Governance

    Corporate policies

    We hold ourselves to the standards we recommend. These policies reflect how we operate, who we are, and the commitments we make to clients, partners, and the communities we work in.

    Anti-Bribery & Corruption Policy

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    Block One Group Ltd has zero tolerance for bribery and corruption in all its forms. This policy applies to all directors, employees, contractors, and anyone acting on our behalf. It is designed to comply with the UK Bribery Act 2010.

    Our commitment

    We will not offer, promise, give, request, or accept any bribe — whether in the form of cash payments, gifts, hospitality, or other inducements — to or from any person or organisation, in any jurisdiction, for any purpose. This applies regardless of local custom or practice.

    Gifts & hospitality

    Modest and proportionate hospitality (such as a working lunch) is acceptable where it has a clear business purpose. Gifts of significant value, cash, or anything that could reasonably be perceived as an inducement are prohibited. Any gift or hospitality offered or received above a nominal value of £50 must be reported to the company's leadership and recorded.

    Facilitation payments

    We do not make or accept facilitation payments of any kind, regardless of local customs or expectations.

    Procurement & tendering

    All procurement and tendering activities are conducted fairly and transparently. We do not seek to influence the outcome of any public or private tender through improper means. Our advisory recommendations are made solely on the basis of client benefit and professional judgement.

    Reporting concerns

    Anyone who suspects bribery or corruption should report it immediately to transform@blockonegroup.co.uk. Reports can also be made via our Whistleblowing Policy. All reports will be investigated and treated in confidence. No one will suffer retaliation for raising a genuine concern in good faith.

    Modern Slavery & Human Trafficking Statement

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    Block One Group Ltd is committed to preventing modern slavery, human trafficking, and forced labour in our business and supply chains. This statement is made in line with the Modern Slavery Act 2015 and reflects our values as a responsible business.

    Our business

    Block One Group Ltd provides energy, strategy, and technology advisory services. Our operations are UK-based, with a small team of senior professionals. We engage a limited number of specialist subcontractors and technology suppliers.

    Our supply chain

    Our supply chain is relatively contained, consisting primarily of professional services, technology platforms, and office facilities. We assess the risk of modern slavery across our supply chain as low, but we remain vigilant and do not take this for granted.

    Our policies

    We operate with clear policies on ethical conduct, whistleblowing, and complaints handling. Our recruitment and employment practices are transparent, and we ensure all team members are paid fairly and work in safe conditions. We do not use agencies that cannot demonstrate compliance with employment law.

    Due diligence

    We conduct proportionate due diligence on new suppliers and subcontractors, including reviewing their employment practices. We expect any third party acting on our behalf to share our commitment to preventing modern slavery.

    Reporting

    Any concerns about modern slavery in our business or supply chain should be reported to transform@blockonegroup.co.uk. All concerns will be taken seriously and investigated.

    Environmental & Sustainability Policy

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    Sustainability is not a side project at Block One — it is embedded in the work we do. We advise clients on energy strategy, net zero roadmaps, and infrastructure investment, and we hold ourselves to the same standards we recommend.

    Our approach

    We integrate environmental considerations into our advisory work, helping clients make sustainable choices that are also commercially sound. We advocate for energy efficiency, decarbonisation, and responsible resource use in every engagement.

    Our operations

    As a professional services firm, our direct environmental impact is modest. We minimise our footprint by operating from shared, energy-efficient office space; using digital-first communication to reduce unnecessary travel; offsetting travel emissions where feasible; and continually reviewing our suppliers and tools for environmental credentials.

    Continuous improvement

    We review our environmental practices annually and set targets to reduce our operational impact. We are transparent with clients and stakeholders about both the progress we've made and the areas where we can do better.

    Client impact

    The greatest environmental contribution we make is through the advice we deliver. Our strategic reviews, energy procurement, and investment cases consistently drive energy efficiency improvements and carbon reduction across client portfolios.

    Equality, Diversity & Inclusion Policy

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    Block One Group Ltd is committed to creating an environment where everyone is treated with dignity and respect. We believe diverse perspectives lead to better outcomes for our clients and our business.

    Our commitment

    We are committed to equality of opportunity in all aspects of our work — including recruitment, development, promotion, and client service. We do not tolerate discrimination, harassment, or victimisation on the basis of age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation.

    Recruitment & employment

    All recruitment and employment decisions are made on the basis of merit, capability, and potential. We actively seek to build a team that reflects a range of perspectives, experiences, and backgrounds.

    Inclusive culture

    We foster a culture of openness and mutual respect. Every team member is expected to contribute to an inclusive working environment. Inappropriate behaviour is addressed promptly through our internal procedures.

    Client & supplier relationships

    We apply the same principles of fairness and inclusion to our relationships with clients, suppliers, and partners. We expect those we work with to share our commitment to treating people fairly.

    Monitoring & review

    We monitor the effectiveness of this policy and review it annually. We welcome feedback from our team and stakeholders on how we can continue to improve.

    Whistleblowing Policy

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    Block One Group Ltd encourages a culture of openness and accountability. This policy provides a safe and confidential channel for anyone to raise concerns about wrongdoing, malpractice, or unethical conduct without fear of retaliation.

    Scope

    This policy applies to all directors, employees, contractors, and third parties working with or on behalf of Block One Group Ltd. It covers concerns about illegal activity, financial malpractice, health and safety risks, environmental damage, bribery or corruption, fraud, modern slavery, and any attempt to conceal wrongdoing.

    How to raise a concern

    Concerns should be reported in writing to transform@blockonegroup.co.uk with the subject line 'Whistleblowing Report'. Include as much detail as possible, including dates, individuals involved, and any supporting evidence. You may raise concerns anonymously, although providing your identity allows us to investigate more effectively and keep you informed.

    Protection

    No one will be penalised, dismissed, or subjected to any detriment for raising a genuine concern in good faith — even if the concern turns out to be unfounded. We treat victimisation of a whistleblower as a serious disciplinary matter.

    Investigation

    All concerns are taken seriously and investigated promptly. Investigations are conducted by a senior member of the team who is independent of the matter being reported. We aim to provide an initial response within 10 working days, confirming that the concern has been received and outlining the next steps.

    External reporting

    If you feel unable to raise your concern internally, or are not satisfied with how it has been handled, you may contact the relevant prescribed body. For financial or corporate misconduct, this may be the Financial Conduct Authority (FCA). For health and safety, the Health and Safety Executive (HSE). For environmental concerns, the Environment Agency. For data protection, the Information Commissioner's Office (ICO).

    Conflicts of Interest Policy

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    Integrity and independence are foundational to how Block One operates. As a customer-side advisory, our clients trust us to act in their interests — not our own. This policy ensures that trust is never compromised.

    Our position

    Block One Group Ltd acts exclusively on behalf of its clients. We do not hold equity, commission arrangements, volume agreements, or referral incentives with energy suppliers, technology vendors, or any other party that could influence our advice. Where a client chooses to pay us via their supplier rather than on invoice, this is at the client's discretion and does not change the advice we give.

    Identifying conflicts

    A conflict of interest arises when a personal, financial, or commercial interest — whether actual, potential, or perceived — could compromise the objectivity of the advice or services we provide. All team members are required to identify and declare any situation that could give rise to a conflict.

    Declaration & management

    Any actual or potential conflict must be reported to the company's leadership immediately. We maintain a register of declared interests which is reviewed regularly. Where a conflict is identified, we will take appropriate action — which may include reassigning work, adjusting team composition, or in exceptional cases, declining the engagement.

    Client disclosure

    Where a conflict cannot be fully eliminated, we will disclose it to the affected client in writing and agree an appropriate course of action before proceeding. Transparency is non-negotiable.

    Annual review

    This policy and the conflicts register are reviewed annually. All team members are required to reconfirm their declarations at each review.

    Cyber Security & IT Governance Policy

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    Block One Group Ltd is committed to protecting the confidentiality, integrity, and availability of our systems, data, and client information. We align our security practices with the UK Government's Cyber Essentials framework and continuously review our posture as our business evolves.

    Our commitment

    We treat cyber security as a core business responsibility, not an afterthought. Our goal is to achieve and maintain Cyber Essentials certification, demonstrating to clients and partners that we meet a recognised baseline of cyber hygiene across our operations.

    Scope

    This policy covers all devices, systems, cloud services, and data used in the delivery of our advisory services — including laptops, mobile devices, email, cloud storage, and any third-party platforms integrated into our workflows.

    Access control

    Access to systems and data is granted on a least-privilege basis. All accounts use strong, unique passwords and multi-factor authentication (MFA) where available. User access is reviewed regularly and revoked promptly when no longer required.

    Device & software security

    All devices used for business purposes run supported operating systems with automatic security updates enabled. We maintain endpoint protection (antivirus/anti-malware) on all devices and ensure only approved, licensed software is installed.

    Firewalls & network security

    Internet-facing services are protected by properly configured firewalls. Default passwords on network equipment are changed on deployment. We regularly review firewall rules and disable unnecessary services and ports.

    Secure configuration

    Systems are configured securely from deployment. We remove or disable unnecessary software, accounts, and services. Administrative privileges are restricted to authorised personnel and used only when required.

    Incident response

    We maintain an incident response process to identify, contain, and recover from security incidents. Any suspected breach or security event must be reported immediately to transform@blockonegroup.co.uk. We will notify affected parties and relevant authorities in accordance with UK data protection law.

    Training & awareness

    All team members receive regular guidance on cyber security best practices, including phishing awareness, password hygiene, and safe handling of client data. Security awareness is part of our onboarding process.

    Supply chain security

    We assess the security practices of key suppliers and technology partners. Where feasible, we select providers that hold recognised certifications such as Cyber Essentials, ISO 27001, or SOC 2.

    Complaints Handling Policy & Procedure

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    Block One Group Ltd takes complaints seriously and is committed to resolving them fairly, transparently and promptly. This policy complies with Ofgem's regulatory framework for Third Party Intermediaries (TPIs) and explains how to raise a concern, how we will respond, and how to escalate if you remain dissatisfied. The full procedure and online complaint form are available at blockonegroup.co.uk/complaints.

    Our commitment

    Every complaint is investigated objectively by someone not involved in the matter being raised. We acknowledge complaints within 5 working days and aim to resolve them within 20 working days — keeping you informed if a complex case requires longer. There is no cost to you for using our internal process or any external escalation route.

    How the process works

    1) Submit your complaint by form at blockonegroup.co.uk/complaints, email to transform@blockonegroup.co.uk, or post to our Cardiff office. 2) We acknowledge in writing within 5 working days, confirming who is handling it. 3) We investigate thoroughly and impartially. 4) We provide a full written response within 20 working days, setting out findings and any remedial action. 5) If you remain dissatisfied, you may escalate (see external escalation below).

    External escalation

    If you remain dissatisfied after our final response, or if 8 weeks have passed without resolution, you may refer your complaint to an independent Alternative Dispute Resolution (ADR) scheme. For microbusiness customers, this is the Energy Ombudsman — a qualifying dispute settlement scheme (QDSS) approved under Ofgem's framework. Website: www.energyombudsman.org · Email: enquiry@energyombudsman.org. Making a complaint through our internal process or to an ADR scheme does not affect your right to seek independent legal advice or take action through the courts.

    Who can complain & what about

    Any person or organisation that has received, or sought to receive, a service from Block One Group Ltd may raise a complaint — including current and prospective clients, their representatives, and any third party materially affected. You may complain about any aspect of our service, including the quality of advice, the conduct of our team, transparency of fees or commissions, the procurement process, communication, or any matter where you believe you have experienced detriment as a result of our actions or omissions.

    Vulnerability & confidentiality

    If you need additional support — alternative formats, additional time, or a representative to act on your behalf — please let us know and we will make reasonable adjustments. All complaints are treated in confidence and shared only with those directly involved in investigating and resolving them, or as required by law. No client or third party will be penalised for raising a genuine complaint in good faith.

    Record keeping & continuous improvement

    We retain records of all complaints, investigations and outcomes for a minimum of 6 years and make them available to regulatory authorities upon request. Complaint trends are reported to senior management regularly and used to drive service improvements. This policy is reviewed annually.

    All policies last reviewed: 8 March 2026

    Next scheduled review: March 2027

    These policies are reviewed annually or sooner if required by changes in legislation, regulation, or business operations. Policy queries should be directed to transform@blockonegroup.co.uk.

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