At Drax, we are committed to conducting business ethically, with honesty and integrity, and in compliance with relevant laws and regulations. We do not tolerate any form of bribery, corruption, human rights abuse, or other unethical business conduct.

Drax Supplier Code

Click here to view the Drax Supplier Code of Conduct

Our Supplier Code sets out the commitments and standards we expect from our third parties, and any subcontractors they use, in relation to working for Drax. The Supplier Code, which was reviewed and updated in 2022, includes details of how any third party can “speak up” about a concern over non- compliance with the Supplier Code.

During 2023 we continued to roll out our Supplier Code to relevant third-party suppliers, incorporating it into the associated contracts by means of a specific business ethics clause, including a termination clause for a serious breach. We commenced a further review of the Supplier Code which will be concluded in 2024.

Our Framework

Our Business Ethics and Privacy Documentation Framework consists of principles, policies, and guidance.

Our Business Ethics and Privacy teams take steps to understand our risk profile and develop an appropriate risk mitigation strategy. In addition to this they monitor compliance and investigate potential breaches, as applicable. Our internal audit function provides additional assurance on the robustness of our Business Ethics and Privacy programmes.

In 2023, we strengthened our Ethical Due Diligence programme by establishing a second line assurance structure and activity plan. The team also commenced work on creating dedicated programmes to support our Anti-Fraud and Political Engagement policies. This work will be completed in 2024.

Responsibility for Ethics and business conduct

Everybody at Drax is personally responsible for ethical business conduct. Managers are responsible for demonstrating leadership on ethical matters and supporting their teams to apply our ethical principles.

We have a dedicated Business Ethics team who develop, maintain, and manage the Business Ethics programmes and associated Documentation Framework.

In addition, we have a Data Privacy team that provides guidance on data privacy best practice and meets the needs of personal data requests.

The Ethics and Business Conduct Committee (EBCC), a sub-committee of the Executive Committee, oversees our Business Ethics and Privacy programmes.

The EBCC is chaired by our Group General Counsel. It serves as an escalation route for higher risk ethical decisions, supported by an agreed Escalation Protocol.

The Audit Committee provides an additional layer of oversight, receiving an annual summary on EBCC activity. The Audit Committee also receives regular Speak Up report updates.

Anti-bribery and anti-corruption

At Drax we do not condone any behaviour that could lead to actual or perceived bribery or corruption. Our ABC programme is based on “Adequate Procedures” guidance. In 2023, we conducted an annual review of our Gifts, Hospitality, and Conflicts of Interests records. We updated guidance on gifts and hospitality, introducing additional thresholds and approaches regarding gifts and hospitality in Drax Asia, Japan, and to indigenous people. We also created and deployed dedicated ABC eLearning to colleagues considered ‘higher-risk’ of encountering bribery due to the nature of their roles.

Fair competition

We are committed to competing fairly and in accordance with applicable fair competition law. Our Fair Competition programme now covers UK and Japanese competition law, US anti-trust law, and Canadian laws, and includes dedicated training for ‘at higher risk’ teams.

Data privacy and security

In 2023, we completed the annual review of policies and notices to confirm they remain in line with prevailing legal and regulatory requirements. System improvements were implemented to third-party onboarding for Data Protection and Information Security Due Diligence across the US and Canada, to help ensure that due diligence is performed consistently across the Group in line with best practice.

Other improvements were made to annual refresher training on data protection topics, working practices with the Information and Cyber Security function, and continued education within the Data Protection team.

Investigations into potential data breaches were investigated in a timely manner, with good support from operational teams. No internal investigations during 2023 resulted in a requirement to send a notification to any relevant authorities (such as the Information Commissioners Office).

Individual rights requests from customers and employees were processed within required timescales, along with requests made by appropriate authorities (such as the Police).

Supply chain human rights

We set out our human rights commitments in our Human Rights policy, the Drax Code, and our Supplier Code. Our cross-departmental Supply Chain Human Rights Working Group reports quarterly to the EBCC. Drax has been a signatory of the UN Global Compact (UNGC) since 2018 and participates in the UNGC’s

Modern Slavery Working Group, together with Utilities Against Slavery (Slave Free Alliance) working groups and a steering committee. We have a close working relationship with UK anti- slavery charity Unseen, who run the UK’s Modern Slavery Helpline. Our 2023 activity in relation to this programme is set out in our 2023 Modern Slavery Statement. Our planned activities for 2024 are also set out in that statement.

Speak Up (whistleblowing)

We are committed to transparency, openness, and continuous improvement.

We encourage those working for and on behalf of Drax, and our third parties, to raise genuine concerns (via our reporting channels) about practices that could breach laws, regulations, or our own ethical standards.

Drax does not condone retaliation or victimisation in relation to Speak Up matters.

During 2023, 49 reports were raised across both our internal and external channels. This is an increase from 14 in the previous year.

Additional ethics and integrity data is available in our ESG Performance Report

ESG Performance Report 2023

Corporate Criminal Offences (CCO) (anti-facilitation of tax evasion) 

Our ethical due diligence and payment procedures seek to facilitate the conduct of business which is compliant with applicable tax laws. These are subject to regular internal audit. Additional guidance was provided to colleagues most likely to be exposed to ‘at higher risk’ activity.

Financial and trade sanctions 

In 2023, our Financial and Trade Sanctions programme was subject to internal audit, which identified some improvements to strengthen the robustness of our programme. We plan to implement these recommendations in 2024. Regular reporting on sanctions activity to EBCC continued in 2023, with no instances of breach identified.