Modern Slavery Act

SONI Statement on the Prevention of Slavery & Human Trafficking – 2026

Introduction

This is SONI Limited’s (“SONI” or “the Company”) Modern Slavery Statement, developed in accordance with section 54 of the Modern Slavery Act 2025 which applies to the financial year ending 30^th September 2025.^

Organisation Structure & Supply Chains

SONI is the licenced electricity transmission system operator for Northern Ireland. We operate the electricity transmission system in Northern Ireland and plan for its future. We do not generate or sell electricity. Our role is to ensure that power can flow safely, securely and reliably from where it is generated to where it is needed.

SONI is a subsidiary of EirGrid plc and is an independent business with its own Board of Directors, management and staff in accordance with its Transmission System Operator Licence.

SONI is also the licenced Single Electricity Market Operator (SEMO) in Northern Ireland. The SEM is the all-island wholesale electricity market jointly operated by SONI and EirGrid plc as a contractual joint venture.

Additionally, SONI is a designated Nominated Electricity Market Operator (NEMO) for Northern Ireland and through a contractual joint venture between the Company and EirGrid plc, implement the NEMO services in the SEM through SEMOpx, and administers the Capacity Market Code, through the Capacity Market Code joint venture. SEMOpx provides day-ahead and intraday electricity market trading for Ireland and Northern Ireland as part of the Single Electricity Market.

SONI’s customers include electricity demand and generation suppliers, wholesale market participants, customers seeking demand or generation connection to the grid and landowners and the communities in which the infrastructure is located.

As all the Company’s business is undertaken in Northern Ireland, SONI considers that the risk of modern slavery is more likely to arise from its supply chain than from its own operations. Suppliers of goods/services to the Company are predominantly based in the UK and EU and are not considered to be at risk of modern slavery or human trafficking.

The Board recognises the key role suppliers play in ensuring the Company delivers its strategy with the provision of essential goods and managed services to the business. The Company’s procurement practices are governed by the Utilities Contracts Regulations 2016.

Policies

The Board, the Chief Executive and the Executive Team are committed to upholding and respecting all aspects of human rights including ensuring that slavery and human trafficking is not taking place in our business or any of our supply chains.

SONI.’s Anti-Bribery & Corruption Policy sets out the Company’s “position on bribery, corruption (including modern slavery/human trafficking) and provides guidance on recognising bribery and corruption in its various guises” and is applicable to “all persons working for SONI or on its behalf in any capacity, including employees at all levels, Board Members, employees, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with SONI, wherever located.”

The key purpose of the Anti-Bribery & Corruption Policy is to:

Set out the six key principles of bribery prevention;
Set out the responsibilities in observing and upholding SONI Ltd’s position on bribery, corruption and human trafficking; and
Provide information and guidance to those working for and on behalf of SONI Ltd, on how to recognise and deal with bribery, corruption and human trafficking issues.

SONI takes a zero-tolerance approach to modern slavery, bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever the Company operates and implement and enforce effective systems to counter bribery and corruption.

Additional Company Policies which are considered relevant to the management of modern slavery related risks faced by SONI include:

Employee Code of Conduct;
Anti-Fraud Policy;
Hospitality, Gifts & Entertainment Policy; and
Whistleblowing Policy.

All the above policies are available on the staff intranet.

Due Diligence

During 2025, SONI has continued to take the following steps to mitigate the risk of modern slavery/human trafficking from occurring within its supply chains:

The Company’s Governance, Risk & Compliance (GRC) function performed a risk assessment review of our key suppliers by value based on both geographical area and information available on their approach to modern slavery/human trafficking to ensure that controls are in place and to understand how effective these controls are to ensure that modern slavery does not exist within the Company’s supply chain. No issues or incidents were identified.
Embedding Modern Slavery/Human Trafficking monitoring obligations and red flags within our Anti-Bribery & Corruption Policy.
Procurement Procedures requiring “that all suppliers who participate in a formal tender process adhere to all statutory obligations under current Occupational Health & Safety, Environmental Management, Employment and Equality Legislation and the Modern Slavery Act.”
Supplier Terms & Conditions which require all suppliers of goods and services to demonstrate compliance with governing laws, anti-bribery and anti-corruption regulations.

Risk Assessment & Management

The continued application of the Company’s Enterprise Risk Management Framework enables the Company to continually identify, assess and respond to any risks associated with slavery/human trafficking and continue to assess the risk environment to ensure our controls remain fit for purpose.

KPIs

KPIs used within the Company during the year to assist in measuring the risk of modern slavery related exposure are:

Fraud Incidents; and
Whistleblowing Incidents.

The above KPIs were reported to the Audit & Risk Committee on a quarterly basis.

Training

Ethics Related Policy Framework

During the year, the SONI Board reviewed and approved the following ethics-related policies in support of embedding an appropriate ethical culture:

Directors’ Code of Conduct;
Anti-Bribery & Corruption Policy;
Anti-Fraud Policy;
Hospitality, Gifts & Entertainment Policy; and
Whistleblowing Policy.

The suite of ethics related policies was communicated to all employees by the Company’s GRC function.

New Employees

Additionally, all new employees are provided with training on the Company’s Ethics Related Policy Framework in the first quarter of their employment commencing. The Company’s GRC function oversees the delivery of the training and reports compliance levels quarterly to the Executive Team and Audit & Risk Committee. 100% of all new employees completed this training during 2025.

Focused Training

During 2025, accredited Modern Slavery & Human Trafficking awareness training was provided to a focused group of employees operating in key areas in the business, specifically, People & Place, Procurement, GRC and Legal Services.

Continuous Improvement

We shall continue to promote awareness of our responsibility through the application of the ethics related policy framework.
We shall continue to monitor our key suppliers to ensure that controls are in place and to understand how effective these controls are to ensure that modern slavery does not exist within the Company’s supply chain.
We shall expand the delivery of focused awareness training to employees operating in Network Projects.
We shall deliver general awareness training to all employees.

This statement was approved by the SONI Board on 10^th March 2026.

Previous Modern Slavery Statements may be viewed in the UK Modern Slavery Register at the following links: