Potential suppliers are asked to complete a questionnaire relating to their management of these risks. Depending on the industry the supplier works in, the product or service being provided, additional sector specific questions are asked.

This questionnaire also considers whether the supplier’s country of operation has a high prevalence of modern slavery or corruption. It also requests information on the supplier’s Human Rights and Modern Slavery policies that outline their approach to safeguarding human rights, including whether any prior instances of labour or human rights abuses have been identified.

The responses are reviewed by OVO Retail’s Sustainability team to assess whether modern slavery, social, and environmental risks are being appropriately managed.

As part of this year’s assessment, two suppliers were identified as operating in countries with potentially higher levels of corruption and modern slavery, according to the indices referenced earlier. The Procurement and Supplier Management teams conducted the necessary due diligence prior to onboarding to ensure that any potential risks were addressed.

With respect to Kaluza, adherence to the Kaluza Code of Conduct seeks to ensure suppliers meet suitable compliance standards across a range of key topics including with respect to anti-Modern Slavery standards.

Kaluza has an established procurement process where appropriate supplier contracts are subject to thorough legal, information security and data protection review.

Supplier management

OVO understands the need to continue working with suppliers once the relationship is live to ensure they are continuing to adhere to the values and standards set out during the due diligence and contracting process.

The OVO Retail Procurement and Supplier Management team engage with suppliers to improve performance across a range of issues and risks, including sustainability and ESG risk. This supports ongoing risk management and ensures any modern slavery risks continue to be identified, assessed, managed and monitored once the relationship has gone live and throughout the lifecycle of the relationship.

Over the past two years, OVO Retail’s Procurement and Sustainability teams have been developing a category-specific approach to procurement and supplier management. For each of these categories, an “ESG” risk landscape has been defined, which outlines the material sustainability risks present across that category, including those related to modern slavery and broader human rights concerns.

For each risk landscape, the supplier receives a series of questions that aim to understand how current and potential suppliers manage the ESG risks specific to their category.

This tailored, category-specific approach enables more effective risk management and is well-established for higher-risk categories such as Technology and Products (e.g. the procurement of hardware like heat pumps, solar panels, and electric vehicle chargers).

The teams are progressively extending this approach across all procurement categories to ensure best practice is embedded throughout OVO’s supply chain and that any potential risks are appropriately addressed, escalated and managed.

The Sustainability team has also begun to deliver tailored training to the Procurement and Supplier Management teams responsible for each category. This training equips them to identify, manage, and mitigate the specific ESG risks relevant to their categories.

In 2024, no instances of modern slavery were identified across OVO’s Tier 1 suppliers base. Where opportunities for improvement were identified, OVO Retail procurement and sustainability teams worked with the supplier on appropriate remedial action plans.

In the event of modern slavery practices being identified, or the supplier being unable to raise standards when required to do so, OVO will take action which may result in termination of the business relationship and reporting to the relevant authorities where appropriate as per the OVO Supplier Code of Conduct.

Assessment of effectiveness

OVO recognises the importance of assessing the effectiveness of its efforts to address modern slavery risks.

In 2024, OVO Retail adopted new Source-to-Pay Technology which includes a supplier management tool. This technology is designed to streamline processes and will support the ongoing monitoring of modern slavery risk management initiatives. As mentioned above, a key focus has been the development of a category-specific approach to ESG risk management across different areas of organisational spend, ensuring that risks are appropriately identified and managed in a way that is tailored to each category.

While this tailored approach enhances OVO’s ability to manage risk at a granular level, it has temporarily limited OVO’s capacity to report against broader social KPIs, such as social value generated from Tier 1 suppliers or residual social risk exposure. As an interim measure, OVO have consolidated modern slavery effectiveness reporting under a single KPI, with plans to expand this framework once the new system is fully operational:

  • Percentage of Tier 1 suppliers who have signed OVO’s Supplier Code of Conduct (%)

As of the end of 2024, 92% of Tier 1 suppliers had signed the Code, reflecting strong alignment with OVO’s ethical sourcing standards.

Kaluza recognises the importance of understanding the effectiveness of the controls put in place around modern slavery. As such, Kaluza tracks the percentage of suppliers who sign up to the Kaluza Code of Conduct.

Training and capacity building

OVO is aware of the importance of raising awareness of modern slavery and human trafficking across OVO's organisation and supply chain.

In 2024, OVO’s Sustainability team launched a Climate Confidence programme designed to equip all employees with a higher level of climate literacy. The programme covers a broad range of sustainability topics, including ESG and modern slavery issues. In autumn 2024, the Sustainability team delivered a series of 90-minute educational sessions to OVO’s Senior Leaders and their direct reports, focusing on the various sustainability risks the business and its value chain are exposed to, and how these are identified, managed, and mitigated. ESG-related risks, including those linked to modern slavery, have also been formally discussed at OVO’s Risk Committee, further embedding them into the organisation’s broader risk governance framework.

Looking ahead

OVO recognises that the eradication of modern slavery and human trafficking is a continuous, collaborative and evolving process.

The priorities for the year ahead are to:

  • Continue to devise and implement category-specific strategies for remaining areas of spend; and
  • Expand existing sustainable procurement training and roll out Climate Confidence training to all OVO employees to help manage environmental and social risks.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes OVO's slavery and human trafficking statement for the financial year ending 31st December 2024.

Jayne-Anne Gadhia
Chair of the Board, OVO

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