Policies & procedures
Modern Slavery Statement
This document covers all four family companies: ICD Energy Managers Ltd, PEP Energy, PEP-ICD Energy Managers Ltd and Cumbria Utilities Ltd.
This statement is made in the spirit of section 54 of the Modern Slavery Act 2015. Although none of the companies within our family currently meets the £36 million turnover threshold at which a statement becomes mandatory, we publish one voluntarily because we believe transparency about how we run our business — and who we do business with — should not depend on company size.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking. We have a zero-tolerance approach to modern slavery in any part of our business or our supply chains.
Who this statement covers
This statement is made on behalf of all four companies in the PEP ICD family:
| Company | Registration | Location |
|---|---|---|
| ICD Energy Managers Ltd | Company no. 13138824 | Newcastle Upon Tyne |
| PEP Energy | — | Kendal, Cumbria |
| PEP-ICD Energy Managers Ltd | Company no. 14837509 | Newcastle Upon Tyne |
| Cumbria Utilities Ltd | Company no. 12341513 | Kendal, Cumbria |
References to "we", "us" and "our" in this statement are to all four companies collectively.
Our business and supply chains
We are an industrial and commercial energy consultancy specialising in risk-managed procurement, market intelligence and contract management for high-consuming businesses across the UK. Our workforce is office-based, directly employed and UK-resident.
Our supply chains are short and predominantly professional in nature. They consist principally of:
- UK-licensed energy suppliers with whom we arrange contracts on behalf of clients
- Providers of market data, analytics and software services
- Our managed office provider and associated facilities services
- Professional services such as accountancy, legal and IT support
We assess the overall risk of modern slavery within our own operations and immediate supply chains as low. We recognise, however, that risk is never zero — particularly in facilities services and in the extended supply chains of the energy industry — and this statement reflects the steps we take in response.
Our policies
We operate the following policies that support the identification and prevention of modern slavery:
- Recruitment. We employ directly, verify the right to work of every employee, and pay all staff above the Real Living Wage. We do not use agency labour.
- Procurement. We expect suppliers to comply with all applicable laws, including the Modern Slavery Act 2015, and reserve the right to terminate any relationship where concerns cannot be resolved.
- Whistleblowing. Staff are encouraged to raise concerns about any wrongdoing, including modern slavery, without fear of detriment.
- Anti-bribery. Our Anti-Bribery Policy supports honest and transparent dealing throughout our business relationships.
Due diligence
When engaging new suppliers, and periodically for existing suppliers, we:
- Confirm the supplier is a registered UK entity or an established provider with a published modern slavery statement where the Act requires one
- Consider the sector, geography and workforce profile of the engagement for indicators of elevated risk
- Build the right to terminate for non-compliance into contractual arrangements where practicable
The energy suppliers we work with are licensed by Ofgem and are, in almost all cases, large organisations that publish their own statements under the Act. We take these into account when reviewing our panel.
Risk assessment and effectiveness
Given the size and nature of our business, we keep our assessment deliberately simple: an annual review of our supplier base against sector and geographic risk, alongside any concerns raised during the year. No instances or suspicions of modern slavery have been identified in our business or supply chains to date. If that changes, we will report it, act on it and say what we did.
Training and awareness
All staff are made aware of this statement and of the indicators of modern slavery relevant to our supply chains as part of their induction, with periodic refreshers for those involved in procurement decisions.
Review
This statement is reviewed annually and was last reviewed in July 2026. Questions about it should be sent to enquiries@icdenergymanagers.com.