John Scott, Chairman
Approved by the BSIF Board: 26 September 2023
Last Updated: 28 September 2023
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Bluefield Solar Income Fund’s slavery and human trafficking statement for the financial year ended 30 June 2023, which was approved by the Board on 26 September 2023.
2. Organisation Structure and Supply Chains
3. Policies and Governance
- Human Rights Policy: On 29 June 2023, the Board of the Company adopted a Human Rights Policy. The policy states the Company’s commitment to respecting human rights in line with frameworks such as the UN Declaration on Human Rights and the UN Guiding Principles on Business and Human Rights (UNGP).
- Supplier Code of Conduct: On 29 June 2023, the Board of the Company adopted a Supplier Code of Conduct. The Supplier Code of Conduct sets out the values and principles the Company expects its suppliers to follow as a minimum requirement, and was developed in line with global frameworks, including the UNGP, UNGC, and the OECD Guidelines. It covers topics including ethics, human and social rights, environmental, business and supply chain risk, and whistleblowing. As of the publication of this statement, the Supplier Code of Conduct has been signed by 26 priority suppliers and will be rolled out to further suppliers over the coming year.
- Sustainable Procurement Policy: On 29 June 2023, the Board of the Company adopted a Sustainable Procurement Policy. The Company’s Sustainable Procurement Policy includes principles such as assessing and managing supply chain risks; upholding human rights; and where possible reducing the environmental impacts of procurement activity.
- Whistleblowing Policy: In May 2023, the Board of the Company adopted a Whistleblowing policy, publicly available at: https://bluefieldsif.com/wp-content/uploads/sites/6/2023/07/BSIF-Whistleblowing-Policy.v2.pdf. The Company appointed Kevin O’Connor, Group General Counsel for the Investment Adviser, as Whistleblowing officer.
- Sustainable Investment Policy: The Company’s Sustainable Investment Policy was made publicly available in December 2022 (https://bluefieldsif.com/wp-content/uploads/sites/6/2023/07/BSIF-Sustainable-Investment-Policy-Final-.pdf) and was formally adopted by the Board of the Company on 29 June 2023. The Sustainable Investment Policy outlines how sustainability factors are considered and integrated within the investment process and as part of operational activities, including considerations relating to human rights and business ethics.
- ESG Policy: The Company’s ESG Policy, adopted by the Board of the Company in June 2022 (https://bluefieldsif.com/wp-content/uploads/sites/6/2023/02/BSIF-ESG-Policy-FINAL.pdf), speaks more broadly to the Company’s sustainability context and its role in delivering renewable energy as part of climate change mitigation. Within this, the Company states its wishes to “ensure that globally, the supply chains that support [its] assets are managed to help ensure that the environmental and social issues associated with the manufacture and supply of [its] key infrastructure are appropriately considered and the risks and impacts suitably mitigated”.
4. Due diligence processes
- Comprehensive ESG due diligence undertaken on key third parties, such as EPC contractors.
- Human rights considerations embedded within pre-investment due diligence processes.
- External ESG risk analysis conducted on key solar and battery manufacturers.
- Social audits requested for solar manufacturing facilities as part of EPC engagements.
- Enhanced contractual protections within key legal agreements, such as EPC and O&M contracts.
- Adoption and roll out of the Company’s Supplier Code of Conduct.
- Participation in industry supply chain initiatives