Modern Day Slavery Statement
Compliance with the Modern Slavery Act 2015 – 2024 Statement
This is the Modern Slavery Statement of Abu Dhabi Future Energy Company PJSC - Masdar, together with its subsidiaries, collectively “Masdar”. This statement has been prepared to outline the steps taken during the year ending 31 December 2023 to prevent modern slavery and human trafficking in our supply chain and operations in line with the Modern Slavery Act 2015 (the “Act”). Although not all Masdar group companies are subject to the Act, Masdar takes a group-wide approach to its human rights-related commitments. This statement is intended to supplement (not override) any other such statements made by entities owned by Masdar.
Masdar has a zero-tolerance approach to slavery and human trafficking and has taken, and will continue to take, the steps detailed below to prevent such activity from taking place in any part of its supply chain or business.
1. Our organizational structure and supply chain
Established in 2006 as a state-owned company in the United Arab Emirates (“UAE”), Masdar is a renewable energy developer and investor, working in partnership with businesses and governments. Active in multiple countries, Masdar is a leading developer and operator of utility-scale and community renewable energy projects, which are helping to expand energy access in emerging markets and reduce reliance on fossil fuels for electricity generation.
Masdar works with a diverse set of suppliers in the following technologies: solar photovoltaic, concentrated solar power, wind, waste-to-energy, energy storage and geothermal. We recognize the increased risk of modern slavery and human trafficking in the construction sector and some of the geographies where we operate, especially where we engage with contractors or third-party service providers. This statement sets out the measures we have taken and will continue to take, to mitigate this risk within Masdar.
2. Our ethics & compliance program, policies, and procedures
As a subsidiary of the Abu Dhabi National Energy Company, PJSC (“TAQA”), , Masdar has adopted and complies with the TAQA Group Code of Ethics and Business Conduct and compliance policies (together referred to as the “Policies”).
The Policies set out the principles and responsibilities that Masdar and its personnel (“Masdar Personnel”) are expected to abide by including (but not limited to):
acting with integrity and complying with all applicable laws and regulations where we conduct our business;
standing firmly against any form of child labor, human trafficking, and modern slavery, and supporting fundamental human rights principles, when conducting business worldwide;
preserving and enhancing diversity within Masdar;
valuing and respecting the differences of Masdar’s diverse people from around the world and their varied culture; and
speaking up and reporting any unethical, illegal, or fraudulent activity either to Masdar management or through the TAQA Group Helpline, which allows for anonymous reporting.
3. Supplier engagement
Masdar is committed to only engaging with businesses which do not employ forced labor, either directly or via their supply chain. Masdar is also committed to only doing business with entities who do not allow children to form part of their workforce, either directly or via their supply chain.
All of Masdar’s suppliers and business partners are expected to uphold the principles of the TAQA Group’s Business Partner Code of Conduct (“Business Partner Code”) and Masdar’s standards and to not engage in any form of child labor, human trafficking, and slavery. Masdar ensures that its suppliers and business partners are aware of our expectations when working for Masdar and we incorporate them into our agreements with third parties.
4. Our third-party due diligence
Masdar’s Projects Environmental, Social and Governance Team (“Masdar Projects ESG”) are involved in all projects that present significant risks; from origination and due diligence, through construction and operation. Masdar’s Supply Chain Team (“Masdar Supply Chain”) monitors suppliers throughout the selection stage and prior to starting production, including through on-site labor audits.
Masdar utilizes a third-party screening tool for additional corporate due diligence screening prior to onboarding any new suppliers. This includes advanced checks for adverse media or criminal prosecutions pertaining to the proposed supplier and its directors and owners (including previous non-compliance with the Act).
5. Ongoing monitoring
Masdar assesses its suppliers, service providers, and employees while engaging with relevant stakeholders as necessary to ensure ongoing compliance with the Business Partner Code and applicable laws and regulations. Emphasizing both continued improvement and ethical behavior, Masdar reserves the right to terminate any relationship with any supplier that violates the Business Partner Code, as part of its commitment to fostering a culture of integrity throughout its supply chain and business operations.
In this respect, Masdar’s service providers are monitored by Masdar’s lenders’ environmental and/or social agents or Masdar Projects ESG and Masdar’s project teams, while Masdar Supply Chain monitors its vendors including during production, through audits, and the verification of the validity of bills of materials through on-site inspections.
6. Our key risks assessments
This year we identified the following areas of our supply chain as carrying potential forced and child labor risks: our suppliers in the manufacturing sector and the construction phase of our projects.
To mitigate these risks, we are engaging with our suppliers and contractors to ensure that appropriate safeguards and reporting mechanisms are in place to take immediate action against any violations of our standards.
For instance, our contracts strictly prohibit practices related to forced labor, child labor, and modern slavery, in line with the International Labor Organization's requirements. We also mandate compliance with globally recognized environmental and social standards. These contractual obligations are an integral part of our supplier selection process.
To ensure our suppliers' compliance with these terms, taking a risk-based approach, we engage in inspections before and during the production process, where appropriate.
This approach helps us to mitigate risks in our supply chain, maintain ethical business practices, and adhere to legal requirements in all of our operational regions. We continuously strive to improve and strengthen our risk management strategies in order to ensure sustainable business growth.
7. Training
Annual training is provided to all Masdar Personnel (including Masdar Supply Chain) in relation to its Ethics & Compliance Policies. Modern slavery assessments are an important part of Masdar’s tender process and Masdar Supply Chain are responsible for carrying these out.
8. Key performance indicators (KPIs)
Protection of human rights is a key area of focus for Masdar’s management. The development of a Health, Safety, Social and Environmental Management System is one of Masdar Projects ESG KPIs.
9. Questions
Any requests for further information or questions in connection with this statement should be directed to Masdar’s General Counsel at legalunit@masdar.ae.
This statement was approved on 2 July 2024 by the Board of Directors of Abu Dhabi Future Energy Company PJSC on behalf of the company and its subsidiaries. It was signed on behalf of the Board by Masdar Chairman HE Dr Sultan Al Jaber.
