Bristol Energy Annual Statement
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (MSA), and constitutes the slavery and human trafficking statement of Bristol Energy & Technology Services (Supply) Limited (“Bristol Energy”) for the financial year 2017/2018. Although Bristol Energy is below the mandatory threshold of £36 million in turnover per year, the Board of Bristol Energy has determined that the company will be a proactive industry leader in its early compliance with the MSA, and submitting to tiscreport.org.
Our Structure, business and supply chains
Bristol Energy is a national supplier of electricity and gas to domestic and commercial customers across Great Britain, and is wholly owned by Bristol Holdings Limited, a company owned and operated by Bristol City Council.
Our company launched in to the UK domestic market in February 2016, and now employs over one hundred employees in the city of Bristol boundaries.
Bristol Energy is a different kind of energy supplier, with an ethos to be a force for social good. We are committed to the fair and ethical sale of energy to all, as well as to reducing social inequality, tackling fuel poverty and supporting local renewable energy.
As a small independent supplier of electricity and gas, Bristol Energy purchases power and gas from the wholesale market via third party partners, suppliers and shippers, as well as directly from renewable generators across the UK. We also use a variety of suppliers and partners to deliver our services to our customers, and buy goods and services for our office sites.
Wholesale electricity and gas procurement
Bristol Energy purchases electricity for on-selling to our domestic and non-domestic customers within the UK retail market. It is the contract (or title) for electricity we purchase, rather than the physical delivery or generation of the units of electricity – this is the role of the National Grid and electricity generation companies. The majority of electricity we buy is generated in the UK, although a proportion of it is derived from interconnectors with France and the Netherlands. It is, therefore, difficult to trace every electron delivered to Bristol Energy customers back to its origin.
The wholesale gas that Bristol Energy trades also comes from the national gas infrastructure – we trade for the title to a specific volume of it rather than being able to trade for gas from a specific source. The gas comes from a variety of sources, including the North Sea, but also pipeline connections with continental neighbours – with some pipelines stretching as far back as Russia – or from overseas shipping vessels carrying liquefied gas from places like Qatar or America. Whilst it may be possible to know where all the gas in the UK grid has come from over a certain period (for example a given year), there is no way of knowing which specific units of this gas are delivered to Bristol Energy customers.
We are aware that our wholesale electricity and gas procurement represents a challenge in that our ability to have full visibility over our indirect supply chains is limited. Whilst we cannot easily influence this, we ensure that our relationship with our suppliers is as transparent as possible. We only transact with other registered market participants in the UK, and each relationship is underpinned by a mutually agreed contract. We will take every opportunity to work with our partners and with other market participants in the UK to address any suspected wrongdoing in our indirect supply chain, including any suspected acts of slavery or human trafficking.
Moreover, we are committed to increasing the amount of electricity we buy directly from the source through our Power Purchase Agreements with renewable generators within the UK; through these, we can have better visibility and a closer working relationship with the generator themselves. We have included more details about this below.
Power Purchase Agreements (PPAs)
Bristol Energy works with a number of renewable generators across the UK to source green electricity for our customers, particularly those on our green tariffs. In 2016/17 we had just over 30 PPAs in place with a range of generators, from local businesses through to community energy groups up and down the country. Our relationships with these are underpinned by mutually agreed contracts, and we ensure that we have a close working relationship with these through a strong account management function. On the one hand, this helps us deliver the high level of service we strive to offer these generators; on the other, it allows us to better understand their business. We will never work with businesses we suspect of any human rights abuses such as slavery, servitude or human trafficking, and this includes the renewable generators we buy from.
We are committed to putting in place a robust process through which our Renewables team can confidently assess these risks in relation to every generator we work with and be able to report, internally in the first instance, any suspected wrongdoing.
We work in close partnership with a number of businesses in order to deliver a high level of service to our Bristol Energy customers. Key contracts include that with our CRM system provider, data collector and aggregator as well as the framework we are developing around our smart meter rollout programme. All of these contracts are determined through competitive tendering processes which take into account aspects relating to the suppliers’ approach to social responsibility, including their own procurement and staff policies. As much as possible, we aim to use locally-based suppliers that are aligned with our values, and are Living Wage Accredited employers.
Moving forwards, we are committed to engage more closely with our key partners and encourage them to formally address the requirements of the MSA, including through the publication of their own Article 54 (1)
Statements, where these do not already exist.
Since our launch just under two years ago, we have been focusing our attention and resources into developing an energy company that delivers something different to our customers: the fair and ethical sale of energy, tackling fuel poverty and being a force for social good. We always strive to be better and to look at how we align every single aspect of our business with this ethos. We recognise that incorporating the provisions of the MSA within our procurement policies should be part of this process. We are currently developing a procurement strategy for all our goods and services, asking all of our suppliers to review
the source of their products to identify risks of human trafficking and modern slavery in their supply chains.
Our own people
Our people policies at Bristol Energy encourage an open and supportive working environment, where colleagues can discuss issues impacting them inside or outside work with their manager as well as other dedicated colleagues e.g. the People Team. We also provide a confidential helpline for issues affecting colleagues, whether these are work or non-work related, should they wish to access independent advice and support without our knowledge.
Our whistleblowing policy encourages all colleagues or business partners to report any concerns relating to our activities or supply chain. This includes raising any issues or circumstances that may lead to an enhanced risk of slavery or human trafficking. The whistleblowing policy is designed to make it easy for our workers to disclose information without worrying about reprisal. This policy is discussed with all employees as part of their induction with Bristol Energy.
We are committed to ensuring that colleagues are treated fairly and this includes ensuring they are paid a fair wage. All employees of Bristol Energy and those working regularly on our premises are paid at least the
Living Wage Foundation’s recommended hourly rate. We conduct internal and external benchmarking to ensure our colleagues are being paid fairly and any colleague can raise an issue relating to their pay informally with their manager or via our grievance guidelines.
We only use reputable employment agencies and ensure that any agency workers are also paid the Living Wage Foundation’s recommended hourly rate by their agency. The majority of our permanent recruitment is completed by our own People Team and we build a relationship with each successful candidate.
At Bristol Energy, we expect our colleagues to behave in an ethical manner and to consider our ethos of being a force for social good when conducting themselves and carrying out their duties at work. Any employee found to be knowingly involved in enhancing the risk of slavery or human trafficking will be managed in line with our disciplinary guidelines.
Bristol Energy will ensure all employees are briefed on the issues of modern slavery, to spot the signs of modern slavery, what steps should be taken if they suspect slavery or human trafficking is taking place and how to escalate their concerns within Bristol Energy.
The way forward – Our commitments for 2018/19
This is our first ever Statement pursuant to Section 54 (1) of the MSA. Through its publication we aim to identify and highlight the key areas of our business and supply chain where there is a risk of slavery and human trafficking taking place, what we have been doing to date to tackle these issues, and what commitments we have to better address the risks, improve transparency in our supply chains, and enable our people to identify and report any suspected wrongdoing.
As outlined above, we recognise that the key risks associated with the provisions of the MSA are deeply entrenched in the very nature of our business – the buying and selling on of energy to our customers. Whilst
acknowledging our reliance on the UK energy systems, infrastructure and established players to deliver this outcome, we want to play a leading role in setting an example for other UK energy suppliers in terms of how the associated risks can be addressed. We will do so by:
- Increasing the number of Power Purchase Agreements we have in place, allowing us to better trace (and show our customers) where our electricity comes from;
- Engaging with our main counterparties to ensure that the provisions of the MSA are thoroughly engrained within their own supply chain policies as much as it is possible for them to do so;
- Using our partnership with Unseen to identify ways in which slavery and human trafficking can be identified in the energy sector and collaboratively finding solutions to addressing the key areas of risk.
- With regards to our wider procurement practices, we have set ourselves the following objectives for the year ahead:
- Develop a procurement strategy that takes into account the provisions of the MSA;
- Working with our key suppliers to raise awareness of the MSA and encourage them to take action on this basis, including through publication of their own Section 54 (1) Statements.
We will ensure we are treating our own people in the best possible way, and this includes putting in place all the necessary policies and due diligence processes to ensure that they are treated fairly and are proud to call themselves Bristol Energy colleagues. We will do so by:
- Reviewing our people policies to enhance elements that specifically relate to modern slavery and human trafficking;
- Provide training to all colleagues so they feel empowered about identifying and reporting any suspected acts of slavery and human trafficking;
- We will have an awareness campaign for colleagues on how to identify, report or prevent slavery and human trafficking, as well as signpost colleagues support that is on offer;
- As we do not have a dedicated procurement team, we will assess roles that may require more in-depth training on slavery and human trafficking.