Our vision is to be the most trusted managing agent, doing the right thing for our customers, with exceptional quality products at the heart of everything we do. This is only possible through the close relationships we have with our suppliers and sub-contractors built on a foundation of shared values and a commitment to ethical trading. Together, we have an important role and responsibility to play in identifying, preventing, mitigating and remediating human rights risks. To do so, we acknowledge that we must act in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs). Identifying and mitigating human rights risks is incredibly complex and it’s why we work in partnership with the wider industry where the risks are shared or where our influence is less direct.
INTRODUCTION FROM THE LEAD DIRECTOR OF RHEA PROJECTS
OVERVIEW
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 which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. Rhea has 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 committed to improving our practices to combat slavery and human trafficking.
We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. As we develop as a business, we will ensure we apply good practice, if we are required to report, we will have been applying the practices necessary.
Our supply chain is quite extensive in the delivery of energy efficiency measures to domestic properties in Lancashire. We will support our direct partners and work with other larger businesses to learn lessons and support our governance. Our workplace policies & procedures demonstrate our commitment to acting ethically.
OUR BUSINESS
This is Rhea's updated Modern Slavery Statement issued in accordance with the Modern Slavery Act 2015. The statement provides an update on the actions we have taken (and continue to take) as a business, during the year ending 29 March 2025, to monitor and prevent slavery and human trafficking from occurring in our own operations and supply chain. Rhea operates as a family of businesses across led by its own integrated management team, with functional accountability for their area of expertise, including delivery, supply chain and finance. We now do this using the CRM developed by Blackpool Council to enhance delivery.
GOVERNANCE
Overall accountability for the Modern Slavery Statement and risk assessment process is held by Lynne Woodburn as the lead director for Rhea. The report is also reviewed by the senior management team.
Our Code of Conduct
Sets benchmark minimum commitments for our business conduct. These commitments are focused on key policy areas affecting Rhea, to ensure we act in line with relevant laws and regulations, industry standards and stakeholder expectations. The code applies to everyone at Rhea including our Board, our management team and all our colleagues, as well as those working in any joint ventures that we control.
Our Human Rights Policy
States our commitment to respecting internationally recognised human rights in line with the principles and guidance contained in the UNGPs on Business and Human Rights.
Our Sourcing Principles
First considered in 2020 we are considered to be in line with the UNGP requirements, these principles set out our minimum requirements and expectations of how we and our supplier partners conduct business to uphold human rights, labour environmental, ethical and legal requirements in their own operations and their supply chains. These Principles were last updated in January 2024
Our Confidential Reporting Principles
Aimed principally at our colleagues, but also available to others working in our supply chain, confidential reporting channels are managed now by the CRM and concerns can be raised by phone or online.
Our Grievance Procedure
Grievance mechanism to remedy adverse human rights impacts within the energy efficiency supply chains. This policy sets out how to raise a grievance and our recommended process for investigating and understanding concerns should they occur. Our grievance policy was last updated in July 2025, and it is regularly reviewed to ensure it remains compliant with the ACAS Grievance Procedure and good practice. Whilst the review did not identify any immediate opportunities to improve our process, it did identify potential opportunities we can learn from to use the data we gather in a more effective way to help guide decision making across the business
Our Human Rights Due Diligence
To support our approach to human rights due diligence, drive continuous improvement. We have looked at developing this guidance to support our energy efficient supply chain.
RISK AND ACTIONS
Our annual modern slavery risk assessment is aligned with the Rhea business risk assessment process. This process considers external, internal, and emerging risks and how these are mitigated. This risk assessment process occurs annually and covers the relevant areas of business its in Food, Rhea's lead director is accountable for the risk assessment and due diligence approach. These risks assessments are reviewed internally with relevant incidents reported in this report if appropriate. Modern slavery can arise in complex and hidden ways, so our risk assessment includes the following to help us in prioritising actions to mitigate risk:
• detailed mapping of supply chains and operations; data from any audits
• contractor engagement • supply chain due diligence;
• discussions with expert stakeholders through multi-stakeholder initiatives
Or primary focus is on energy supply chains, where, working closely with our trusted supplier partners, we can make the greatest impact. Our salient human rights issues remain largely unchanged year-to-year but with emerging and watching issues that nevertheless have the potential to increase in risk.
The nature of the business means it is unlikely we would come across issues as most engagement is with suppliers and contractors who are Lancashire based and subject to an onboarding process.
REPORTING CHANNELS
Any notifications of potential modern slavery issues and risks that are reported to us through other channels, grievance mechanisms, whistleblowers or any other parties are thoroughly investigated and remediated where required. We work closely with our contractors enables us to be alerted to any reports of potential labour exploitation within the supply chain. This allows us to respond swiftly to any concerns.
OVERTIME
Excessive overtime can be a forced labour indicator, as defined by the International Labour Organisation (ILO). It’s therefore important that any overtime is done voluntarily, and the amount of overtime completed is within the limits set by international standards and/or national law. In times of supply chain disruption, such as the recent political unrest in several countries can result in delays that mean that when supplies are released there is a ripple of high levels of work There is additional complexity when workers want to increase their incomes through overtime. In this situation, compliance with overtime limits can be an issue. So, our approach is to verify through our compliance monitoring that all overtime is voluntary and within legal limits and ETI guidance.
TRAINING AND AWARENESS RAISING
Our colleagues and supplier partners play a major role in helping us to identify and prevent modern slavery in our supply chain.
Warning signs include
Unusual travel or working times.
Restricted freedom of movement.
Living conditions – at the place of work.
Clothing – limited changes of clothing or limited personal possessions.
Inappropriate work clothing – poor quality PPE.
Physical appearance.
Always accompanied.
Rarely interact and seem anxious.
FORWARD PRIORITIES ONGOING COMMITMENT PLANNED ACTION FOR 2025/26
Train our colleagues to raise awareness of our corporate responsibility and assess their ability to detect and mitigate modern slavery risks. Identify risks regarding recruitment practices, operations and supply chains. Identify and use opportunities for collaboration to verify and help resolve risk issues.
RESPONSE AND REMEDIATION FRAMEWORK
If you believe that you have suffered any such treatment, you should inform your line manager immediately.
As every situation is different and we do not expect to come across many, we utilise “Modern slavery response and remedy framework. This provides a workable framework to follow, outlining actions to be taken to facilitate remedy in situations where a company is involved in exploitative labour practices or modern slavery.
Step One: Investigate and verify
Step Two: Remediate harm to workers
Step Three: Mitigate and prevent future harm
Step Four: Escalation
Step Five: Incident reporting and tracking
Step Six: Review
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