Modern Slavery Act Transparency Statement

This Modern Slavery Statement is made in accordance with section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Pretoria Energy during the financial year ending 31st December 2025 to prevent modern slavery and human trafficking in its business operations and supply chains.

Our Organisation and Supply Chains

Pretoria Energy is a UK based business and operates in the renewable energy sector, generating biomethane for energy, distributed into the national grid as gas and electricity, as well as LNG/CNG for road fuel and Bio-CO2 for the food and drink sectors. Anaerobic digestion (AD), agricultural feedstock production, gas processing, storage, logistics and related commercial services are all part of the business operation.
Operations are focused on two sites with AD plants in Cambridgeshire, directly employing more than 175 people. Additional seasonal labour needs are supplied through agency providers.

The organisation works with suppliers, contractors, service providers and business partners that may support agricultural operations, plant operation and maintenance, engineering, transport, fleet services, utilities, professional services, technology, recruitment, facilities management and other operational requirements. The majority of these providers are also UK based but some of the specialist AD engineering businesses are based elsewhere in Europe, predominantly Germany and Italy.

We recognise that modern slavery risks can arise in renewable energy, agriculture, construction, engineering, logistics and labour supply chains, particularly where services are labour-intensive, seasonal, subcontracted, reliant on temporary or agency labour, or where visibility beyond first-tier suppliers is limited.

Policies and Standards

Pretoria Energy is committed to conducting business ethically, responsibly and in compliance with applicable laws. We expect our employees, suppliers, contractors and business partners to act with integrity and to respect internationally recognised human rights and labour standards. We will continue to deliver information and training to our staff to empower them to make responsible decisions, identify potential issues and work with our suppliers to prevent modern slavery.

Our approach to preventing modern slavery may be supported by policies and procedures covering areas such as anti-slavery and human trafficking, procurement, supplier onboarding, contractor management, whistleblowing, anti-bribery and corruption, recruitment, equal opportunities, health and safety, employee conduct, site access and operational compliance.

We encourage anyone who has concerns about modern slavery, forced labour, human trafficking or unethical labour practices connected with our business or supply chains to report those concerns promptly through the appropriate internal or external reporting channels.

If a specific case of modern slavery is identified here in the UK, it should be reported immediately to the Gangmasters and Labour Abuse Authority (GLAA) on 0800 432 0804 or the police on 101. If potential victims are in immediate danger, the standard 999 emergency number should be used.

Due Diligence

We take a risk-based approach to due diligence across our operations and supply chains. This may include assessing suppliers and contractors during onboarding, reviewing contractual commitments, requesting information about labour standards, checking relevant compliance documentation, monitoring supplier performance, and taking appropriate action where concerns are identified.

Where appropriate, we seek to include contractual provisions requiring suppliers and contractors to comply with applicable laws, prohibit modern slavery and human trafficking, maintain appropriate employment and labour practices, manage subcontractors responsibly, and cascade equivalent expectations through their own supply chains.

Risk Assessment and Management

We assess modern slavery risk by considering factors such as the nature of the goods or services supplied, geographic location, sector risk, use of seasonal, temporary or agency labour, subcontracting arrangements, site-based work, transport and logistics activities, and the level of visibility we have over supplier and contractor operations.

If we identify an actual or suspected case of modern slavery, we will take appropriate steps, which may include investigation, engagement with the supplier or business partner, corrective action plans, escalation to senior management, reporting to relevant authorities where required, and support for remediation that prioritises the welfare and safety of affected individuals.

Measuring Effectiveness

We may monitor the effectiveness of our approach through measures such as supplier and contractor due diligence completion, policy reviews, training completion, reported concerns, supplier engagement outcomes, site compliance checks, audit findings, corrective actions and improvements in supply chain visibility.

We aim to improve our approach over time by reviewing our policies, strengthening supplier engagement, enhancing risk assessment processes and increasing awareness of modern slavery risks across the organisation.

Training and Awareness

We seek to promote awareness of modern slavery risks among employees and relevant stakeholders. Training and guidance may be provided to employees involved in procurement, supplier management, contractor management, recruitment, human resources, compliance, site operations, logistics and other functions where modern slavery risks may be identified or managed.

Governance and Approval

This statement has been approved by the board of directors or equivalent governing body of Pretoria Energy and is signed on behalf of the organisation. This statement covers the following subsidiary entities:

• Pretoria Energy Company (Arable) Limited
• Pretoria Energy Company (Chittering) Limited
• Pretoria Energy Company (Chittering 2) Limited
• Pretoria Energy Company (Chittering 3) Limited
• Pretoria Energy Company (Mepal) Limited
• Pretoria Energy Company (Mepal 2) Limited
• Pretoria Energy Company Holdings Limited
• Pretoria Energy Company Holdings 2 Limited
• Pretoria Energy Company (Services) Limited
• Pretoria Energy Group Limited