Modern Slavery Policy

1. Introduction

Activ8 Solar Energies (“Activ8”, “we”, “us”, “our”) is committed to conducting business ethically, responsibly, and with integrity. We recognise that modern slavery and human trafficking are serious crimes and fundamental violations of human rights.

This Policy applies to all operations of Activ8 Solar Energies and reflects our commitment to preventing modern slavery in our business activities and supply chains.

This Policy is reviewed annually and updated where necessary to reflect legal, operational, and supply chain developments.

2. Our Business

Activ8 Solar Energies is a trading name of Marron Activ8 Energies Limited, based in Carrickmacross, Co. Monaghan, Ireland, with operations across Ireland and Northern Ireland.

We design, supply, and install renewable energy systems, including solar PV and solar thermal solutions.

Our supply chains include both local and international manufacturers, particularly in relation to solar PV components, inverters, and associated electrical equipment.

Given the global nature of renewable energy manufacturing, we recognise that certain supply chain tiers may present higher human rights risks and require ongoing due diligence.

3. Definitions of Modern Slavery

Modern slavery encompasses a range of serious human rights abuses, including:

• Human trafficking
• Forced or compulsory labour
• Debt bondage
• Child labour
• Servitude
• Exploitation through coercion, threats, or abuse of vulnerability
• Restriction of freedom of movement or withholding of identity documents

4. Legal & Regulatory Framework

Activ8 operates in compliance with applicable human rights and employment legislation, including:

• Irish Criminal Law (Human Trafficking) Act 2008
• Irish employment and equality legislation
• UK Modern Slavery Act 2015 (where applicable to Northern Ireland and UK trading activities)
• EU Charter of Fundamental Rights
• Emerging obligations under the EU Corporate Sustainability Due Diligence Directive (CSDDD)

We also align our internal controls with internationally recognised human rights principles.

5. Our Commitment

We are committed to:

• Acting ethically and with integrity in all business dealings
• Preventing modern slavery and human trafficking in our operations and supply chains
• Treating all workers fairly, respectfully, and lawfully
• Ensuring employment is freely chosen
• Complying with all applicable labour, human rights, and health & safety laws
• Avoiding any business relationship with organisations knowingly involved in modern slavery
• Continuously improving supply chain transparency and oversight

We do not knowingly engage with any supplier, contractor, or partner involved in forced labour, servitude, or human trafficking.

6. Supply Chains

Our supply chains include:

• Solar PV module manufacturers
• Inverter and electrical component suppliers
• Installation subcontractors
• Logistics and transport providers
• Technical service providers

We recognise that certain components of the renewable energy sector rely on global manufacturing markets, where labour conditions may vary significantly by jurisdiction.

7. Risk Assessment & Exposure

We acknowledge that the highest potential exposure to modern slavery risks exists within:

• Global manufacturing supply chains (particularly solar PV components)
• Tier 2 and Tier 3 raw material production
• Outsourced manufacturing and subcontracted labour environments

We assess our overall risk exposure as moderate due to the international nature of supply chains, and we are committed to strengthening oversight and due diligence processes on an ongoing basis.

8. Due Diligence & Controls

We have implemented and continue to develop the following controls:

• Supplier onboarding assessments
• Review of supplier ethical and labour standards where proportionate
• Contractual obligations requiring compliance with applicable human rights laws
• Right to terminate supplier relationships where concerns arise
• Monitoring of supplier performance where relevant and feasible
• Engagement only with suppliers who meet acceptable ethical standards to the best of our knowledge

We are actively strengthening our supplier due diligence framework in line with evolving EU CSDDD requirements.

9. Employment Practices

We are committed to fair and lawful employment practices, including:

• Fair wages in line with legal requirements
• Safe and healthy working conditions
• Non-discrimination and equal opportunity
• Voluntary employment with freedom to leave employment
• Respect for employee dignity and rights
• Prohibition of forced, bonded, or involuntary labour

10. Reporting Concerns

We encourage employees, contractors, suppliers, and stakeholders to report any concerns relating to:

• Modern slavery
• Human trafficking
• Exploitative labour practices
• Unethical supplier conduct
• Human rights violations

All concerns will be treated seriously, investigated appropriately, and handled confidentially where possible.

No individual will suffer retaliation for reporting concerns in good faith.

11. Governance & Responsibility

Overall responsibility for this Policy lies with senior management.

Management is responsible for:

• Implementing this Policy across operations
• Reviewing supplier risk and compliance
• Ensuring appropriate escalation of concerns
• Promoting awareness of ethical sourcing standards
• Ensuring ongoing improvement of due diligence processes

12. Key Performance Indicators

We monitor and review the effectiveness of our approach through:

• Supplier onboarding and review completion rates
• Number of supplier assessments conducted
• Number of reported concerns and resolution outcomes
• Training and awareness activities
• Audit and compliance reviews where applicable

These indicators will continue to evolve as our supply chain governance framework matures.

13. Continuous Improvement

We recognise that preventing modern slavery is an ongoing responsibility.

We are committed to:

• Strengthening supply chain transparency
• Enhancing supplier auditing processes where appropriate
• Improving risk assessment methodologies
• Aligning with EU CSDDD requirements as they come into force
• Updating policies and controls in line with best practice

14. Policy Review

This Policy is reviewed at least annually and updated where necessary to reflect:

• Changes in legislation
• Changes in business operations
• Developments in supply chain risk
• Regulatory guidance and best practice

15. Contact Information

If you have any questions or concerns regarding this Policy, please contact:

Activ8 Solar Energies
NEXUS N2 Business Park
Carrickmacross
Co. Monaghan
Ireland

Email: info@activ8energies.com
Phone: +353 (0)42 969 0352
Website: https://www.activ8energies.com/contact

Policy Owner: Senior Management
Last Reviewed: May 2026