Modern Slavery Act
This statement is made in accordance with the requirements of the modern slavery act 2015 (hereinafter referred to as the Act)
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
OEG have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in our own business or in our supply chain. In support of this we have a Supplier Code of Ethics which details our expectations for all members of our supply chain.
Our commitment applies to all persons working for OEG, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. The purpose behind our commitement is to support the elimination of Modern Slavery and fully meet our obligations under the Modern Slavery Act 2015.
Introduction to the ACT
The Modern Slavery Act 2015 is an Act of the Parliament of the United Kingdom. It is designed to tackle slavery in the UK and consolidates previous offences relating to trafficking and slavery. The bill was introduced to the House of Commons in draft form in October 2013 by James Brokenshire, Parliamentary Under Secretary for Crime and Security.
James Brokenshire was quoted as saying that the act will:
"send the strongest possible message to criminals that if you are involved in this disgusting trade in human beings, you will be arrested, you will be prosecuted and you will be locked up."
JURISDICTIONAL REACH OF THE MODERN SLAVERY ACT
The Modern Slavery Act will give law enforcement the tools to fight modern slavery, ensure perpetrators can receive suitably severe punishments for these appalling crimes and enhance support and protection for victims. The Act received Royal Assent on Thursday 26 March 2015 and will;
- consolidate and simplify existing offences into a single act
- ensure that perpetrators receive suitably severe punishments for modern slavery crimes (including life sentences)
- enhance the court’s ability to put restrictions on individuals where it’s necessary to protect people from the harm caused by modern slavery offences
- create an independent anti-slavery commissioner to improve and better coordinate the response to modern slavery
- introduce a defence for victims of slavery and trafficking
- place a duty on the secretary of state to produce statutory guidance on victim identification and victim services
- enable the secretary of state to make regulations relating to the identification of and support for victims
- make provision for independent child trafficking advocates
- introduce a new reparation order to encourage the courts to compensate victims where assets are confiscated from perpetrators
- enable law enforcement to stop boats where slaves are suspected of being held or trafficked
- require businesses over a certain size to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chains
EMPLOYEE RESPONSIBILITY AND HOW TO RAISE A CONCERN
The prevention, detection and reporting of Modern Slavery & Human Trafficing is the responsibility of all employees throughout the OEG Group. If any Employee becomes aware or suspects that an activity or conduct has taken place then it must be reported immediately.
Any such incidents should be reported in accordance the Company's whistle blowing policy (which can be found on the Employee Intranet in the Global QHSE section) or reported directly by email to : john dot heiton at oegoffshore dot com, Group CEO.
It is OEG Group policy to conduct its business in an honest and ethical manner. OEG takes a zero-tolerance approach to Slavery & Human Trafficing and is committed to acting professionally, fairly and with integrity in all of its business dealings and relationships wherever OEG operates. We provide policy awareness training and enhanced training where necessary to ensure that we have a robust system in place to prevent Salvery & Human Trafficking.
We are committed to the prevention, deterrence, detection and we aim to maintain Slavery & Human Trafficking compliance “business as usual”, rather than as a one-off exercise.
The following resource links are provided for our Employees and website visitors to further expand awareness and updates on the latest online information available;
Slavery and Human Trafficking Transparency / Statement for the Financial Year 2016
MODERN SLAVERY ACT TRANSPARENCY STATEMENT
This Statement is made pursuant to Section 54 (Part 6) of the Modern Slavery Act 2015 (‘Act’) and sets out the steps that Northstar Midco Limited has taken during the previous financial year to ensure that slavery and human trafficking is not operating within either its own business or its supply chains.
Northstar Topco Limited and its subsidiaries (“OEG”) support the objectives of the Modern Slavery Act 2015 (“the Act”) of eliminating slavery and human trafficking. This statement sets out action taken to understand and mitigate potential modern slavery risks related to its businesses and put in place steps that are aimed at ensuring there is no slavery and human trafficking in its own business or in its supply chain. This statement is made on behalf of OEG group companies.
Our Company Structure
OEG is a global provider of high quality certified cargo carrying units (CCU’s) to the Offshore Oil & Gas Industry worldwide. OEG has approximately 200 directly employed colleagues worldwide in all the main Oil & Gas markets and have several distribution agency agreements in place for our product range.
Our Supply Chain
OEG procures a range of goods and services from a variety of suppliers. We have undertaken a risk-based approach to the assessment of our business and supply chain, which has involved taking geographical, industry and market factors into account in order to identify categories of supply that may present a higher risk of modern slavery being present.
Our Due Diligence Processes for Slavery and Human Trafficking
In those areas of our businesses where we source goods from countries where modern forms of slavery are more likely to be prevalent we are undertaking the following activities to assess and address this risk:
- Conducting an internal risk assessment to identify which of the Group’s suppliers are most likely to manufacture goods or provide services in countries and/or sectors where instances of modern slavery are more likely to be prevalent.
- Reviewing the Group’s existing contractual arrangements and identifying ways these can be strengthened to further reduce the risk of slavery and human trafficking in our businesses and supply chains.
- Consulting with those suppliers whom we have identified as presenting significant inherent risk in order to understand more about their own businesses, supply chains and the steps they have taken to reduce the risk of slavery and human trafficking.
- Maintain our policies and systems to enable whistleblowing.
Monitoring our Effectiveness in Combating Slavery and Human Trafficking
We will continue to monitor the Group’s businesses and our supply chain to assess ongoing risks and develop measures to further reduce the risk of slavery and human trafficking taking place. We shall use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chain:
- Annual declarations on compliance from our key suppliers
- Completion of supplier audits
- Annual declaration from relevant members of staff on their compliance with our policy and the Act.
Our Continued Commitment
We recognise the importance of maintaining constant vigilance to identify and address any impacts associated with slavery and human trafficking throughout our supply chains. In recognition of these issues, we are committed to continuing to enhance our capacity to identify, prevent and mitigate any impacts in this field. Our various management teams will be required to consider its own supply chain and to assess the level of risk relating to slavery and human trafficking. To this end we will undertake a review and further development of the following areas;
- Review of Modern Slavery Act 2015 training for our own businesses
- Review of existing supplier contractual arrangements
- Develop a Risk based supplier evaluation programme to determine higher risk companies
- Review of new supplier evaluation process and ongoing monitoring
This Statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and sets out OEG’s slavery and human trafficking statement for the financial year ending 31st December 2016.
Northstar Topco Limited (OEG)