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Vattenfall’s
statement on
slavery and
trafficking
2025
Introduction from [navn skjult], CEO and President of Vattenfall AB
This is Vattenfall's ninth update of the statement on slavery and human trafficking following the introduction
of the Modern Slavery Act in 2015. We're proud of the progress we have made and we are committed to
continuously improve our approach towards identifying and combating any form of modern slavery and
human trafficking throughout our value chain.
About Vattenfall
Vattenfall AB is the parent company of the Vattenfall Group (the “Group”) and is 100% owned by the Swedish
State. The Group owns and operates a diverse range of energy businesses and is involved in the generation,
distribution and sales of electricity and heat. Vattenfall’s core countries of operation are Sweden, Germany,
the Netherlands, Denmark and the UK. In 2025, Vattenfall reported a turnover of SEK 234,915 million,
Vattenfall has a total of 21,301 employees, out of which 766 are temporary. Further details can be found at
www.vattenfall.com.
1. Organisation structure and supply chains
The Group’s activities are divided into five different business areas: Generation, Wind, Markets, Distribution,
and Customers & Solutions. Responsibility for modern slavery and respecting human rights lies with the
heads of the business areas and staff functions.
Supply chains for the five business areas can be roughly consolidated into the following sourcing streams:1
Sweden, Germany, The
Goods & Netherlands & other
22,882 Diverse European and Asian 8,864 36
services
countries
Sweden, Netherlands, Germany,
Waste & Woody biomass, France, Poland, Belgium,
210 Finland, Iceland, Norway, UK, 199 38
biomass waste, bio-oils
Latvia, Canada, USA.
Natural
gas N/A Natural gas European gas hubs N/A N/A
Canada, Australia, USA,
Nuclear
fuels 13 Uranium Great Britain, Germany, 20 5
Netherlands and Sweden.
Number of Primary Primary Number of Number of
suppliers products countries supplier site audits
screenings conducted
conducted
Vattenfall also hires contractors to carry out various activities including installations, logistics and
construction. As Vattenfall operates in locations with established human rights legislation, the risk of
modern slavery for contractors operating on our sites is low. Nonetheless, several measures are being
implemented, including a pilot project on worker welfare to further monitor their working conditions. See
section 5. Progress and Effectiveness for details.
1
Vattenfall does not hold any direct contract with gas producers as the gas is sourced through European gas hubs. More
information can be found in Section 4: Due Diligence Procedures
2. Our Policies
Vattenfall is a signatory of the UN Global Compact and acknowledges that our business has a duty to respect
all internationally recognised human rights based on the International Bill of Human Rights. Our Human Rights
Policy forms the foundation of our work and is based on The Universal Declaration of Human Rights, The
International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work, The
OECD Guidelines for Multinational Enterprises, United Nations Global Compact and UN Guiding Principles for
Business and Human Rights.
In respect to modern slavery, the Human Rights Policy states our aim to:
Commit to provide decent working conditions and treat everyone with equity, dignity and
respect, we promote equity, diversity and inclusion and work against all forms of child labour,
modern slavery, harassment, and discrimination in our own operations, our supply chains and
with partners.
Furthermore, Vattenfall has a number of policies governing its operations and its suppliers’ and partners’
behaviour. Internally, the Code of Conduct and Integrity defines policies for conducting business with integrity
in the context of Vattenfall’s four principles: Open, Positive, Active, and Safety.
With regards to our “Positive” principle, the Code of Conduct and Integrity states:
Our procurement processes are fair, transparent and responsible, and we only work with those
who share our commitment to doing business in an appropriate and ethical manner.
And linked to our “Active” principle, it specifies:
It is every employee’s responsibility to report anything that does not seem appropriate or safe.
Examples include: …the possible infringing of a person’s human rights...
The Code of Conduct and Integrity also establishes a whistleblowing system available to any stakeholder to
report serious irregularities concerning Vattenfall, including human rights violations. In 2025, no cases of
modern slavery were reported through the system. In cases where Vattenfall has directly caused or
contributed to negative human rights impacts, we commit to provide appropriate forms of remediation.
Vattenfall’s whistleblowing channel can be accessed in a variety of languages and is available 24/7 at:
https://report.whistleb.com/en/vattenfall
The Group’s Code of Conduct for Suppliers and Partners2 defines our expectations on our counterparties in
the area of human rights and working conditions, the environment and business integrity. It explicitly
addresses modern slavery, and states that all forms of modern slavery are unacceptable to Vattenfall. More
information about our approach to supply chain responsibility is available at:
https://group.vattenfall.com/who-we-are/sustainability/social-responsibility/supply-chain-responsibility
The Code of Conduct for Suppliers and Partners includes specific provisions on entering employment freely
and freedom of movement and association of employees, linked to the International Labour Organisation’s 11
indicators of forced labour. Additionally, it also prohibits other human rights violations that are linked to
2
The Code of Conduct for Suppliers and Partners is translated into several languages. English, Swedish, Dutch and
German translations can be found in the local version of our Group websites: group.vattenfall.com. Other language
translations including Danish, Finnish, French, Polish and Chinese are shared with suppliers upon request. Vattenfall
requires suppliers to communicate this policy to their workers.
modern slavery such as excessive overtime, child labour, discrimination, the confiscation of worker’s identity
documents and any threat of violence, harassment and intimidation towards employees.
This policy is enforced through various mechanisms, including the Ethical Clause. The Ethical Clause is a
contractual provision that requires suppliers to adhere to the Code of Conduct for Suppliers and Partners (or
an agreed upon equivalent), enables on-site audits by Vattenfall, and allows for contract termination in case
of severe violations or if the supplier refuses to rectify and remediate impacts. See section 4. Due Diligence
procedures for more information on the enforcement mechanisms.
Lastly, the Guide to the Vattenfall Code of Conduct for Suppliers and Partners has been developed as an
accompanying document to the Code. The aim is to ensure that our suppliers and partners have access to a
range of different examples on how to fulfil the expectations outlined in the Code. This Guide incorporates
elements related to modern slavery, including guidelines and best practices that suppliers can implement to
ensure their compliance with our Code of Conduct and international standards.
The above policies were developed following multiple rounds of internal and external stakeholder feedback
and are available at https://group.vattenfall.com/who-we-are/sustainability/policies-and-management.
3. Risks and risk assessment
We systematically identify, assess and manage human rights risks and impacts through due diligence
processes which cover our own operations as well as sourcing and purchasing. In addition to our due
diligence procedures for our supply chain (see section 4. Due diligence procedures) we engage third party
experts every three to five years to conduct human rights risk assessments of our full value chain. In 2025,
we continued to work on the results of our latest Human Rights assessment (from 2021), addressing our most
salient risks, which include community engagement, livelihoods, and cultural heritage; grievance
mechanisms and access to remedy; Indigenous Peoples; occupational health, safety and security; just
transition and responsible decommissioning; environmental impacts; sourcing from conflict-afflicted or high-
risk areas; and supplier and contractor labour conditions. We also do internal risk assessments on an annual
basis where we identify and assess risks arising from any significant changes in e.g. our product & service
portfolio, geographies and supply chain.
We are aware of the risk of modern slavery in certain product categories and geographies, and work diligently
to prevent instances of modern slavery. No cases of modern slavery have been found in our Tier 1 suppliers
in 2025.
On an annual basis, we identify high-risk suppliers among our active supplier base, covering Goods &
Services, Waste and Biomass, and Nuclear fuels3, based on product and service category, manufacturing
country risk, and spend. This control helps us to
validate whether appropriate risk mitigation on
existing high-risk suppliers took place. In 2025, the
assessment revealed 905 high-risk suppliers,
which represents around 5% of our total supplier
base. Currently we have approximately 88% of our
supplier base covered by our annual risk
assessment and our aim is to increase this
coverage. For the 26 newly detected high-risk suppliers, we initiated dialogues on key risk elements, including
modern slavery if relevant. Depending on the risk picture, follow-up measures might include desktop follow
3
This annual review does not cover commodity fuels and ancillary products and services. Risk assessments on these
categories are carried out separately and cover 100% of our counterparties.
up, supplier dialogues, supplier trainings or on-site sustainability audits. For the recurring high-risk suppliers,
we review the effectiveness of the previous measures and follow up where necessary.
The situation of the Uyghurs and the strong indications of potential links to forced labour in the Xinjiang region
continue to be of major concerns to Vattenfall. This is particularly significant as it can affect our solar, batteries
and vehicle fleet4 supply chains, and can be present in raw material extraction and processing done in the
region, potentially ending up in products relevant to Vattenfall. We continue to monitor the situation, engage
in capacity building, hold internal and external dialogues, and collaborate through industry initiatives.
In 2025, the risk of forced and child labour in the supply chain was determined as a material topic by our
yearly Double Materiality Assessment (DMA). This prioritization led us to implement enhanced due diligence
practices to prevent and mitigate this impact. See section 4. Due diligence procedures for more information.
4. Due diligence procedures
The Group purchases a wide range of goods, services, and fuels, with varying risk profiles and varying legal
and sustainability requirements. The composition and complexity of the Group’s supplier base varies
depending on what is being purchased or sourced. Therefore, the evaluation of our suppliers’ implementation
of the Group’s Code of Conduct for Suppliers and Partners varies. Nevertheless, modern slavery is always
considered when evaluating all suppliers.
Our general approach to due diligence in the supply chain is described in the following graphic, with slight
nuances in the different sourcing streams based on risks, regulations, and market conditions for those
streams:
Initial Risk assessment Investigate Corrective Actions Monitor
Suppliers are assessed by
During an on-site audit the The supplier addresses the
the SRAT Light. If Our suppliers’
supplier’s compliance with findings by providing and
Stream
Audit
indicated, high-risk sustainability
our sustainability implementing a corrective
suppliers undergo a performance is being
requirements is evaluated. action plan.
sustainability audit. monitored and
followed up to ensure
continuous
Screening Stream
If records are found during Follow-up actions and in- improvement.
Potential suppliers are
screened based on screening, sustainability depth investigations may be
ownership structure, analysts evaluate the carried out depending on
PEP5, sanction lists and findings. the findings.
adverse media.
Compliance to the Code of Conduct for Suppliers and Partners (CoCfSP)
The Supplier Risk Assessment Tool, hereafter SRAT Light6, identifies and assesses ESG risks, including
labour conditions and modern slavery, in connection to suppliers and contractors and provides a risk
response (e.g., full or tailored scope sustainability audits, self-assessment questionnaires or other
4
Mainly work vehicles used for sales and maintenance.
5
PEP: Politically Exposed Person
6
This is a tool used by the procurement organisation to assess individual suppliers' sustainability risks. A supplier's
sustainability risks are based on manufacturing country, product or service provisioning category, and contracted spend.
engagement activities). The tool is applied individually on suppliers with a contracted volume above
€100,000 prior to contracting to assess suppliers’ risks and identify appropriate risk mitigation based on
product or service category, manufacturing country and spend risk. When recommended by the SRAT Light,
a full or tailored-scope on-site audit focusing on all or either environmental, social or governance dimensions
is conducted by a third party on high-risk suppliers. If the supplier is contracted, all non-conformances that
are identified during the audit are followed up in a corrective action plan.
The checklist for our on-site sustainability audit covers potential modern slavery risks at suppliers by
specifying items to observe, such as the presence of recruitment fees or deposits, withholding of identity
documents, substantial differences on the conditions promised to (migrant) workers versus current working
conditions, and the ability of each worker to resign from their job voluntarily and freely. If excessive overtime
is detected in an audit, which can be one indicator of modern slavery, we alert the supplier to take immediate
actions to reduce the working hours to sustainable levels, conduct a root cause analysis to identify the cause
for the overtime and initiate long-term actions.
Additionally, Vattenfall screens and monitors potential and existing counterparties (e.g. suppliers, partners
and select B2B customers) for risk factors based on environmental, social and governance criteria to identify
potential risks and drive collective improvements. We continuously monitor our counterparties based on their
associated risk level as part of our monitoring & re-screening strategy. High risk suppliers are constantly
monitored, while medium risk are re-screened every 2 years and low risk every 3 years.
Building on these efforts, recent board-level discussions on forced labour risks in our supply chains led to the
implementation of an enhanced due diligence process for sourcing high-risk product categories. This
process includes several steps that allow for a more thorough and consistent evaluation of suppliers based
on specific risk information connected to each product category. We’ve applied this approach to solar panels,
batteries, company cars, IT equipment, and uranium to gain deeper insight into associated risks, including
modern slavery. Our goal is to expand this in-depth assessment to other high-risk categories. While the steps
may vary depending on the supplier’s context and the most prominent risks in their supply chain, they
typically involve the following:
Initial Risk assessment Investigate Corrective Actions Monitor
During an on-site audit
the supplier’s
compliance with our
sustainability
requirements is
Suppliers are assessed The supplier addresses
Audit Stream
evaluated.
by the SRAT Light. If the findings by
indicated, high-risk Enhanced due providing and
suppliers undergo a diligence step: implementing a
sustainability audit. corrective action plan.
When assessing a
potential high-risk 1st
tier supplier, it
Our suppliers’
undergoes a full scope
sustainability
sustainability audit.
performance is being
monitored and
followed up to ensure
continuous
Potential suppliers are
If records are found Follow-up actions and improvement.
screened based on
during screening, in-depth investigations
ownership structure,
sustainability analysts may be carried out
PEP, sanction lists and
evaluate the findings. depending on the
adverse media.
findings.
Screening Stream
Enhanced due
Enhanced due diligence step:
diligence step:
We may ask suppliers
External reports on the for traceability records
risks in the supplier’s and due diligence
industry (including measures to
modern slavery) are understand their
reviewed. sustainability controls
and supply chain.
Compliance to the Code of Conduct for Suppliers and Partners (CoCfSP)
In parallel, we collaborate with other industry stakeholders through multi-stakeholder initiatives with the aim
to jointly assess and mitigate risks in the deeper supply chain. Where appropriate, we incorporate insights
gained from these engagements into our decision-making process, looking to ensure a more comprehensive
understanding of our suppliers' context.
Standard due diligence practices per supply chain category are summarised as follows:
Goods and services Waste and biomass Natural gas Nuclear fuels
Threshold All counterparties Differing thresholds to All natural gas All nuclear fuels
for with a contract value conduct screenings are counterparties. counterparties.
screening over €10,000. applied across the
organisation, which are
currently being aligned.
Threshold Suppliers from high- Differing thresholds for There are no audits All nuclear fuel
for risk countries and sustainability audits are conducted on gas suppliers are regularly
sustainabili suppliers of high-risk applied across the suppliers as we use the audited (every three to
ty on-site product or service organisation, which are wholesale market to six years).
audits categories are currently being aligned. obtain gas for our own
regularly audited consumption and for our
(every 3rd year) if customers.
their contracts are
over €100,000.
Industry Industry initiatives in The woody biomass Vattenfall supported the Vattenfall is an active
Initiatives Goods and Services that we purchased Gas Taskforce initiated member of the World
are often product or from third parties on by the Responsible Nuclear Association
industry dependent the international Commodities Sourcing (WNA), participating in
which is why market in 2025 was Initiative (RECOSI), which the WNA ESG working
Vattenfall sourced only from is investigating if the group.
participates in certified suppliers model used to address
several of these, within the EU, Canada sustainability risks of
including the Solar and the U.S. The coal producers can be
Stewardship certifications we rely on adapted for the natural
Initiative, the are: the Sustainable gas supply chain. As part
International Biomass Program of this, a due diligence
Responsible (SBP) and/or the Forest framework for natural
[navn skjult] Stewardship Council gas that tackles a range
Agreement for the (FSC). of sustainability risks,
[navn skjult] including forced labour
Sector, and the is being designed.
German Energy
Sector Dialogue.
5. Progress and effectiveness
Since 2023, we have detailed the actions taken in response to key human rights risks in our Human Rights
Progress Report, outlining efforts to reduce negative impacts and promote positive outcomes. We also
disclose actions towards addressing modern slavery in our Annual and Sustainability Report, where forced
and child labour were added as material topics this year. In 2025, as detailed in these reports, we introduced
additional measures to strengthen our approach to modern slavery and human rights such as:
• Continuing the development of a category matrix7 to review human rights and other risks related to
the products and services Vattenfall purchases. In 2025 a mapping was conducted to identify the
product categories exposed to forced labour, which serves as input to future product category
strategies and action plans.
7
A category matrix is a map of sustainability focus areas against Vattenfall’s product categories. This helps identify the
sustainability risks associated with each product purchase, allowing for targeted actions to be taken to mitigate those
risks.
• Developing a “Worker’s Voice” survey template to be implemented collaboratively with a supplier as
part of a pilot.
• Conducting a one-month pilot with a supply chain transparency software provider to help identify
risks such as modern slavery and improve visibility beyond Tier 1 in high-risk supply chains.
• Continuing dialogues internally and externally around supplier and contractor labour conditions to
increase awareness, share learnings and map risks connected to several human rights topics
including modern slavery. Specifically, we conducted biannual supplier meetings with particular
emphasis on the solar supply chain with the objective of mitigating the risk of forced labour.
• Requesting component traceability reports from specific suppliers in high-risk product categories to
better assess several risks in their value chains, including forced labour.
• Requesting battery suppliers to commit to enhance transparency regarding the origins of their
materials, to better assess the risk of child and forced labour associated with raw materials used in
these products.
• Implementing a chain of custody certification scheme for bioenergy feed coming from outside the
European Union using EU recognized voluntary certification schemes along the whole supply chain,
that include child labour as a compliance criterion.
• Participated in two multi-stakeholder initiatives (German Energy Sector Dialogue and International
Responsible Business Conduct Agreement for the Renewable Energy Sector) which developed tools
to identify and address human rights risks in the construction of renewable energy sites, specifically
focusing on vulnerable groups such as migrant workers. In 2025, various tools were tested, with
particular interest on trainings for site managers, a template for mapping contractors on site, and
tender requirements. We aim to implement selected tools on a broader scale after refining these
based on the feedback from the pilot process.
• Engaging with peer-level suppliers in the energy and other sectors affected by the risk of Uyghur
forced labour in knowledge sharing sessions around labour conditions in supply chains, seeking to
establish a consolidated approach towards this matter.
6. Training and competence building
We aim for 100% of newly hired buyers in Procurement to receive a training which covers compliance and
human rights in the supply chain. Additionally, Vattenfall has developed an internal library of sustainability
requirements to help integrate human rights and sustainability considerations into tenders. It simplifies risk
mitigation by enabling quick matching of product and service categories with their associated sustainability
risks and suggested tender requirements to mitigate these. This encourages Procurement professionals to
deepen their understanding of sustainability issues attached to certain product categories and apply
appropriate requirements early in the tender process.
Furthermore, we conducted workshops focused both on ensuring we execute our existing risk identification
and management activities, as well as identifying opportunities to go beyond mandatory requirements to
further improve our environmental, social, and governance performance in the supply chain. A general human
rights training, including modern slavery, is available to all employees. Our Share and Learn8 sessions with
key suppliers are also part of our capacity building efforts. In 2025 a targeted training addressing risks of
forced labour and exploitation on construction sites was delivered to approximately 200 site managers.
Vattenfall also participated in various seminars and workshops performed together with industry initiatives
and networks like Solar Power Europe, The Swedish Network for Business and Human Rights, the Nordic IT
buyers' initiatives: ATEA Sustainability Focus and ASF Leadership for Change, Wind Europe, the International
RBC Agreement for the Renewable Energy Sector, and the German Energy Industry Dialogue.
8
A Share and Learn session consist on meeting with suppliers with the objective of sharing practices around a specific
relevant topic for both companies.
Accountability
The Group will report regularly and transparently on its approach to addressing modern slavery and human
trafficking annually in conjunction with the publication of the annual report and will include information about:
1. The Group and its supply chain
2. Policies relevant to modern slavery
3. Risk assessment procedures and key risks
4. Due diligence processes applied during sourcing and purchasing activities
5. Progress and effectiveness of efforts to combat modern slavery and human trafficking in the value
chain
6. Training and competence building
Vattenfall’s Board of Directors has a Human Rights update and approval of the Human Rights policy and the
Statement on UK Modern Slavery Act on the agenda every year.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's
slavery and human trafficking statement for the financial year ending 2025-12-31. This statement was
approved by the Board of Directors on 04 February 2026 and is valid for the Group and its subsidiaries,
including the UK subsidiaries listed in the Annex.
Annex – List of UK subsidiaries
Company name Company number
Vattenfall Wind Power Ltd 06205750
Vattenfall Heat UK Limited 02951085
[navn skjult] 05358030
[navn skjult] 04130301
[navn skjult] SC380657
[navn skjult] 04874027
Ourack Wind Farm One Limited 05532689
Ourack Wind Farm Two Limited 05475126
[navn skjult] 04512200
Nuon UK Limited 03446477
Pen Y Cymoedd Wind Farm Limited 03494498
[navn skjult] 06941519
Llanerfyl Access Road Consortium Limited 06118626
East Anglia Offshore Wind Limited 06990367
Ourack Wind Farm LLP SO305106
Aberdeen Offshore Wind Farm Limited SC278869
[navn skjult] 12504538
[navn skjult] SC678840
Muir Mhor Offshore Wind Farm Limited SC717262
[navn skjult] 13876958
[navn skjult] 11652156
Clashindarroch II Wind Farm Limited SC825996
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