Policies

Doveryard Privacy Policy

 

Preliminary remarks

In accordance with the Legislative Decree no. 196 of 30 June 2003 (Code for the protection of personal data), as amended, Stc Power S.r.l., headquartered at Forlì, Via Dragoni n. 59, as “controller” of the data processing is required to provide to the interested parties, pursuant to art. 13, the following information regarding the use of their personal data. The statement is also based on Recommendation no. 2/2001 that the European authorities for the protection of personal data – gathered in the Group established under art. 29 of Directive no. 95/46/EC – adopted on 17 May 2001 to establish minimum requirements for collecting personal data on-line, and, in particular, the manner, timing and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purpose of the connection.

 

Purpose of Italian Legislative Decree 196/2003

The Code aims to ensure that the processing of personal data will be performed in respect of fundamental rights and freedoms, as well as the dignity of the interested parties, with particular reference to privacy, personal identity and the right to protection of personal data. The regulation aims to protect the data of interested parties against improper processing and use by the “data controller” and, in particular, against the disclosure of data to third parties without the prior consent of the interested parties, pursuant to art. of Legislative Decree 196/2003, with the exception of the cases provided for by law under art. 24.

 

Data controller

Stc Power S.r.l. – Via Dragoni, 59 – 47122 Forlì (Italy), info@stcpower.it

 

Type of collected data

The Personal Data collected by this Application, either independently or through third parties, include: Email, First Name, Last Name, Resume, Telephone Number, City, Address, Country, Postal code, Profession, Province, Cookie and usage data. Other Personal Data collected may be listed elsewhere in this privacy policy or through information texts displayed upon collection of said data. The Personal Data may be entered voluntarily by Users, or collected automatically when using this Application. Any use of Cookies – or other tracking tools – by this application or the owners of third party services used by this Application, unless otherwise specified, aims to identify the Users and track their preferences for purpose closely tied to the provision of the service requested by Users. Failure to provide some Personal Data may prevent this Application from providing its services. The User assumes the responsibility of the Personal Data of third parties published or shared through this Application and represents to have the right to communicate or disseminate them, thereby releasing the Controller from any liability to third parties.

 

Mode and place of processing of the data collected

Processing methods

The Controller processes the Personal Data of Users taking all necessary security measures to prevent unauthorised access, disclosure, modification or destruction of said Personal Data. Processing is carried out using IT and/or ICT tools, based on organisational methods and procedures strictly related to the purposes indicated. In addition to the Controller, in some cases, categories of personnel involved in the site organisation (administrative, sales, marketing, legal staff, system administrators) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) may have access to the Data. The Controller shall appoint said persons, if necessary, as Responsible for Processing. The updated list of persons Responsible for Processing can be requested at any time to Data Controller.

 

Place

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, contact the Data Controller.

 

Time

The Data are processed for the time necessary to perform the service requested by User, or as required by the purposes described in this document, and the User can always ask for discontinuation of Processing or deletion of Data.

 

Purposes of Data Processing

The User Data are collected to allow the Controller to provide their services, as well as for the following purposes: Contact the User, Recruiting, Display content from external platforms and Statistics. The types of Personal Data used for each purpose are indicated in the specific sections of this document.

 

Contacting the User

Contact form (This Application)

The Users, by filling out the contact form with their Data, agree to their use in response to requests for information, enquiries, or any other request indicated in the form.
Personal data collected: Company, PC, Last Name, Email, City, Address, Country, First Name, Telephone Number, Profession and Province.

 

Displaying content from external platforms

These services allow you to view content hosted on external platforms directly from the pages of this Application and interact with them. If a service of this type is installed, it is possible that, even in case the Users do not use the service, the latter collects traffic data relating to the pages in which it is installed.

 

Google Fonts (Google Inc.)

Google Fonts is a service for displaying font styles run by Google Inc. which allows this Application to integrate such content within its pages.
Personal data collected: Cookies and Usage data
Place of processing: USA – Privacy Policy

 

Widget Google Maps (Google Inc.)

Google Maps is a service for displaying maps run by Google Inc. which allows this Application to integrate such content within its pages.
Personal data collected: Cookies and Usage data
Place of processing: USA – Privacy Policy

 

Statistics

The services contained in this section are used to allow the Data Controller to monitor and analyse traffic data and are used to keep track of User’s behaviour.

Doveryard Limited – Anti-corruption and bribery policy

 

1. Policy statement

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate
and implementing and enforcing effective systems to counter bribery and corruption.

1.2 We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

 

2. About this policy

2.1 The purpose of this policy is to:

(a) set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

(b) provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

2.2 It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine. As an employer if we fail to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously.

2.3 In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

2.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

 

3. Who must comply with this policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business
partners, sponsors, or any other person associated with us, wherever located.

 

4. Who is responsible for the policy?

4.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2 The activities of Doveryard Limited are overseen by Melton Renewable Energy UK Limited (MRE) in accordance with the terms of a management services agreement entered into between the parties (MSA). As required by the MSA, MRE’s Group HR Manager and Legal Counsel have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.

4.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

4.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to MRE’s Group HR Manager.

 

5. What are bribery and corruption?

5.1 Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

5.2 An advantage includes money, gifts, loans, fees, hospitality, services, discounts, and the award of a contract or anything else of value.

5.3 A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.

5.4 Corruption is the abuse of entrusted power or position for private gain.

 

6. What you must not do

It is not acceptable for you (or someone on your behalf) to:

(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

(b) give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;

(c) accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it we will provide a business advantage for them or
anyone else in return;

(d) accept hospitality from a third party that is unduly lavish or extravagant under the circumstances.

(e) offer or accept a gift to or from government officials or representatives, or politicians or political parties, without the prior approval of your manager or MRE’s Group HR
Manager;

(f) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or

(g) engage in any other activity that might lead to a breach of this policy.

 

7. Facilitation payments and kickbacks

7.1 We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.

7.2 Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK, but are common in some
other jurisdictions.

7.3 Kickbacks are typically payments made in return for a business favour or advantage.

7.4 You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods
or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with MRE’s Group HR Manager

 

8. Gifts, hospitality and expenses

8.1 This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:

(a) establishing or maintaining good business relationships;

(b) improving or maintaining our image or reputation; or

(c) marketing or presenting our products and/or services effectively.

8.2 The giving and accepting of gifts is allowed if the following requirements are met:

(a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

(b) it is given in our name, not in your name;

(c) it does not include cash or a cash equivalent (such as gift certificates or vouchers);

(d) it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas; and

(e) it is given openly, not secretly;

(f) it complies with any applicable local law.

8.3 Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable.

8.4 Reimbursing a third party’s expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost
of an extended hotel stay) is not acceptable.

8.5 We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention
behind it should always be considered.

 

9. Donations

9.1 We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of MRE’s Group HR Manager and Chief Executive Officer.

 

10. Record-keeping

10.1 We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

10.2 You must declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review.

10.3 You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

10.4 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

 

11. Your responsibilities

11.1 You must ensure that you read, understand and comply with this policy.

11.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

11.3 You must notify MRE’s Group HR Manager or the confidential helpline as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further
“red flags” that may indicate bribery or corruption are set out in paragraph 16.

 

12. How to raise a concern

12.1 You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.

12.2 If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager or MRE’s Group HR Manager or report it in accordance with our Whistleblowing Policy as soon as possible.

12.3 If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your manager or MRE’s Group HR Manager or through the confidential helpline.

 

13. Protection

13.1 Individuals who refuse to accept or offer a bribe, or who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy,
even if they turn out to be mistaken.

13.2 We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place
in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform MRE’s Group HR Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using MRE’s Grievance Procedure.

 

14. Training and communication

14.1 Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

14.2 Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

 

15. Breaches of this policy

15.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

15.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

 

16. Potential risk scenarios: “Red Flags”

The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

 

If you encounter any of these red flags while working for us, you must report them promptly to your manager or MRE’s Group HR Manager or by using the procedure set out in MRE’s whistleblowing policy:

(a) you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
(b) you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign
government officials;
(c) a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
(d) a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
(e) a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
(f) a third party requests an unexpected additional fee or commission to “facilitate” a service;
(g) a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
(h) a third party requests that a payment is made to “overlook” potential legal violations;
(i) a third party requests that you provide employment or some other advantage to a friend or relative;
(j) you receive an invoice from a third party that appears to be non-standard or customised;
(k) a third party insists on the use of side letters or refuses to put terms agreed in writing;
(l) you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
(m) a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or
(n) you are offered an unusually generous gift or offered lavish hospitality by a third party.

 

Examples:

Offering a bribe
You offer a potential client tickets to a major sporting event, but only if they agree to do business with us.
This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential client to accept
your offer.

 

Receiving a bribe
A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in our organisation to ensure we continue to do business with them. It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.

 

Bribing a foreign official
You arrange for the business to pay an additional “facilitation” payment to a foreign official to speed up an administrative process, such as clearing our goods through customs. The offence of bribing a foreign public official is committed as soon as the offer is made.
This is because it is made to gain a business advantage for us. We may also be found to have committed an offence.

Doveryard Data Protection Policy

 

• Interpretation
• Introduction
• Scope
• Personal data protection principles
• Lawfulness, fairness, transparency
• Consent
• Transparency (notifying Data Subjects)
• Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Security integrity and confidentiality
• Reporting a Personal Data Breach
• Transfer limitation
• Data Subject’s rights and requests
• Accountability
• Record keeping
• Training and audit
• Privacy by Design and Data Protection Impact Assessment (DPIA)
• Automated Processing (including profiling) and Automated Decision-Making
• Sharing Personal Data
• Changes to this Data Protection Policy

 

1.Interpretation

Definitions:

• Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The UK GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.
• Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.
• Company name: Doveryard Limited.
• Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.
• Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.
• Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the UK GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.
• Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings.
• Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
• Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programmes involving the Processing of Personal Data.
• Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the UK GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.
• Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).
• UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the UK GDPR.
• Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.
• Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.
• Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the UK GDPR.
• Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.
• Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
• Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.
• Related Policies: the Company’s policies, operating procedures or processes related to this Data Protection Policy and designed to protect Personal Data, are available on the Intranet.
• Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

2. Introduction

This Data Protection Policy sets out how Doveryard Limited (“we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties.

This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

This Data Protection Policy applies to all Company Personnel (“you”, “your”). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on our behalf and attend training on its requirements. This Data Protection Policy sets out what we expect from you for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Related Policies are available to help you interpret and act in accordance with this Data Protection Policy. You must also comply with all such Related Policies. Any breach of this Data Protection Policy may result in disciplinary action.

Where you have a specific responsibility in connection with Processing such as capturing Consent, reporting a Personal Data Breach, conducting a DPIA as referenced in this Data Protection Policy or otherwise then you must comply with the Related Policies.

This Data Protection Policy (together with Related Policies) is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO.

3. Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to £17.5 million or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the UK GDPR.

All departments are responsible for ensuring all Company Personnel comply with this Data Protection Policy and need to implement appropriate practices, processes, controls and training to ensure that compliance.

The DPO is responsible for overseeing this Data Protection Policy and, as applicable, developing Related Policies.  That post is held by Michael Jervis Chaston, Legal Counsel of Melton Renewable Energy UK Limited, an affiliated company providing management services to Doveryard Limited, Michael.jervischaston@eprl.co.uk .

Please contact the DPO with any questions about the operation of this Data Protection Policy or the UK GDPR or if you have any concerns that this Data Protection Policy is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

• if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company) (see paragraph 1);
• if you need to rely on Consent and/or need to capture Explicit Consent (see paragraph 6);
• if you need to draft Privacy Notices (see paragraph 7);
• if you are unsure about the retention period for the Personal Data being Processed (see paragraph 11);
• if you are unsure about what security or other measures you need to implement to protect Personal Data (see paragraph 1);
• if there has been a Personal Data Breach (paragraph 13);
• if you are unsure on what basis to transfer Personal Data outside the UK (see paragraph 14);
• if you need any assistance dealing with any rights invoked by a Data Subject (see paragraph 15);
• whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA (see paragraph 19) or plan to use Personal Data for purposes other than what it was collected for;
• if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making (see paragraph 20); or
• if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see paragraph 21).

4. Personal data protection principles

We adhere to the principles relating to Processing of Personal Data set out in the UK GDPR which require Personal Data to be:

• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency);
• collected only for specified, explicit and legitimate purposes (Purpose Limitation);
• adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation);
• accurate and where necessary kept up to date (Accuracy);
• not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);
• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);
• not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and
• made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

5. Lawfulness, fairness, transparency

Lawfulness and fairness

Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The UK GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The UK GDPR allows Processing for specific purposes, some of which are set out below:

• the Data Subject has given his or her Consent;
• the Processing is necessary for the performance of a contract with the Data Subject;
• to meet our legal compliance obligations;
• to protect the Data Subject’s vital interests; or
• to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.

You must identify and document the legal ground being relied on for each Processing activity.

6. Consent

A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the UK GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.

Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Notice to the Data Subject to capture Explicit Consent.

You will need to evidence Consent captured and keep records of all Consents in accordance with Related Policies so that the Company can demonstrate compliance with Consent requirements.

7. Transparency (notifying Data Subjects)

The UK GDPR requires Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the UK GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the UK GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the UK GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

If you are collecting Personal Data from Data Subjects, directly or indirectly, then you must provide Data Subjects with a Privacy Notice in accordance with our Related Policies.

8. Purpose limitation

Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.

You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

9. Data minimisation

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

You may only Process Personal Data when performing your job duties requires it.  You cannot Process Personal Data for any reason unrelated to your job duties.

You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.

10. Accuracy

Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

11. Storage limitation

Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time. You must comply with the Company’s guidelines on Data Retention.

You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company’s applicable records retention schedules and policies. This includes requiring third parties to delete that data where applicable.

You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice.

12.Security integrity and confidentiality

Protecting Personal Data

Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Special Categories of Personal Data and Criminal Convictions Data from loss and unauthorised access, use or disclosure.

You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

• Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it;
• Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and
• Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the UK GDPR and relevant standards to protect Personal Data.

13. Reporting a Personal Data Breach

The UK GDPR requires Controllers to notify any Personal Data Breach to the Information Commissioner and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches (the DPO). You should preserve all evidence relating to the potential Personal Data Breach.

14. Transfer limitation

The UK GDPR restricts data transfers to countries outside the UK to ensure that the level of data protection afforded to individuals by the UK GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

You may only transfer Personal Data outside the UK if one of the following conditions applies:

• the UK has issued regulations confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject’s rights and freedoms;
• appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved for use in the UK, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;
• the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
• the transfer is necessary for one of the other reasons set out in the UK GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

15. Data Subject’s rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

• withdraw Consent to Processing at any time;
• receive certain information about the Controller’s Processing activities;
• request access to their Personal Data that we hold;
• prevent our use of their Personal Data for direct marketing purposes;
• ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
• restrict Processing in specific circumstances;
• challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
• request a copy of an agreement under which Personal Data is transferred outside of the UK;
• object to decisions based solely on Automated Processing, including profiling (ADM);
• prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
• be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
• make a complaint to the supervisory authority; and
• in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

You must immediately forward any Data Subject request you receive to the DPO.

16. Accountability

The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

The Company must have adequate resources and controls in place to ensure and to document UK GDPR compliance including:

• appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;
• implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;
• integrating data protection into internal documents including this Data Protection Policy, Related Policies or Privacy Notices;
• regularly training Company Personnel on the UK GDPR, this Data Protection Policy, Related Policies and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and
• regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

17. Record keeping

The UK GDPR requires us to keep full and accurate records of all our data Processing activities.

You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects’ Consents and procedures for obtaining Consents.

These records should include, at a minimum, the name and contact details of the Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a description of the security measures in place. To create the records, data maps should be created which should include the detail set out above together with appropriate data flows.

18. Training and audit

We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

You must undergo whatever data privacy related training we consider to be necessary.

You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

19. Privacy by Design and Data Protection Impact Assessment (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following:

• the state of the art;
• the cost of implementation;
• the nature, scope, context and purposes of Processing; and
• the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

Controllers must also conduct DPIAs in respect to high-risk Processing.

You should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:

• use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
• Automated Processing including profiling and ADM;
• large-scale Processing of Special Categories of Personal Data or Criminal Convictions Data; and
• large-scale, systematic monitoring of a publicly accessible area.

A DPIA must include:

• a description of the Processing, its purposes and the Controller’s legitimate interests if appropriate;
• an assessment of the necessity and proportionality of the Processing in relation to its purpose;
• an assessment of the risk to individuals; and
• the risk mitigation measures in place and demonstration of compliance.

20. Automated Processing (including profiling) and Automated Decision-Making

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

• a Data Subject has Explicitly Consented;
• the Processing is authorised by law; or
• the Processing is necessary for the performance of or entering into a contract.

If certain types of Special Categories of Personal Data or Criminal Convictions Data are being processed, then grounds (b) or (c) will not be allowed but the Special Categories of Personal Data and Criminal Convictions Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject’s rights and freedoms and legitimate interests.

We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.

A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.

21. Sharing Personal Data

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.

You may only share the Personal Data we hold with third parties, such as our service providers, if:

• they have a need to know the information for the purposes of providing the contracted services;
• sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;
• the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
• the transfer complies with any applicable cross-border transfer restrictions; and
• a fully executed written contract that contains UK GDPR-approved third party clauses has been obtained.

22. Changes to this Data Protection Policy

We keep this Data Protection Policy under regular review. This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Company operates.

ESG Policy for Doveryard Limited

This environmental, social and corporate governance (“ESG”) policy is set by the board of Doveryard Limited (“Doveryard”) to identify and manage ESG matters applicable to it. The activities of Doveryard are overseen by Melton Renewable Energy UK Limited (“MRE”) pursuant to the terms of a management services agreement entered into between the parties (“MSA”). The policy will be implemented by the MRE management team and will be reviewed annually.

 

Purpose

The purpose of this policy is to ensure that ESG considerations are integrated within the management
and operations of Doveryard. Further, the policy aims to identify opportunities to improve the performance of the Doveryard as measured against ESG criteria and mitigate any associated risks.

 

Objectives

Doveryard will incorporate the following principles (the “Principles”) into its operational decision-making process:

• Consider material ESG issues to mitigate potential risks and enhance value for Doveryard.
• Monitor any ESG issues that are considered material to the operations and performance of
  Doveryard using specific ESG metrics.
• Develop appropriate KPIs and other reports to provide the Doveryard board with oversight of its ESG performance.

 

ESG Principles

Environmental:

• Operating in accordance with the relevant environmental regulatory requirements and
  environmental permits.
• Minimising the haulage distance of fuels.
• Monitoring the carbon footprint of our operations and aiming to reduce where possible.
• Monitoring the energy efficiency of our operations and making improvements where possible.

 

Social:

• We will provide safe and healthy working conditions for all, promoting diversity and inclusion and ensuring its staff and contractors are treated fairly, irrespective of race, gender, sexual
  orientation, nationality, disability, political or religious beliefs, and upholding high standards of business integrity in all our dealings.
• We will be honest, clear and transparent in all forms of communication with employees, counterparties, suppliers, customers, community stakeholders, regulators, lenders and
  shareholders. We aim to maintain and build on this with our employees in accordance with relevant policies to ensure effective training, development and staff management.
• We will actively seek to understand the impact of our decisions on others. For example, seek feedback and give a voice to all staff, foster strong communication and consider the impact of
  any operations on local communities, our stakeholders and the environment.
• We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
• We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards
  from all of our contractors, suppliers and other business partners, and we expect that our suppliers will hold their own suppliers to the same high standards.

 

Governance:

• It is our policy to conduct all of our business in an honest and ethical manner.
• We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and
  corruption.

 

Responsibility and Oversight

The MRE management team, in accordance with the MSA, will report to the Doveryard board, and is
responsible for implementing this policy and thereafter managing ESG issues on behalf of Doveryard.

Anti-Slavery and Human Trafficking Policy

 

1. Policy statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms,
such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we
are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and we expect that our suppliers will hold their own suppliers to the same high standards.

1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business
partners.

1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

 

2. Responsibility for the policy

2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.2 The activities of Doveryard Limited are overseen by Melton Renewable Energy UK Limited (MRE) in accordance with the terms of a management services agreement entered into between the parties (MSA). MRE’s Legal Counsel has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to MRE’s Legal Counsel.

 

3. Compliance with the policy

3.1 You must ensure that you read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 You must notify your manager as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

3.5 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.

3.6 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform MRE’s Legal Counsel immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

 

4. Communication and awareness of this policy

4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

4.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

 

5. Breaches of this policy

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2 We may terminate our relationship with suppliers, contractors, business partners and any other individuals and organisations working with us or on our behalf if they breach this policy.

Modern Slavery Act Transparency Statement 2021

Modern Slavery Act Transparency Statement 2022

Doveryard Limited

Statement issued in accordance with the Modern Slavery Act 2015 (“the Act”) in relation to the period 1 January 2022 to 30 June 2022 (“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 during the third quarter of 2022 with the Plant being operational during 2024.

Doveryard has no turnover presently. Once operational the Plant will generate 17MW of electricity whilst managing 186,500 tonnes of non-recyclable 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.

1. 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.

2. Doveryard is also party to two long-term fuel supply agreements although no services have been rendered
pursuant to these agreements during the Statement Period, and thereafter not before the Plant is ready
for performance testing and commissioning.

3. 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 

 

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 with regards to modern slavery and human trafficking, this has been raised with the relevant members of MRE’s management
team (including in particular the CEO, Legal Counsel and the project management team).
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.
• Facilitate and 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 is monitored by MRE’s senior management team through its management services agreement, specifically MRE’s CEO, Legal Counsel and its Project Management team.

 

Training

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.

 

Further steps

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 which is publicised at site.

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 30 June 2022.

E J Wilkinson
Director
Date: 6th July 2022
Board approval obtained on 5th July 2022

To read the 2021 Modern Slavery Statement, please click here.

Safety, Health and Environmental Policy Statement

 

Doveryard Limited (Doveryard) is committed to the highest possible Safety, Health and
Environmental (SHE) performance. Our aims in this respect are:

• Zero harm
• Zero non-conformances
• Zero breaches
• Effective reporting

In support of these objectives, as Client on the Oldhall Energy Recovery Project (the Project) during
the construction phase Doveryard is committed to:

• Complying with all relevant SHE legislation and all agreed voluntary obligations towards
  interested parties
• Ensuring there are arrangements in place for managing and organising the Project
• Allowing adequate time for the design, planning and construction of the Project
• Providing information to and ensuring ongoing communications with the Principal Designer
  (PD) and Principal Contractor (PC)
• Ensuring there are adequate welfare facilities on site
• Ensuring provision and continual review of a suitable Construction Phase Plan
• Ensuring the Health & Safety file is maintained and up to date
• Ensuring that our PD and PC are protecting members of the public, contractors and
  employees, by the implementation of all necessary policies, procedures and control
  measures to reduce and/or eliminate hazards and overall SHE risks
• Monitoring SHE performance through regular auditing and formal SHE meetings
• Minimising any environmental impact through reducing waste and preventing pollution
  through effective monitoring and control.

This SHE Policy Statement will be displayed at site and will be made available to the general public
and all interested parties on request. Doveryard will ensure that all persons working for or on its
behalf are kept aware of this policy, its corporate SHE targets and their associated individual
responsibilities, through an appropriate programme of training, inductions, communication,
consultation and participation in, and feedback from, local SHE forums.

Signed:           Date: 24th March 2022