Statement on Modern Slavery

Bluefield Solar Income Fund (“BSIF” or the “Company”) is an investment company focused on the acquisition and long-term management of a diversified portfolio of low carbon assets in the UK, with the objective of delivering long-term stable dividends. The Company primarily targets utility scale solar assets and portfolios on greenfield, industrial and/or commercial sites. In addition, the Company has the ability to invest a minority of its capital into onshore wind, hydro and storage technologies.

The Company recognises the importance of sound corporate governance and is committed to acting ethically and with integrity in its business relationships. The Company also acknowledges its responsibility to manage ESG risks and impacts transparently, proactively, and in alignment with evolving standards.

This statement relates to the Company’s financial year 1st July 2024 to 30th June 2025, hereafter referred to as the “reporting period”. The Company opposes any form of human rights abuse, including modern slavery, and is actively evolving its ESG controls to help embed human rights considerations across its investments and supply chain. This supports the Company in implementing effective systems and due diligence processes to help mitigate human rights risk within its direct business operations and, as far as possible, its supply chains.

During the reporting period, the Company has continued to adhere to the AIC Code of corporate governance and works closely with its Investment Adviser, Bluefield Partners LLP, and other industry specialists to achieve high standards of conduct. This statement outlines the Company’s commitment to upholding the UK Modern Slavery Act and sets out the measures taken to prevent modern slavery in its direct operations and its supply chains during the reporting period.

2.1 Organisational Structure

The Company is a Guernsey domiciled company which benefits from a highly experienced, fully independent board of directors. The Company has an annual turnover in excess of £170 million and an asset portfolio of 882.9 MegaWatts (MW) as of 30 June 2025.

The Company holds and manages its investments through a UK limited company, Bluefield Renewables 1 Limited, in which it is the sole shareholder. Bluefield Renewables 1 Limited owns several portfolio sub-holding companies, which in turn own Special Purpose Vehicles (SPVs), through which the portfolio investments (i.e., renewable energy assets) are held.

In addition to its wholly owned portfolio, the Company has established a long-term strategic partnership with GLIL Infrastructure through the creation of a jointly owned entity, Lyceum Solar. Although the Company maintains a minority position in this investment, it remains a shareholder with a long-term perspective.

As an investment fund, the Company has no employees, and delegates day-to-day management of its portfolio to its Investment Adviser and other key service providers.

2.2 Supply Chains

The Company recognises that human rights risks, including modern slavery, can manifest across virtually all sectors, regions, and tiers of supply chains. Operating in a sector with complex and globalised supply chains, the Company also recognises that while transparency is improving, full visibility of human rights risks remains a work in progress.

The Company engages a range of suppliers, both directly (i.e., through direct engagement with its SPVs) and indirectly (i.e., through its third-party service providers, including its Investment Adviser, and its Engineering, Procurement & Construction (EPC), asset management and Operation & Maintenance (O&M) contractors, who procure goods and services on the Company’s behalf). Table 1 presents some of the Company’s most notable supplier types engaged during the reporting period.

Table 1: Examples of the Company’s notable suppliers

^{1 Bluefield service providers refer to Bluefield Partners LLP, Bluefield Renewable Developments Limited, Bluefield Construction Management, Bluefield Services Limited and Bluefield Operations Limited.}

The Company’s suppliers are identified each year by consolidating information from the Company’s underlying accounts, which capture all expenses associated with suppliers engaged by SPVs and other entities within the Company’s organisational structure. In relation to suppliers engaged on behalf of the Company by its key service providers, these are identified through the following processes:

• Bluefield service providers identify their suppliers annually by consolidating information from each businesses underlying accounts. Such information enables the identification of suppliers engaged by Bluefield on the Company’s behalf; and
• Engagement with EPC contractors by the Investment Adviser to identify the manufacturers of key equipment (solar PV, BESS, transformers, inverters, and mounting structure) procured as part of construction activities.

For PV and BESS manufacturers, who are associated with higher modern slavery and human rights risk, additional supply chain information is requested as part of procurement processes. During the reporting period, EPC contractors procured PV and BESS equipment for the Company’s construction pipeline. In addition to manufacturer due diligence (see Section 5: Due Diligence Processes), PV and BESS manufacturers were required to provide supply chain information down to raw materials sourcing. This included identifying sourcing regions for key raw materials and upstream factory locations for their processing. This due diligence was used to guide purchasing decisions, enabling the business to minimise the likelihood of sourcing from areas with the highest forced labour risk and therefore reduce the risk of modern slavery in its supply chains.

While supply chain transparency for solar PV and BESS has remained a key focus, during the reporting period, the Company also commissioned an assessment of the supply chains for inverters and transformers, critical equipment also deployed in solar PV and BESS installations. The assessment included identifying key materials and sourcing regions, to support the Company’s understanding of these equipment supply chains. The results of this assessment will be used to inform the Company’s approach to due diligence in relation to these components in the future.

Consistent with the updated 2025 UK Government Guidance on Transparency in Supply Chains, the Company acknowledges that while it is continuing to develop and improve its due diligence processes, there are areas of its supply chains, particularly in the tiers beyond its direct suppliers, where further work is required to increase transparency, which will better enable it to identify and address potential modern slavery risks.

3.1 Governance

The Board of the Company has ultimate responsibility and oversight of ESG risks and opportunities, including those relating to human rights and modern slavery. ESG risks are integrated within the Company’s risk management processes. Daily management of ESG is outsourced to the Investment Adviser, with the Board regularly updated on ESG activity through investment committee papers, Board meetings, ad hoc calls, and written updates. Please refer to the Company’s ESG governance structure, within its 2025 Annual Report, for further information.

The Company’s focus on human rights is reflected within its ESG strategy, which has been refreshed during the reporting period following a reassessment of the Company’s material ESG risks, opportunities and impacts. Risks relating to the Company’s supply chain, particularly human rights risks presented by suppliers, were identified as material. The results of the assessment were used to update the Company’s ESG framework, with accompanying targets and KPIs currently under review. For its 2025 Annual Report, the Company has reported against its commitments and KPI’s from the previous reporting period, including those relating to human rights. Refer to the ESG report, within the 2025 Annual Report, for further information.

The Company updates its shareholders and wider stakeholders on its progress in relation to supply chain matters, including human rights, through its ESG report, disclosed within its Annual Report. Furthermore, the Company produces an annual Principal Adverse Impact (PAI) statement as part of its compliance with the EU Sustainable Finance Disclosure Regulation (SFDR), within which it reports against sustainability indicators focused upon social safeguards, including compliance with UN Global Compact (UNGC) principles and the OECD guidelines.

4.1 Risk Assesment

The Company invests in infrastructure assets held by SPVs that do not directly employ operational teams. As a result, the risk of modern slavery at the asset-level itself is assessed to be low. Modern slavery risk therefore arises primarily from the service providers, suppliers and contractors engaged to operate the Company’s investments on its behalf, in addition to manufacturers who provide key equipment.

Supply chain risk has been identified as a principal risk by the Board of the Company. Furthermore, following the Company’s updated materiality assessment, ‘Ethical Supply Chains’ was identified as a material topic to the Company, with particular focus given to human rights risks presented by select supplier types.

During the previous reporting period, the Company undertook a high-level assessment of human rights risk, including in relation to forced labour, for key stakeholder groups, including EPC contractors, O&M contractors, communities and broader supply chain workers. EPC contractors were identified as a high-risk stakeholder group. To build upon this, during the current reporting period, the Company commissioned an in-depth review to assess how human rights risks are considered and may present in EPC contractors. Research on inherent human rights risks within the EPC sector was undertaken, alongside a gap analysis of current management practices, and a review of selected EPC’s human rights management systems, policies and procedures. A set of targeted recommendations were developed to inform engagement activities and risk reduction strategies for the Company in the future.

The Company recognises the human rights risks presented by key manufacturing supply chains. Procurement of solar PV panels presents heightened risk, as identified by public reports which suggest that a significant proportion of the current global polysilicon supply chain, a key material in solar PV panels, is sourced from regions with forced labour issues. Similar issues of forced labour have been linked to the sourcing regions of some raw materials used in BESS systems. As a result, the Company undertakes heightened due diligence on these manufacturers (Section 5: Due Diligence Processes) and requests additional supply chain information, including identifying key raw materials sourcing regions, relating to any equipment procured from them (Section 2.2: Supply Chains). This is in addition to including policy adherence and clauses specifically relating to forced labour (Section 4.2: Risk Management) within relevant EPC arrangements.

To support the identification of human rights and modern slavery risks in other equipment supply chains, during the reporting period, the Company commissioned a review into inverter and transformer supply chains, to assess the social and environmental risks and impacts of this equipment. This review builds on previous assessments undertaken in relation to BESS and solar PV equipment and will inform whether strengthened due diligence and management measures need to be applied to manufacturers of these products.

4.2 Risk Management

The Company is committed to building robust management and due diligence processes, aligned with global frameworks and recognised industry standards, and recognises that addressing modern slavery risks will require long-term commitment to develop and effectively implement these processes.

As stated above, the Company’s Supplier Code of Conduct sets out the Company’s principles, rules of engagement, and what is expected from suppliers in terms of responsible business conduct and preventing child labour and modern slavery. It is the Company’s intention that its suppliers will acknowledge and adhere to the Company’s Supplier Code of Conduct, and work with the Company to identify risks, areas of improvement, and follow up agreed actions. Adherence to the Company’s Supplier Code of Conduct is a contractual requirement for key suppliers.

The adoption of wider ESG policies, including in relation to Human Rights and Sustainable Procurement, strengthen the Company’s requirements for its suppliers and contractors. Through adoption of policies, and the cascade of the requirements within them, the Company aims to support and benefit from ethical supply chains over the long-term. Specific contractual protections relating to compliance with anti-slavery and human trafficking laws and policies are also embedded within key legal agreements, including EPC and O&M agreements.

Matters relating to human rights and supply chain are managed as part of the Company’s overarching ESG framework. Activities to advance the Company’s approach to human rights, such as the EPC risk review previously described, are considered as part of the annual review of the Company’s ESG commitments and KPIs. This supports the Company in improving its human rights risk identification and management processes over time.

The Investment Adviser supports the UK solar energy industry’s response to the concerns of forced labour, which condemns and opposes any abuse of human rights, including forced labour, anywhere in the global supply chain. The UK solar industry’s supply chain statement, to which the Investment Adviser is a signatory, can be viewed here. The Investment Adviser will continue to remain abreast of the industry response to ESG topics, such as human and labour rights issues, and look to integrate recommendations from these to further develop its own approach to managing these risks.

5.1 Investment Process

The Company understands its responsibility to avoid causing or contributing to adverse human rights impacts as part of its operations and, as far as possible, its supply chains. ESG considerations, including in relation to human rights and modern slavery, continue to be integrated into the Company’s investment processes.

Pre-investment, human rights due diligence is applied during the acquisition process for operational assets, concentrated upon the working practices of contractors connected to assets under consideration. This includes the existing O&M contractor’s ability to uphold commonly accepted labour standards in the workplace, including compliance with labour laws, internationally accepted norms and standards, as well as the presence of formal grievance mechanisms. Legal checks are also undertaken on key counterparties to ensure that they are reputable, including anti-money laundering, anti-bribery and anti-corruption, and sanctions checks.

5.2 Supplier Engagement

As described in Section 4: Risk Assessment and Management, the identified scope and scale of human rights risks presented by solar PV and BESS equipment manufacturers and EPC contractors necessitates heightened due diligence measures. Measures taken during the reporting period include:

• Refreshed due diligence questionnaires relating to EPC’s and key equipment manufacturers, to better align with industry initiatives and international frameworks such as the UN Global Compact and OECD Guidelines.
• Review of the EPCs policies, including policies that pertain to or contain reference to human rights, including modern slavery.
• External ESG due diligence undertaken on an EPC contractor and certain manufacturers, to supplement findings from internal reviews.
• Enhanced contractual protections and requirements drafted for inclusion within EPC contracts, relating to various aspects of responsible business practice including human rights aspects.
• Supply chain traceability information requested from solar PV and BESS equipment manufacturers as part of EPC engagements.
• Social audits requested for solar PV panel manufacturing facilities as part of EPC engagements.

Also during the reporting period, the Company engaged an external consultant to undertake an ESG assessment on an inverter manufacturer, which included consideration of human rights and modern slavery risks.
Should the Company discover that a supplier is directly or indirectly contributing towards modern slavery, then the Investment Adviser would engage with the supplier to encourage the removal of such practices. Should the issue persist, the Company would seek to terminate the relationship with that supplier.

To expand the breadth of the Company’s due diligence processes, both in relation to human rights and more broadly, a supplier vetting platform was implemented by the Investment Adviser during the reporting period. Whilst supplier onboarding is still in progress, the system will standardise and broaden due diligence across a variety of topics, covering both the Company’s direct suppliers and those of its Bluefield service providers.

Training requirements relating to both the Board of the Company and the Company’s Bluefield service providers will be reviewed over the coming year to support adequate oversight, monitoring and management of modern slavery risks.

The Company agrees with the UK Government expectation that organisations should seek to continuously improve their response to modern slavery risks. As detailed within this statement, the Company has evolved the measures taken, when compared to the previous reporting period, to mitigate the risk of modern slavery in its direct operations and supply chains. Nevertheless, given the nature and complexity of the Company’s supply chains, it is not possible to definitively state its absence at present.

Therefore, the Company will continue to monitor the effectiveness of its human rights due diligence approach to identify, mitigate, and where possible, prevent human rights issues in its supply chain, including in relation to potential modern slavery.