Modern Slavery Statement

Green Energy Group is committed to ensuring its business does not knowingly support any form of modern slavery and human trafficking. We are committed to promoting ethical business practices and policies that protect workers from being abused and exploited, both in our own business and across our supply chains.

Green Energy Group is committed to limiting the risk of modern slavery occurring in our business and strives to adopt a transparent approach to tackling modern slavery throughout our supply chain.

We expect our employees and our suppliers to share this commitment.

Green Energy Group comprises five distinct business that follow distinctive paths to pursue the common purpose of accelerating Australia’s journey to net zero and beyond.

• Green Energy Trading is Australia’s leading environmental certificate agent and clean energy market advocate. We work together with installers in diverse solutions in Residential Solar, Commercial Solar, Water Heating, Space Heating & Air-Conditioning, Commercial Lighting and Energy efficiency projects.
  

• National Carbon Bank of Australia is focussed on simplifying the process for NSW businesses to maximise the financial benefits of energy efficiency projects and peak demand reduction.
  

• Green Energy and Carbon Management is an engineering consultancy that assists business to implement best practice energy management, supports them in pursuing net-zero pathways.

• Green Energy Markets provides market and policy insights that empower industry leaders to make better decisions and strong commitments.

• ACXargyle is a highly innovative and flexible provider of GreenPower, Carbon Offsets, and online solutions for organisations wishing to reduce their compliance costs while improving their environmental performance.

Collectively, the group employs over 50 dedicated professionals who are united a by commitment to this common purpose and the shared values of future focus, adaptability and curiosity.

GEG companies support businesses to achieve credible and cost-effective net zero commitments by:

• assessing their carbon footprint,

• mitigating  emissions by administering certificate creation and monetisation processes for energy efficiency and renewable opportunities, and

• sourcing reputable offsets.

Green Energy Group has a relatively simple supply chain. The bulk of our business involves the supply of services to customers that install equipment that produces an environmental benefit (the avoidance of greenhouse gas emissions associated with the consumption of grid electricity). This benefit can be monetised through a range of State and Federal Government programs that involve the creation of certificates which can be sold to energy market participants who use them to discharge regulatory obligations.

We have supply relationships with several hundred businesses that provide a range of services and products that support the Group’s ongoing operations. These suppliers are predominantly Australian based and mostly fall within three categories:

• Participants in Environmental Certificate Markets

• Professional and technology services (including accounting, legal, marketing, recruitment and software development)

• Office supply (IT equipment, stationary, etc)

Our Modern Slavery Risks

Our operations

We assess that there is a very low risk of modern slavery in our directly employed workforce. The Australian labour market is highly regulated, and the Group has a strong track record of compliance. Most of our staff are employed on a permanent basis (the Group does not have a material casual labour force).

Our supply chain

A desktop assessment of the modern slavery risks from our three supplier groups concluded that the majority represent a low risk of modern slavery. A key consideration in reaching this determination was the fact that they are Australian based and hence operate within a highly regulated labour market.

The one category of supply that does warrant more detailed analysis is the Group’s relationships with other participants in Environmental Certificate Markets. Three Group Companies (Green Energy Trading, National Carbon Bank of Australia and ACX Argyle) at times participate in the primary and secondary markets for a range of tradeable environmental commodities. These commodities take the form of certificates issued under schemes created under schemes managed by:

• The Australian Government - Small-scale Technology Certificates (STCs), Large-scale Generation Certificates (LGCs), and Australian Carbon Credit Units (ACCUs)

• The New South Wales Government - Energy Saving Certificates (ESCs)

• The Victorian Government - Victorian Energy Efficiency Certificates (VEECs)

• The Gold Standard Foundation – Verified Emissions Reductions (VERs)

• Verra - Verified Carbon Units (VCUs)

Group Companies participate in these markets for three main reasons. First, to monetise certificates created on behalf of its clients. Second, to obtain certificates on behalf of customers that are meeting compliance obligations or honouring voluntary commitments. Third, to manage risks in its portfolio and ensure it can meet forward commitments to customers.

We assess the risks of modern slavery in the supply of Environmental Certificates created under schemes established by the Australian, New South Wales and Victorian Governments as low. This is because the creation process of each of these certificate types is heavily regulated, and the projects that give rise to them are all being undertaken in Australia, which has a highly regulated labour market.

Generally, we assess the scheme level risk of Environmental Certificate types not regulated by Australian Governments (VERs and VCUs) as moderate. This is because both schemes are open standards that can be applied anywhere in the world. The risk level of projects with which the Group interacts however is assessed as low, reflecting the higher technology nature and skilled workforce of our preferred solar and wind projects and the careful due diligence carried out on the projects that the certificates have been generated from. Over the reporting year, the Group purchased VERs and VCUs from less than three projects, all of which we assess as having a low risk of modern slavery.

In our upcoming reporting year, we aim to continue to revise and develop our approach to modern slavery compliance to build capacity within our business to monitor and act on modern slavery risks. This may include looking beyond our first order relationships to better understand the modern slavery risks in inputs used by our suppliers in their business.

Awareness Raising Program

The Group aims to raise awareness and strengthen our understanding of the risk of modern slavery within our business and our supply chain during the 24/25 reporting year by:

• Employees: Online Education Learning Module – we are developing an annual online education tool to provide employees information on and their role in eliminating modern slavery in our workplace and our supply chain.

• Suppliers: The Group’s standard supplier and procurement agreements will include contractual obligations to address modern slavery compliance wherever possible.

Corporate governance

Green Energy Trading Pty Ltd will continue to review our policies and procedures to ensure that we have sound governance processes in place to meet our modern slavery compliance requirements.

This statement has been adopted by the Board of Green Energy Trading on behalf of all Green Energy Group Companies, pursuant to section s14(2)(ii) of the Modern Slavery Act 2018 (Cth).