Anti-Slavery and Human Trafficking Statement

Approved by the Directors on 31st May 2022


Modern slavery can take various forms such as forced and compulsory labour, child labour, domestic and
indentured servitude (e.g., debt bondage) as well as human trafficking, all of which deprive a person of their
liberty in order to exploit them for personal or commercial gain. Modern slavery represents some of the
gravest forms of human rights abuse in any society. We all have a responsibility to be alert to the risks, however
small, in both our business and in our wider supply chain. Our employees are expected to report any concerns
and the Board is expected to act upon them.

The use of exploitative labour and human trafficking is a criminal offence and is strictly forbidden in both our
own operations and in the supply chains we use. We do not support or deal with any person or business
knowingly involved in slavery or human trafficking.

Our Business

Intelligent Energy is a world leading fuel cell engineering company focused on the development, manufacture
and commercialisation of its Proton Exchange Membrane (PEM) fuel cell products for customers in the aero,
automotive, stationary power and Unmanned Aerial Vehicle (UAV) sectors. Fuel cells are used in multiple
applications, where clean, lightweight, high efficiency and cost-effective power is required. We are
headquartered in Loughborough, in the UK, with additional offices and representation in the US, Japan, Korea
and China.

Our supply chains

Our supply chains include the sourcing of materials principally in relation to the manufacture and testing of
our fuel cell products. Over 95% of suppliers that we have used in the last 12 months are based within the UK,
or other areas of the world that we class as low risk for the purposes of slavery and human trafficking. For
suppliers in high-risk territories, our Procurement and Legal team carry out further screening and checks where deemed necessary.

Our policy on slavery and human trafficking

Intelligent Energy is committed to conducting all aspects of its business in an ethical and transparent manner.
We acknowledge our duties and responsibilities under the Modern Slavery Act 2015 (the “Act”). Although we
are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are
making this voluntary statement to show that we are committed to maintaining high ethical standards and
acting with honesty, integrity and transparency in all our business dealings worldwide. We do not tolerate any
form of slavery or human trafficking in our organisation or within our supply chains. We expect the same high
standards from all our suppliers, contractors and business partners. We have implemented a Modern Slavery
Policy, which reflects our commitment, and outlines how our various procurement practices, policies and
procedures ensure that we comply with the Act and avoid any potential complicity in human rights violations.

Supplier adherence to our values

We seek to ensure that we only engage with suppliers who uphold the values to which we adhere, and all new
suppliers, contractors and business partners that we choose to work with are required to sign up to our
Supplier Code of Conduct (or have appropriate equivalent policies and procedures in place), which confirms the
standards we expect our suppliers to uphold, particularly in relation to labour/human rights; health & safety;
environment; legal compliance and ethics; management systems; anti-bribery & corruption; and modern slavery &
human trafficking. They are also required to provide a copy of their Slavery and Human Trafficking Statement, if
subject to the Act.

Our Supplier Code of Conduct is regularly reviewed to reflect our commitment to compliance with the Act.

Responsibilities for policy compliance

The Directors are ultimately responsible for the overall compliance of our legal and ethical obligations under the Act.

Under the leadership of the Operations Director, the Procurement and Supply Chain team is responsible for ensuring that our policies and procedures are adhered to, with regards to the day-to-day vetting of new suppliers and monitoring our supply chain to ensure compliance with our duties.

In addition, compliance with the Act is the responsibility of all employees, persons or organisations working for or on behalf of the Company.


To ensure a high level of understanding of the risks of slavery and human trafficking in both our supply chain and own business, we offer additional training to relevant employees where required.

Reporting of suspected policy breaches

All employees are encouraged to report any concerns they may have in relation to slavery and human trafficking. We also operate a Whistleblowing Policy which allows employees to report such matters to the Whistleblowing Officer. Incidents or concerns raised via this route can also be reported directly to the Board. As of the date of this statement, no concerns have been raised in relation to modern slavery or human trafficking.

This voluntary Anti-Slavery and Human Trafficking Statement constitutes the Company’s slavery and human trafficking statement for the financial year ending 30th December 2022.

David Woolhouse

Chief Executive Officer

Intelligent Energy Limited