MEMS Modern Slavery Policy

Introduction This statement sets out MEMS Power Generation’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2023 to 31 March 2024. As part of the Engineering / Transport industry/sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. Organisational structure and supply chains This statement covers the activities of MEMS Power Generation who are a specialist temporary power solutions provider in operation 24/7, supplying disaster recovery solutions for our diverse range of customers including small businesses through to blue chip multinational organisations and utility companies. With a fleet of over 500 generators and 40 years’ experience, we are the supplier of choice in the UK power rental market. The organisation currently operates within the UK. Responsibility for the organisation’s anti-slavery initiatives are is as follows:

Policies: Michala Burrluck – Human Resources
Risk assessments: Tom Badman – H&S and Compliance Manager and Mark Diffey – Director
Investigations/due diligence: Michala Burrluck– Human Resources, Tom Badman – H&S and Compliance Manager and Mark Diffey – Director
Training: Via internal and external sources

Relevant policies The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing policy

The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can [use our confidential helpline / complete our confidential disclosure form].

Recruitment and selection policy

The organisation sources applicants on a direct basis via word of mouth; the corporate website; social media outlets; local and national job boards. Agency workers are not normally sourced, however of required our Modern Slavery and Human Trafficking statement is outlined to said providers. Proof of identification is required as well as vetting procedures. It is MEMS policy not to knowingly conduct business with those engaged with slavery and human trafficking and to cooperate with the Police regarding investigations carried out in relation to slavery and human trafficking, when required Due diligence The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
evaluating the modern slavery and human trafficking risks of each new supplier
reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
conducting supplier audits or assessments through the organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified
taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans
participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular
using reputable suppliers where they can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular
invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship

Performance indicators The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

requiring supply chain managers have completed training on modern slavery
developing a system for supply chain verification whereby the organisation evaluates potential suppliers before they enter the supply chain
reviewing its existing supply chains whereby the organisation evaluates all existing suppliers

Training The organisation requires supply chain managers within the organisation to complete training on modern slavery. The organisation’s modern slavery training covers:

how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available
how to identify the signs of slavery and human trafficking
what initial steps should be taken if slavery or human trafficking is suspected
how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation
what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative
what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies
what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains

Awareness-raising programme As well as training staff, the organisation has raised awareness of modern slavery issues by conducting toolbox talks which explains to staff

the basic principles of the Modern Slavery Act 2015
how employers can identify and prevent slavery and human trafficking
what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation
what external help is available, for example through the Modern Slavery Helpline

Board of Directors approval This statement has been approved by the organisation’s Board of Directors, who review and update it annually.