Modern Slavery Act

Drax Group plc Modern Slavery Statement 2019 2 Modern Slavery Statement 2019 Modern Slavery Statement 2019 3

Organisational structure

Drax operates an integrated value chain across three core areas of activity in the US and the UK:

• production

• Power generation and system support services

• Business to Business (B2B) and management solutions

Safety, sustainability and operational excellence underpin all our activities.

Our UK and US biomass production assets include: Introduction Asset Description Daldowie Fuel Daldowie Fuel Plant processes sludge from a wastewater “We believe in doing the right thing” Plant, UK treatment plant and converts it into dry, low-odour fuel pellets. Daldowie can convert 1,000 tonnes of sludge into 23.5 tonnes In this, our fourth Modern Slavery Statement, we of biomass pellets for use as a sustainable fuel source. This outline the progress we’ve made in 2019 and our safely disposes large volumes of sludge that might otherwise planned improvements for 2020. end up in landfill.

We’re making this Statement for the financial Drax Biomass, US Drax Biomass International manufactures compressed wood year ending December 2019 and according to the pellets produced from sustainably managed working forests (in requirements of section 54 part 6 of the Modern Louisiana, Mississippi and Arkansas) that supply fuel to Drax Slavery Act 2015. .

This Statement applies to all companies within the Drax Headquartered in Monroe, Louisiana, the company owns Group (“Drax”) that are required to publish a Statement, and operates three wood pellet manufacturing plants: Amite as listed in the ‘statement approval’ section. BioEnergy in Gloster, Mississippi; Morehouse BioEnergy near Bastrop, Louisiana; and LaSalle BioEnergy, near Urania, Louisiana.

For further information on Drax and A port facility in Baton Rouge, Louisiana manages the shipping our earlier Modern Slavery Statements, of the compressed wood pellets. please see our websites:

Drax Group Haven Power Drax Biomass Visit Cruachan 4 Modern Slavery Statement 2019 Modern Slavery Statement 2019 5

Our UK power generation assets include: Our modern slavery programme Asset Description Drax Power Station is the biggest renewable generator in the UK. It supplies 11% of the UK’s renewable power and generates enough power to keep the lights on in more than 6 million homes. Cruachan Power Cruachan Power Station is one of only four pumped hydro Station storage stations in the UK and has a capacity of 440 MW – enough to power more than 90,000 homes. Hydro-electric Lanark consists of two stations – at Bonnington Governance power stations and at Stonebyres – and has a total capacity of 17 MW. Galloway comprises six power stations (Drumjohn, Kendoon, Carsfad, Speak up Risk Earlstoun, Glenlee and Tongland), eight dams and a series of culture assessment tunnels, aqueducts and pipelines that help to control the flow of the water - and has a total capacity of 109 MW. Combined cycle Drax has four CCGTs - Damhead Creek (805 MW), Rye House gas turbines (715 MW), Shoreham (420 MW) and Blackburn Mill (60 MW). (“CCGTs”) Training Due diligence

Our UK energy supply businesses include:

Asset Description Supplier Policies and Haven Power Haven Power supplies and manages for large contracts procedures industrial and commercial customers, as well as smaller businesses. Haven Power supplies renewable electricity as Employment standard, and at no extra cost to customers. practices Opus Energy Opus Energy supplies electricity and gas to businesses and has partnerships with over 2,000 independent UK generators. This provides a market for power from renewable energy sources such as wind, solar, hydro and anaerobic digestion. 6 Modern Slavery Statement 2019 Modern Slavery Statement 2019 7

“The MSWG developed a 3-year rolling continual improvement programme, with an accountable lead assigned to each workstream.”

Governance

Our Modern Slavery Working Group (MSWG) is Progress in 2019: In 2020, we plan to: responsible for the development and delivery of our modern slavery programme. • The company restructured the MSWG • Strengthen the EBCC agreed protocol to ensure inclusion of representatives by adding a detailed remediation plan Our Ethics and Business Conduct Committee (EBCC), a from across our business (i.e. sub-committee of our Executive Committee, oversees Sustainable Business; Business Ethics; • Assess the effectiveness of our modern our modern slavery programme. Procurement; Fuel Procurement; HR; slavery training through employee focus Biomass Sustainability Compliance; and groups The MSWG provides a quarterly report on its activity to Freight and Logistics) and to improve EBCC for review. the effectiveness and timeliness of delivering actions The EBCC provides an annual report on its decisions and activity to the company’s Audit Committee, which • The MSWG developed a 3-year rolling comprises executive and non-executive directors. continual improvement programme, with an accountable lead assigned to The EBCC: each workstream, to drive action and provide progress updates at each bi- • Has approved a protocol, based on guidance from monthly meeting the Home Office, that we must follow if we discover modern slavery in our business or supply chain • Our modern slavery programme was subject to internal audit and achieved a • Is responsible for making sure that Drax takes steps to positive outcome investigate and remediate the risk of modern slavery, both within our own business and our supply chain

No cases of modern slavery have been escalated to the EBCC to date. We continue to work with our employees and suppliers to raise awareness and promote transparency in our supply chains. 8 Modern Slavery Statement 2019 Modern Slavery Statement 2019 9

Non-fuel supply: Progress in 2019:

The following graphic provides statistics • Completed our annual risk assessment, Risk Assessment on our 2019 non-fuel procurement activity, in line with Home Office guidance, and by percentage of spend and geography, on reported on it to the EBCC our tier 1 supply. 100% of our spend is with “We’re committed to identifying 2019 fuel procurement by tier 1 suppliers based in countries that are • Updated our Group-wide modern slavery country: lower risk for modern slavery. risk register, which was subject – like the and addressing modern slavery that risk assessment – to review by the EBCC Biomass procurement Top 10 tier 1 countries of could be connected to both our by country 2019 origin based on spend • Issued the modern slavery survey to * Provisional data used % of 2019 non-fuel supply business and supply chain.” for Dec 2019 and may be appropriate third parties and assessed spend by country subject to minor changes responses, following up as required Due to the controls and practices we’ve adopted (as described in the ‘employment practices’ section), we 65% 91.43% • Commenced a project to map our higher believe the risk of modern slavery in our own business United States UK risk non-fuel supply chains, including is very low. 4.6 million tonnes our smart meter manufacturing supply 4.58% chains Because our supply chain is varied and complex, the 16% 2% Switzerland risk of modern slavery is higher. • Progressed the consolidation of our Canada Estonia 1.1 million tonnes 0.1 million tonnes approved supplier list across our power We have over 2,500 suppliers across our procurement 1.12% 0.18% generation assets activities. We engage with them in many different USA France industries, including forestry, mining, manufacturing, 9% 2% In 2020, we plan to: freight and logistics, engineering, , IT and Latvia Brazil 1.19% 0.16% 0.6 million tonnes 0.1 million tonnes site services. Germany Netherlands • Progress the non-fuel supply chain mapping project, including the selection The Global Slavery Index, which is built into our 2% 1% 0.55% 0.11% and adoption of a new tool to assist the due diligence platform, continues to contribute to Portugal Belarus Czech Republic Norway mapping process, as necessary the risk assessment of relevant potential suppliers. 0.2 million tonnes <0.1 million tonnes If the assessment of an organisation regarding 0.23% 0.08% • Reflect any updates to the Global Slavery modern slavery is medium or higher risk, we issue a 2% 1% Ireland Australia Index in our due diligence platform, as supplementary survey for completion. The survey Russia Other European required 0.2 million tonnes <0.1 million tonnes includes questions on underage workers, employee We have good transparency of our fuel rights and freedoms, use of foreign and migrant procurement by country 2019 supply chains. It’s more challenging workers, due diligence processes, policies and (Data refers to coal purchased and delivered to map the supply chain for non-fuel procedures. to UK ports in 2019) suppliers and their sub-contractors (e.g. those involved in the production From a modern slavery perspective, we currently 42% of smart meters or replacement parts consider our supply chains involving Belarus, Russia, Russia for our generating assets). In 2019, our Ukraine, India (sub tier 1) and China (sub tier 1) to be 236,330 tonnes Procurement team commenced a project higher risk. 28% to map these supply chains. Supply chain mapping UK In the meantime, our policy is to carry 159,492 tonnes out due diligence on all suppliers prior The following graphics provide statistics on our 2019 to contracting. We also endeavour to fuel supply procurement activity. Of those countries 22% include obligations within our agreements listed, we consider Belarus, Russia and Ukraine higher 8% USA USA / UK blend with suppliers for them to cascade our risk for modern slavery and carry out additional due 121,298 tonnes 45,266 tonnes standards to sub-contractors. diligence on these supply chains. 10 Modern Slavery Statement 2019 Modern Slavery Statement 2019 11

Supplier approval Progress in 2019:

Following country approval, potential • Improved our third-party due diligence suppliers residing in those jurisdictions process by building a request form can be put forward for due diligence. into Drax’s self-service portal, to help employees trigger and then track We carry out due diligence checks on the completion of due diligence. suppliers and, where appropriate, their Various internal communications and associated persons and supply chain. our mandatory learning programme Should we identify concerns during the supported the deployment of the process, we may procure enhanced due functionality Due Diligence diligence from a specialist service provider before escalation to the EBCC. The EBCC • Strengthened the modern slavery survey will decide whether to appoint the supplier. hosted within our due diligence platform “We’re committed to conducting As reported in our 2018 statement, we • Agreed with the EBCC a due diligence implemented a new due diligence platform approach relating to trial volumes of business with honesty and integrity, which all our business units use, both in the potential new fuels UK and the US. and in accordance with applicable • Completed audits – including human laws and regulations.” We use the platform to perform both the rights content – on two sunflower mills initial due diligence and the continuous in Russia Country approval monitoring of suppliers. Designated employees at the local business units • Identified the manufacture of our Our due diligence system automatically calculates the review the monitoring alerts and, if smart meters as a potential risk area geographic risk assessment of potential third parties, appropriate, escalate to the Group Business and reviewed an independent audit based on several system-hosted indices. In relation to Ethics team. report conducted at the manufacturing modern slavery, these include the Global Slavery Index. facilities in China in 2019. Though this Biomass supplier audits audit focused on production and quality The EBCC must approve conducting business in management processes, it provided higher risk countries before it happens. The EBCC can To supplement our existing due diligence evidence of safe working conditions. consider blanket country approvals or specific contract procedures for low volume, non-woody We intend to include further monitoring approvals, depending on the consolidated commercial biomass, we engaged a third-party audit in the non-fuel supply chain mapping interest in the underlying country and the level of company in 2019 to complete two audits. project. identified risk associated with the territory. The audit scope includes human rights and covers the risks identified at a regional In 2020, we plan to: level. Suppliers seeking approval and appointment need to address all findings. • Evaluate the appropriateness of our approach to trial fuel volumes, including Modern slavery instances benchmarking with another UN Global Compact Modern Slavery Working Group In 2019, our due diligence processes member identified no instances of modern slavery. • Strengthen the human rights content of our third-party fuel supplier audits 12 Modern Slavery Statement 2019 Modern Slavery Statement 2019 13

Progress in 2019: In 2020, we plan to:

• Drafted Employee and Supplier Codes of • Seek Board approval for the new Conduct Employee Code of Conduct

– Noting that the Employee Code of • Publish the Employee Code of Conduct Conduct will incorporate the current “Doing the right thing” handbook • Separate the content of our Corporate Crime policy into its constituent parts – Engaged a third-party to work with us (such as a Human Rights policy, in Policies and to create interactive versions of the relation to Modern Slavery) Codes

Procedures – Embedded eLearning will also feature in the Codes, helping us to reach out to more suppliers on the topic of modern “We expect our people to work in slavery accordance with our business values • Updated our Corporate Crime policy and principles. Our HR policies and (including modern slavery content)

procedures ensure our people have – The revised document was subject the appropriate rights to work and to external legal review and Board approval are employed in accordance with – The policy was rolled out as a applicable legislation.” mandatory read to all employees, We provide online access to our “Doing the right thing” temporary workers and relevant handbook. This mandatory, principles-based handbook consultants via our Learning forms part of our business ethics documentation Management System (c. 3,000 people) framework and sets out our values and the behaviours • Integrated our new generating assets we expect from our people. The handbook is into our Business Ethics programmes supplemented by policies, procedures and guidance and documentation framework that provide further information on the obligations applicable to Drax and how we will comply with them. All our written materials are readily available to employees via our Group Business Ethics SharePoint.

We have a Corporate Crime policy in place that provides specific detail in respect of modern slavery, in addition to our Due Diligence guide.

Should an employee fail to meet the standards expected by the business, we’ll fully investigate the matter in line with the relevant terms of employment and disciplinary procedures. If necessary, we’ll take disciplinary action. 14 Modern Slavery Statement 2019 Modern Slavery Statement 2019 15

Drax is committed to maintaining high We respect our employees’ rights in standards in its employment practices and areas such as freedom of association to giving colleagues employment security. and collective bargaining. Overall, 24% A high proportion of our employees are on of the workforce across Drax is covered permanent contracts. by a collective bargaining agreement. For the rest of the workforce, employee Although the risk of modern slavery forums are in place, enabling a two-way taking place within our business is much dialogue between the senior leadership lower than through our supply chain, our team and employees. We maintain healthy recruitment procedures nevertheless relationships with our trade union partners incorporate several steps designed to and attend monthly meetings to discuss eliminate such risks. These include: potential issues (e.g. employment terms and conditions, learning and development, • Carrying out “right to work” checks and business change) that may affect Employment ensuring that the agencies we use to members. We also undertake annual supply temporary workers carry out negotiations on pay and conditions of Practices equivalent checks employment. • Carrying out pre-employment checks We communicate with employees both to verify the identity of prospective “We do not tolerate any form formally and informally, including through employees and to ensure they are over posters, leaflets, our intranet, a quarterly of human trafficking, forced or 16 years of age newsletter, and open forum meetings bonded labour or the exploitation • Completing disclosure and barring involving members of the senior leadership service checks for specific roles to team. Each week, the CEO takes questions of children or vulnerable persons enable us to make safer recruitment from across Drax on a wide range of topics decisions and we share his responses with the whole in our own business or our supply workforce. chains. We’re committed to tackling • Making sure that an employment this abhorrent crime.” contract is in place before the commencement of employment at Drax We strive to be an inclusive workplace and value diversity, with policies and practices in place to encourage this. We currently employ over 2,900 people across the UK and the US.

Our HR strategy centres around valuing people and focusing on talent, raising business performance, building capability through our people, and developing a high performing organisation. Our employees are at the heart of our success and are key enablers of our business strategy and our ethical culture.

A safe and healthy workplace is paramount to our business and so our employees benefit from a range of policies that support them. These include policies designed to enable wellbeing, to accommodate different work and lifestyle preferences, to encourage employees to raise grievances or concerns, and to support a diverse, inclusive and ethical workplace. 16 Modern Slavery Statement 2019 Modern Slavery Statement 2019 17

Progress in 2019: Supplier • Expanded our approach to wellbeing Contracts • Harmonised the level of core benefit cover across Drax i.e. healthcare We’ve incorporated provisions on human rights and • Rolled out unconscious bias training for all managers modern slavery into our Corporate Responsibility Statement (CRS), which we seek to include within • Introduced ways to improve engagement and appropriate agreements. communication with employees The CRS expects suppliers to have the relevant policies In 2020, we plan to: and procedures in place. These should aim to safeguard against direct or indirect engagement in activities that • Further expand our approach to physical and would constitute an offence under the Modern Slavery mental health with the introduction of a Wellbeing Act 2015. programme Progress in 2019: • Continue to embed our communication and engagement channels with employees • Drafted improved guidance for suppliers, to be incorporated into the new Supplier Code of Conduct In 2020, we plan to:

“We communicate with employees • Seek approval from the Board for the Supplier Code both formally and informally, of Conduct including through posters, • Publish the Supplier Code of Conduct leaflets, our intranet, a quarterly newsletter, and open forum meetings involving members of the senior leadership team.” 18 Modern Slavery Statement 2019 Modern Slavery Statement 2019 19

Awareness and Training

In 2019, we built on the modern slavery awareness and training that we’d previously provided. Our key deliverables are set out below. Progress in 2019:

• Issued our Corporate Crime policy (including policy level detail on modern slavery) as a mandatory read to all colleagues, temporary workers and relevant In 2020, we plan to: consultants (c. 3,000 people) via our Learning Management System • Assess the effectiveness of our modern slavery training through employee focus groups and feed • Deployed, as mandatory learning, a third-party this insight into the development of future training modern slavery specific eLearning package to all materials managers and ‘at higher risk’ teams (c. 1,000 people) via our Learning Management System • Develop and deploy our own in-house refresher eLearning material • Provided a modern slavery focused session to Procurement colleagues from across Drax. • Deploy the Employee Code of Conduct (including modern slavery content) as a mandatory read to – The session included a refresher on the all employees, temporary workers and relevant background to the law, compliance requirements, consultants, (including short videos on modern our programme, our ethical concerns and a slavery and other topics) and embed it within our discussion on how to improve the mapping of our new starter induction process. non-fuel procurement supply chains • Deploy the Supplier Code of Conduct (including • Continued our Biomass Sustainability Compliance short videos on modern slavery and other topics) team’s programme to promote modern slavery awareness when conducting biomass supplier site visits and to reinforce our ethical requirements

• Continued to issue our “Doing the right thing” eLearning videos (including a specific module on modern slavery and due diligence) to all new starters, as part of our induction programme 20 Modern Slavery Statement 2019 Modern Slavery Statement 2019 21

Progress in 2019:

• We selected a new third-party speak up service that all employees and suppliers can use

• Appointed a Whistleblowing Officer to oversee speak up activities

• Commenced quarterly reporting to the EBCC on speak up matters In 2020, we plan to:

• Implement and communicate our new third-party “Speak up” speak up service • Review and update our Whistleblowing policy, for Culture approval by the Board • Report directly to the Board, instead of the Audit We encourage those working on behalf of Drax to Committee, on speak up matters challenge unethical behaviour and promote a speak up culture. Colleagues can raise concerns with their • Create and deploy a dedicated Whistleblowing line managers, the Group Business Ethics team, or a programme, including an annual risk assessment and member of the EBCC. Alternatively, an independently- risk register operated and confidential speak up hotline and web portal is available. This enables employees to raise • Create and deploy non-retaliation guidance concerns anonymously, should they wish. The service • Publish our Employee and Supplier Codes of Conduct forwards any issues raised to the Group Business (that reiterate our speak up culture, reporting options Ethics team, who (in accordance with confidentiality and details) preferences) acknowledge, triage and organise investigation of the matter. The Group Business Ethics team then reports the issue to the EBCC, the Audit Committee and, if required, the relevant authorities.

Drax will not seek to punish (or otherwise retaliate against) anyone expressing genuine concern.

No concerns relating to modern slavery were raised through our reporting processes in 2019. 22 Modern Slavery Statement 2019 Modern Slavery Statement 2019 23

The organisation provides greater In 2020, we plan to: Working assurance that the coal we procure comes from mines that take a • Leverage our membership of UNGC responsible approach to safeguarding Modern Slavery Working Group by together workers, communities and their local collaborating with another member environment. More information on to share learnings on due diligence “We seek to work in partnership with Bettercoal can be found on its website. approach for trial fuel volumes others to strengthen our learning UN Global Compact Stakeholder Engagement and approach” In 2018, we became participants in the Like many businesses, we have a diverse UN Global Compact (UNGC) – a voluntary group of stakeholders who are affected Home Office consultation corporate sustainability initiative that by our global activities. These include encourages businesses worldwide to our shareholders, investors, employees, In 2019, we responded to the Home Office “Transparency adopt sustainable and socially responsible temporary employees, contractors, in Supply Chains Consultation”. We’re supportive of practices. Further information on the UNGC customers, suppliers, communities and several of their proposals including “mandatory reporting can be found on its website. local authorities, government regulators areas” and of the new online registry being proposed. and policymakers, schools and colleges, In addition to our general participation, academics, think tanks, non-governmental Modern Slavery registries we’re members of both the UNGC’s organisations (NGOs), network operators, Advisory Group (which governs the UK In 2019, we engaged with the Modern Slavery Registry trade and industry associations. Network) and its Modern Slavery Working and TISCreport.com to improve the transparency of our Group. Such involvement enables us to We conduct an ongoing mapping Modern Slavery Statement reporting. collaborate with, and benchmark our exercise to assess how the stakeholder activities against, our peers. landscape is developing and to ensure Sustainable Biomass Program (SBP) we’re recognising, and responding to, Our Annual Report for financial year end The SBP is a certification system designed for woody the expectations of a broad range of 2019 will contain the details required for biomass, mostly in the form of wood pellets and stakeholders across our businesses. our “UNGC Communication on Progress”. wood chips, used in industrial, large-scale energy These include the actions we’ve taken to production. demonstrate our commitment to all 10 of COMMUNITIES AND LOCAL the UNGC principles and to the Sustainable AUTHORITIES SBP proactively encourages the adoption of standards PROVIDERS CUSTOMERS OF CAPITAL and due diligence processes that include promotion Development Goals we’re actively progressing. of human rights. For suppliers to be approved under TRADE AND INDUSTRY EMPLOYEES the certification scheme, they must satisfy multiple ASSOCIATIONS requirements, including those relating to modern slavery Progress in 2019: due diligence. Further information on the Sustainable • Participated in all the UNGC Modern THINK TANKS GOVERNMENT Biomass Program and it’s independent board can be AND ACADEMICS AND Slavery Working Group meetings REGULATORS found on the SBP website.

• Hosted a UNGC peer Modern Slavery NON- Bettercoal SUPPLIERS AND GOVERNMENTAL Statement review, including three other CONTRACTORS ORGANISATIONS members Drax continued its engagment with Bettercoal in SHAREHOLDERS REGULATOR 2019. Established by a group of major European AND INVESTORS AND NETWORK BUSINESSES utilities, Bettercoal is a global, not-for-profit initiative SCHOOLS that promotes the continuous improvement of corporate responsibility in the coal supply chain. 24 Modern Slavery Statement 2019 Modern Slavery Statement 2019 25

KPIs and looking ahead Planned initiatives consolidation for 2020 As described throughout this Statement, we’ll explore how to strengthen our activities in human rights and modern slavery during 2020. This will include:

“We’re committed to continual improvement and aim to Programme element Initiatives strengthen our compliance programme year on year” Governance • Strengthen the EBCC agreed protocol by adding a detailed remediation plan Key Performance Indicators (KPIs) Risk assessment • Progress the non-fuel supply chain mapping We have internal modern slavery KPIs that measure the effectiveness of our programme. project, including the selection and adoption We consult the EBCC on progress and performance. of a new tool to assist the mapping process, as necessary 2019 KPI Progress • Reflect any updates to the Global Slavery Index in Employee training levels Building on our training programme from previous our due diligence platform, as required years, in 2019 all employees, temporary employees and relevant consultants received our updated Due diligence Corporate Crime policy as a mandatory read via • Evaluate the appropriateness of our approach to our learning management system. In addition, all trial fuel volumes, including benchmarking with managers and teams ‘at higher risk’ of encountering another UNGC Modern Slavery Working Group modern slavery received a mandatory eLearning member module to complete. • Strengthen the human rights content of our Identify and use opportunities Participation in the UN Global Compact (including third-party fuel supplier audits for collaboration to verify and membership of its Modern Slavery working group) resolve risk issues continued throughout 2019. Policies and procedures Steps taken to upskill our Our Biomass Sustainability Compliance team has • Seek Board approval for the new Employee Code high-risk suppliers continued its programme to promote modern slavery of Conduct awareness when conducting biomass supplier site visits and meetings. • Publish the Employee Code of Conduct Actions taken to strengthen Continuation of relationships with SBP and • Separate the content of our Corporate Crime our supply chain auditing and Bettercoal. We initiated a programme of fuel supplier policy into its constituent parts (such as a Human verification audits, and reviewed an independent audit report Rights policy, in relation to Modern Slavery) conducted at the Chinese manufacturing facilities for our smart meters. Employment practices • Further expand our approach to physical and Investigations undertaken into mental health with the introduction of a Wellbeing reports of modern slavery and Not applicable in 2019 due to zero reports. programme remedial actions taken Maintain up to date due • Continue to embed our communication and diligence information on Modern slavery survey enhanced and issued where engagement channels with employees supply chains that are high relevant. risk for modern slavery 26 Modern Slavery Statement 2019 Modern Slavery Statement 2019 27

Programme element Initiatives Supplier contracts • Seek approval from the Board for the Supplier Statement approval Code of Conduct

• Publish the Supplier Code of Conduct We’re committed to doing the right thing. We believe this approach, and the measures we’re taking, demonstrate how effectively we’re identifying and Training • Assess the effectiveness of our modern slavery addressing any modern slavery that could be connected to our business and training through employee focus groups supply chain.

• Develop and deploy our own in-house refresher The Drax board of directors has approved this statement for our financial year eLearning material ending 31 December 2019. We’ve completed it according to the requirements of section 54, part 6 of the Modern Slavery Act 2015. It applies to all • Deploy the Employee Code of Conduct (including companies within the Drax Group that are required to have a Modern Slavery modern slavery content) as a mandatory read to Statement, including: all employees, temporary workers and relevant consultants, (including short videos on modern • Drax Biomass Inc. slavery and other topics) and embed it within our • Drax Corporate Limited new starter induction process. • Drax Generation Enterprise Limited (former Generation Ltd) • Drax Group Holdings Limited • Deploy the Supplier Code of Conduct (including short videos on modern slavery and other topics) • Drax Group plc • Drax Power Limited Speak Up culture • Implement and communicate our new third-party • Drax Smart Generation Holdco Limited speak up service • Drax Smart Sourcing Holdco Limited • Drax Smart Supply Holdco Limited • Review and update our Whistleblowing policy • Haven Power Limited • Commence reporting to the Board on speak up • Opus Energy (Corporate) Limited matters • Opus Energy Group Limited • Opus Energy Limited • Create and deploy a dedicated Whistleblowing • Opus Energy Renewables Limited programme • Opus Gas Supply Limited • Create and deploy non-retaliation guidance This statement was signed by:

Dwight Daniel Willard Gardiner (known as Will Gardiner) Chief Executive Officer Drax Group plc

25 February 2020