COMPANY POLICY

    Environmental Policy

    Last reviewed 24 August 2026 · Next review August 2027

    Spiral Renewables designs, procures and delivers electrical infrastructure for electric vehicle charging — principally on operating petrol filling stations and forecourt sites, and on connections for commercial and industrial customers.

    That work involves excavation and ground works, the installation of electrical plant, and the movement of people, vehicles and equipment to sites across the UK. This policy sets out how we manage its environmental consequences. It applies to everyone who works for us or on our behalf, including subcontractors.

    We are building an environmental management system aligned to ISO 14001:2026 and are working towards independent certification.

    Our commitments

    Protecting the environment. We prevent pollution, protect the ground and water environment on and around the sites where we work, use resources efficiently, and reduce our impacts wherever it is within our control to do so.

    Meeting our compliance obligations. We identify and comply with the environmental legislation, permits and codes of practice that apply to our activities, and with the environmental requirements our clients place on us.

    Continually improving. We set, monitor and review environmental objectives, and we improve our performance year on year.

    Considering climate change. We treat climate change as part of the context we operate in — both our contribution to it and its consequences for our operations and our clients' assets.

    Holding our supply chain to the same standard. We require subcontractors and suppliers to work to environmental standards no lower than our own, and we verify this rather than assume it.

    Being open about performance. We report honestly on how we are doing, including where we fall short.

    Where our impact is greatest

    Ground works on operating fuel sites

    This is the most significant environmental risk we carry. Soils around fuel storage and dispensing infrastructure may be impacted by hydrocarbons, and excavation can both expose contamination and create pathways to groundwater and site drainage.

    We treat arisings from forecourt excavation as potentially hazardous until testing shows otherwise. Soil and stones from this work fall under mirror entries in the List of Wastes, and we classify them in line with Environment Agency guidance WM3 before any material leaves site. We do not allow arisings to be removed on the assumption that they are inert.

    Where we find contamination that was not anticipated, we stop work in that area, secure it, and notify the site operator and client before going further.

    Equipment, cable and metals

    End-of-life charge points, enclosures, switchgear and transformers are segregated as WEEE rather than entering general waste. Cable and metal offcuts are recovered through licensed reprocessors, and oils and dielectric fluids are drained and consigned as hazardous waste under controlled conditions.

    Fleet, plant and travel

    Our direct emissions come mainly from vehicles, site plant and business travel. We are transitioning our light fleet to electric, favouring grid, battery or lower-carbon fuelled plant over diesel generation, storing fuel in compliant bunded containment, and reducing avoidable travel through planning and remote working where it does not compromise site safety or quality.

    Waste and duty of care

    We are a waste producer and we accept the duties that carries under section 34 of the Environmental Protection Act 1990. We classify waste correctly before it moves, use only registered carriers and permitted facilities — checking registrations rather than taking them on trust — and keep the records the law requires. We are preparing for mandatory digital waste tracking as it comes into force across the UK.

    Responsibility

    The Managing Director holds ultimate responsibility for environmental performance and approves this policy. Project and site management implement it on their projects. Everyone working for us or on our behalf is expected to follow it — and to stop work and escalate if they believe environmental harm is being caused or is likely.