Statement issued in accordance with the Modern Slavery Act 2015 (“the Act”) in relation to the period 1 January 2021 to 31 December 2021 (“the Statement Period”)
Introduction from the Chief Executive Officer
We are committed to improving our practices to combat slavery and human trafficking, with a view to ultimately achieving the best possible practices in this regard.
Organisation’s structure and business
Doveryard Limited (“Doveryard”) is the developer of an energy recovery facility to be constructed at Oldhall West Industrial Estate, Irvine, Scotland (“the Plant”). Construction activities are expected to commence in the first quarter of 2022 with the Plant being operational during 2024.
Doveryard has no turnover presently. Once operational the Plant will manage 186,500 tonnes of waste per annum.
Doveryard is the direct parent company of DY Oldhall Energy Recovery Limited (“the Subsidiary”). Doveryard plans on winding up the Subsidiary shortly after the end of the Statement Period in order to simplify its group structure.
Our supply chains
Aside from services provided to Doveryard by its professional advisors, which services we consider to be low risk in the present context, our supply chains during the Statement Period are set out below.
- Doveryard is party to an EPC contract, for the construction of the Plant. The EPC contractor is (or will
shortly be) party to a number of sub-contracts.
- Doveryard is also party to two long-term fuel supply agreements however no services will be rendered pursuant to these agreements during the Statement Period, and thereafter not before the Plant is ready for performance testing and commissioning.
- Doveryard is also party to a long-term operation and maintenance contract, however no services will be rendered pursuant to this agreement until the Plant is ready for operation.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems
and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Modern Slavery Policy.pdf
Due diligence processes for slavery and human trafficking
The activities of Doveryard are overseen by Melton Renewable Energy UK Limited (MRE) pursuant to a management services agreement entered into between the parties. As part of Doveryard’s initiative to identify and mitigate any risks this has been raised as a particular issue with the relevant members of MRE’s management
team (including in particular commercial, procurement, and fuel supply departments).
MRE has carefully considered its various supply chains and identified particular areas of risk, it being noted that construction activities and its fuel supply chain (which involves the waste industry and transportation) have each been identified as industry sectors presenting a potentially higher risk.
We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Encourage vigilance as to potential risk areas in our supply chains.
- Encourage whistle-blowing and protect whistle blowers.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure those in our supply chains as well as our contractors comply with our values, we have put in place a supply chain compliance programme.
Given that, during the Statement Period, services are being provided to Doveryard only pursuant to the EPC contract, our compliance programme ensures that this contract requires the contractor to comply with all applicable legislation, which includes the Act.
Ongoing compliance with the Act will be monitored by MRE’s senior management team and in particular by key representatives from the following departments:
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, MRE has provided training to such of its staff members as are likely to be affected by the Act and its requirements.
As work commences on site, we will be monitoring the contractor induction programme, ensuring that this makes specific reference to the Act, gives a brief explanation of what the Act is designed to combat and asks all contractors to raise any relevant concerns with their contact either at the EPC contractor or at Doveryard.
Doveryard will also introduce a confidential external whistle-blowing hotline.
The EPC contractor will be asked to provide an annual statement confirming that no slavery or human trafficking has taking place in its business or supply chains in the period in question.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the company’s slavery and human trafficking statement for the period ended 31 December 2021.
E J Wilkinson
1st December 2021
Board approval obtained on 30th November 2021