Modern Slavery Statement


The Modern Slavery Act of 2015 (the “Act”), defines Modern Slavery as “slavery, servitude and forced or compulsory labour”, a situation in which tens of millions of people around the world are kept against their will. So Energy as a company vehemently opposes such actions, and was founded with fairness, equality and inclusivity at its core, in line with our Company Values. 

So Energy recognises that slavery and human trafficking is a global issue that has to be addressed by all companies within all industry sectors. So Energy recognises our responsibility to respect and promote international human rights standards in everything we do, in line with our Parent Company, ESB. So Energy expects all partners, contractors, and suppliers of goods, services, or works – to the company or on behalf of the company – to perform their duties in an honest and ethical manner, within the law and with respect for everyone’s human rights. We are committed to acting ethically in all of our business dealings and relationships and will take all reasonable steps to ensure human trafficking and/or modern slavery is not happening anywhere in our business or in the organisations with whom we do business. 

As per section 54 of the Act, in our organisation and those of our suppliers we are confident that the risk of the involvement of slavery and human trafficking is low. There has been no evidence found of modern slavery or forced labour across our organisation or supply chain, but we remain vigilant and continue to evolve processes and controls to guard against risk. While incredibly unlikely, if we were to discover that any of these organisations were to be involved in such exploitation, we would take all appropriate measures up to and including the termination of  our relationship and make reports to the appropriate authorities. 

We regularly carry out due diligence with our suppliers to confirm that they adhere to the ethical standard that we require and will only work with those that meet that standard. 

Our People – Recruitment Policies and Procedures 

So Energy employs over 400 Energists (“our employees”).  

Our in-house Talent team employs robust, fair and consistent recruitment practices, for all permanent and temporary appointments, which uphold equal opportunities, compliance, equal and fair pay, as well as adhering to current legislation to ensure our workforce is free from modern slavery. We believe that all of our employees and job applicants must be treated equally and be given the same set of opportunities regardless of their age, sex, race, disability, sexual orientation, disability, culture or any other personal characteristic that might be discriminated against. We are a proud member of the Disability Confident Scheme, which encourages employers to think differently about disability and take action to improve how they recruit, retain and develop disabled people.  

As part of our new starter process, we ensure that right to work checks are completed and supported by relevant documentation for all of our direct employees, upon receiving their application for a role at So Energy. Furthermore, all relevant vetting checks are processed prior to our new starters first day at So Energy including further vetting checks, including a basic criminal record check and 2/3 years of employment history, which are completed by a third party. Under no circumstances are new joiners permitted to commence their employment at So Energy, without these checks being completed. 

Additionally, there are certain roles within So Energy which require further third-party vetting measures, depending on the area of the business and the level of the role. We also complete additional vetting measures for individuals who have areas of significant control or significant managerial responsibility or influence, in line with Ofgem regulations, where there is a reasonable prospect that there will be a change in a Person with Significant Control or Significant Managerial Responsibility or Influence (as defined in SLC 19AA). The SLC 19AA Assessment is an assessment of significant personnel developments by the Authority against the requirements set out in guidance issued by the Authority on SLC 19AA and (subject to the licensee's provision of information required by the Authority) to be carried out in advance of any significant developments. This assessment is to increase regulatory scrutiny of supplier growth and to strengthen checks on significant personnel developments, which will protect consumers by mitigating the harmful effects associated with unchecked and unsustainable supplier growth, and poor supplier business practices. 

So Energy works with external recruitment agencies at times, to secure candidates for certain roles. As part of this working relationship, So Energy ensures that all recruitment agencies are aligned with our recruitment practices to ensure that these requirements are achieved. 

So Energy is proud to be an accredited London Living Wage employer , since 2021. The Real Living Wage is the only UK wage rate based on the cost of living. It is voluntarily paid by over 12,000 UK businesses, of which So Energy is one of those businesses. So Energy believes that everyone deserves to be fairly compensated for their work, including equal pay which is defined as “the right for men and women to be paid the same when doing the same, or equivalent, work” under the Equality Act 2010 and the Equality and Human Rights Commission (EHRC) statutory code of practice on equal pay.

ESB Group  

So Energy  is part of the Electricity Supply Board and along with its own policies has integrated with the ESB Group. ESB is a vertically integrated utility whose business activities include the generation, transmission and distribution and supply of electricity in Ireland and the United Kingdom. Further details of ESB business operations can be found at  

ESB launched an updated ESB Staff Employee Code of Ethics “Our Code” in September 2021, which includes guidance on ethical business practices and communicated these guidelines to all employees and contracting parties, click on the following link for further information esb-our-code---september-2021.pdf.

In addition, ESB published a Human Rights Policy in 2021, linking its policies on human rights areas (Health and Safety, Environment and Sustainability, Cultural Diversity, ESB Equal Opportunities and Diversity, Anti-Bribery, Corruption & Fraud, Whistleblowing & Protected Disclosures and Modern Slavery), see link for further information - ESB Human Rights Policy.

The Company has also adopted ESB’s Policy on Modern Slavery (available at This policy sets out the actions that the Company will take to ensure the prevention of modern slavery, the roles and responsibilities from Board level down to each individual employee and the means by which any suspected incidences of modern slavery should be reported. Employees are encouraged to report any suspected wrongdoing, and ESB’s Group Policies set out the protections for employees in reporting serious malpractice at work.  

In order to understand how effective these controls are to ensure that modern slavery does not exist within our supply chain, external audits are conducted, where appropriate, on the activities of suppliers considered to operate in high-risk regions or industries. No incidents of modern slavery were found during the course of these audits.  

The specific work outlined above will be complemented by a further programme of work for 2023.