Human Rights and Modern Slavery Statement

For the financial year 2022

Introduction

Our Human Rights and Modern Slavery Statement (hereafter “Statement”) determines MFT Energy A/S and its subsidiaries (hereafter “MFT Energy”) commitment to preventing slavery and human trafficking in our business activities and the measures MFT Energy has taken to ensure that no slavery or human trafficking is to be found in our business. MFT Energy acknowledges the UK Modern Slavery Act from 2015 and supports its objective to eradicate forced labor and human trafficking.

We strive to be the best possible company for the benefit of our employees as well as our business partners. Besides that, we aim to contribute to the society we are a part of, and as an integrated part of this ambition, we support and comply with internationally recognized principles for environmental protection, human and labor rights, business ethics, and anti-corruption.

Who are we?

MFT Energy and its subsidiaries are an independent trading hub specialized in power and gas. We trade 24/7 across 38 countries around the world. Generally, our trading expertise helps restore energy balances and brings efficiency to the markets. Our power and gas trading includes physical and financial trading via exchanges, standard futures, and structured products, covering all delivery periods and capacity auctions. The supply chain of MFT Energy is constituted by several suppliers.

How we incorporate our Statement into our culture

Our Statement sets out our position in line with internationally recognized human rights principles. We host the Statement on our website and review and confirm that we comply with the Statement every year. Our Statement is incorporated into our business culture through our Code of Conduct as well as our take on ESG (environment, social, governance). Furthermore, we make a great effort to enforce our Statement by setting the tone from the top. We have built a culture where employees can feel free to share ethical dilemmas and potential violations if rules, legislation, ethical standards, and internal rules aren’t complied with.

How we ensure human rights risks

At MFT Energy we have policies and procedures to ensure that human rights risks are identified, assessed, and addressed. We ensure that all employees in all countries we operate in are recruited lawfully both international and national. Therefore, we have HR management procedures for all relevant countries to ensure compliance. In addition, we require that all employees have valid residence and work permits to ensure that they are living and working legally in the country in question.

Due diligence and risk assessment

MFT Energy considers its position within the energy trading industry as having a low risk for modern slavery. MFT Energy expects its suppliers and business partners to ensure that modern slavery does not occur within their supply chain as well. Modern slavery is a global issue that typically occurs within industries where labor is intensive, low-skilled, and underregulated across supply chains. Even though MFT Energy’s position within the energy trading industry is identified as low risk, MFT Energy makes a great effort to review any ongoing relationships with an organization if issues are identified and aren’t resolved to our satisfaction.

Setting the tone from the top to ensure compliance

In order for us to effectively deliver on our Statement key personnel in our business need to have sufficient understanding of this topic and our approach to risk identification and management. This is why we make a great effort to set the tone from the top, which ensures awareness on a continuing basis. Having strong competencies within compliance is essential to ensure an ongoing strengthening of MFT Energy’s overall governance. We know that our systematic approach and constant focus on documentation and compliance ensures a high level of governance.

Accountability for human rights and modern slavery relating to our business resides with the Chief Executive Officer. Our Head of Compliance is responsible for the day-to-day management of the Statement.

Our commitments

MFT Energy monitors and evaluates its processes on a continuing basis to ensure an effective approach to prevent slavery from taking place in any part of our business. At MFT Energy, we are committed to respecting human rights in everything we do and comply with the UN’s 30 articles regarding the Universal Declaration of Human Rights.

Approval and reviewing

This Statement covers the financial year 2022. Our Statement is reviewed annually by the Executive Management and approved by the Board of Directors. The signing has been delegated to the Chief Executive Officer of MFT Energy.

Bo Palmgren Chief Executive Officer