Introduction
This statement is made on behalf of Grey Energy LLC pursuant to The United States End Modern Slavery Initiative Act of 2015, section 54 of the UK Modern Slavery Act 2015, European Union Modern Slavery Act 2015, Australia Modern Slavery Act 2018, California Transparency In Supply Chains Act 2010 and constitutes our slavery and human trafficking statement for the 2023 year.
At Grey Energy LLC, we are committed to the highest ethical and professional standards and value transparency and accountability in everything that we do. We support the objective of eradicating modern slavery and human trafficking in all its forms and are committed to ensuring that human rights abuses, however, they may arise, are recognized and eradicated in our business and any supply chains in which we participate.
Our Structure
Grey Energy LLC is an organization of separate legal practices and entities comprising partnership and corporate form, each established to provide solutions under the Grey Energy LLC name from the various locations in which it is based.
This jurisdiction does not have a poor record of modern slavery and human trafficking. As part of our HR policies and procedures, we only use reputable firms and/or third-party vendors and comply with all relevant local laws and regulations. We regularly review our global procedures and providers, as well as our arrangements for employee welfare and care.
Our Supply Chain
As a global investor, we do not have intricate supply chains and we operate in an environment where the risk of encountering modern slavery is low. Our business is a sophisticated structure that does not involve and is not built upon the type of low-skilled labor often associated with such practices. Nevertheless, we do expect our suppliers and outsourced contractors and/or third-party vendor organizations, together with their supply chains, to take all reasonable and practical steps to comply with The United States End Modern Slavery Initiative Act of 2015, section 54 of the UK Modern Slavery Act 2015, European Union Modern Slavery Act 2015, Australia Modern Slavery Act 2018, California Transparency In Supply Chains Act 2010 and/or any other modern-day slavery acts around the world.
Our Policies
Our team members are qualified professionals who are subject to a comprehensive and enforceable set of ethical rules. As a global group, we comply with all relevant laws and regulations in the respective jurisdictions we operate in. Accordingly, we have policies to prevent money laundering, bribery, and corruption and to counter the financing of terrorism. Furthermore, we conduct due diligence checks prior to taking on new projects and/or ventures to assess the extent to which the potential client exposes Grey Energy LLC to a range of risks. In this regard, we provide all of our staff with relevant training on our policies and procedures.
We have developed a Business Code of Conduct that applies to our third-party providers of goods and services and sets out the standards we expect them to observe, including in respect of modern slavery risks. We request that all our significant suppliers implement the Code and impose the principles on their respective suppliers. The Code can be found here.
We continue to review and develop our supply chain due diligence and risk assessment across our global structure to ensure a robust and consistent approach to supply chain risks. We continue to make all efforts to identify any significant risks in our business and supply chain and implement any actions appropriate or necessary directly with suppliers.
This document has approved and reissued the foregoing statement and has instructed that it be posted on the Grey Energy LLC website.
July 17, 2023