Procurement Policy

Commitment

Enerveo is committed to operating ethically, sustainably and within the law in its procurement of all goods, work and services from its external sources.

Objectives

Sustainable Supply Chain

To expect our sub-contractors and supply chain to meet with our principles, complying with, as a minimum, local laws and regulations, ensuring fair payment and treatment of our Supply Chains’ workforce, respecting internationally recognised human and labour rights, and valuing fairness and respect;
To maintain our Sustainability Agenda designed to meet the requirements of legislation and best practice as well as supporting Client agendas, and centred around three key areas: Economic, Social and Environmental; and
To have zero tolerance of modern slavery in all forms within its own business and supply chain. This includes the use of forced labour, servitude, slavery, human trafficking, debt bondage, forced or servile marriage, descent-based slavery or child labour. The right to freedom of association and collective bargaining must be respected.

Procurement Authority Levels

To set authority to approve the approach to procurement and the placement of contracts with third parties.

Information Security and Data Protection

To consider Information Security and Data Protection risks within its Procurement processes. Suppliers must protect confidential information and personal data belonging to or vested in Enerveo in accordance with all relevant laws, and act to prevent its misuse, theft, fraud, damage or improper disclosure.

People

To employ and maintain a professional Procurement team with the knowledge, skills and experience to carry out their duties efficiently and engage with its strategic supply chain partners, ensuring long term relationships which create value for the business, our clients and interested parties are established and maintained; and
To be committed to the principles outlined within the Prompt Payment Code and to the fair treatment of all suppliers, adopting an approach of providing suppliers with quick resolution of invoices and ensuring any queries or issues are managed effectively.

Counterfeit, Fraudulent and Suspect Items

To be very aware of the risks associated with the potential supply of Counterfeit, Fraudulent and Suspect Items (CFSI) within our supply chain; and
To mitigate risk, engaging with suppliers who have a demonstrable capability to guarantee the quality and appropriate sourcing of the goods, materials and services we require.

Safety, Health, Environment (SHE)

To remain committed to maintaining a safe and healthy working environment where everyone is valued, treated with respect and consulted on SHE issues, encouraging and promoting the participation, commitment and involvement in SHE activities of all interested parties including our Supply Chain.
To fulfil legal requirements and achieve effective risk control, create an open style relationship with our Supply Chain, with no punitive action taken against anyone who raises SHE concerns through the appropriate channels.

Corporate Social Responsibility

Through continuous improvement and innovation, we remain committed to reducing waste, material, energy, water usage and CO2 through the local selection of our suppliers, ethical sourcing of materials, and improving the positive impact of our actions on the communities in which we work.

This will be achieved by:

Governance

Incidents and breaches being reviewed and where appropriate opportunities for improvement actioned;
Confirming potential suppliers’ eligibility, prior to joining our approved supply chain, through a detailed Pre-Qualification Questionnaire (PQQ) process, confirming third-party accreditation bodies, SHE and Corporate Social Responsibility arrangements and performance, commercial viability, and management systems, are to a recognised standard; and
Procurement processes being subject to continuous surveillance and audit.

Communication and Training

Communicating this policy, its supporting framework and expectations to all employees, contingent workers, contracted Third Parties and any other interested party as applicable; and
Maintaining a professional Procurement team with the knowledge, skills and experience to carry out their duties efficiently and effectively. In order to achieve our vision of providing an industry leading Procurement service, we have in place:

- Strategic sourcing processes which are available to all Procurement and Commercial Staff; and
- An annual Procurement training needs analysis and individual development plans.

Responsibilities

This policy applies to all Enerveo employees, contingent workers and people contracted to provide services to the Company through third parties. Those concerned with the procurement of goods, materials and services for Enerveo are aware of the potential risks and will ensure that procurements are only made from properly accredited suppliers registered to our supply chain.
The Enerveo Board is responsible for the oversight of this policy including the approval of any changes.
The Director of Commercial supports the Head of Procurement to make sure that the policy is adhered to through awareness, training and monitoring of policy implementation.
Managers are responsible for making sure that their teams understand and comply with the policy and supporting procedures as well as complete any relevant training.
All employees must comply with the policy and supporting procedures and complete all relevant training. All employees are empowered to question the veracity of supply and in cases of doubt, initiate non-conformance reporting.

Scope

This policy applies to Enerveo Limited, Enerveo Ireland Limited and Enerveo Infrastructure Solutions.

Signed:

Zak Houlahan

Chief Executive Officer

Helen Wain

Procurement Director