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 commitment 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 and was quoted 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 Trafficking 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 Trafficking 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 Slavery & 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;
This statement is made in accordance with the requirements of the modern slavery act 2015 (hereinafter referred to as the act)
Slavery and human trafficking transparency statement for the financial year 2017
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 (OEG) 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. At OEG we respect human rights and do not tolerate any form of modern slavery. We recognise that no supply chain is without risk of modern slavery and it is our responsibility to ensure we understand these risks and work in partnership with our suppliers to mitigate them.
Northstar Midco 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 are no slavery and human trafficking in its own business or in its supply chain. This statement is made on behalf of the following OEG group companies;
- Northstar Midco Limited
- Northstar Investments Limited
- Northstar Holding Limited
- Offshore Container Holdings Limited
- OCHL (Globe) Limited
- OEG Offshore Limited
Our Company Structure
OEG Offshore Group is headquartered in Aberdeen, Scotland and was established in January 2010. 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, we serve over 500 customers in 41 countries and have hub locations in all the main Oil & Gas markets. We also operate several distribution agency agreements with key country partners for our product range. OEG has developed and international reputation for quality, safety and providing cost effective offshore container and modular solutions for our global customers from our operations in the UK, Europe, North America, Caribbean, Africa, Caspian, Middle East, Asia Pacific, Australia and New Zealand.
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 Modern 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:
- 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;
- 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;
- Maintain our policies and systems to enable whistle-blowing;
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 declaration from senior management on their compliance with our policy and the Act;
- Annual declarations on compliance from our key / critical suppliers;
- Completion of supplier audits;
- Our Continued Commitment to develop new methods of raising awareness within OEG and our supply chain.
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;
In January 2017, we established our Modern Slavery Act Policy Statement which details OEG’s approach to fulfilling its commitment to support the elimination of Modern Slavery and fully meet its obligations under the UK Modern Slavery Act 2015. This policy is now part of our Global management system which is a Group mandatory requirement for all group companies. In 2018 we introduced a global monthly campaign of awareness posters to ensure that this critical area in our business is at the forefront of our minds worldwide. This was established as an ongoing method of connection to all our employees providing updated information and factual reminders across our Global business units. In 2016 specific reference to the Modern Slavery Act 2015 was added to our Whistle blowing Policy which has been posted on our website to raise awareness on how anyone can raise a concern.
Review of existing and new supplier contractual arrangements, evaluation process and monitoring;
We measure our effectiveness in ensuring that slavery and human trafficking are not taking place in our business or supply chains in a number of ways. As part of our supplier engagement campaign we have integrated Modern Slavery Act clauses within our contracts and our new supplier enrolment forms and in January 2017 we introduced a Suppliers code of ethics policy. This new policy covers commitments against corrupt practices and commitments to ethical and environmental standards. The policy is based on statutory requirements and internationally recognised standards set out in the UN Universal Declaration of Human Rights, the International Labour Organisation Conventions and the Modern Slavery Act 2015. This Code relates to suppliers to our local & global operations and exists to protect the relationship and to help us set out the OEG high standards of expectations. Further monitoring continues to be undertaken during key/critical supplier audits.
It is important that we continually develop and improve our awareness, understanding and performance in relation to human rights and modern slavery and will report on our progress each year. In addition we will specifically look at integrating the following elements within our business and provide feedback on next years statement;
- We will increase our modern slavery and human trafficking training/awareness across our business through the introduction of global campaigns including posters and online training for all our staff. It is also important that our senior management are provided with an advanced level of training in order to provide guidance and information to employees or suppliers if necessary.
- This coming year we plan to strengthen the ethical questions we discuss with existing key critical suppliers. We are looking at incorporating specific questions on modern slavery and human trafficking during our onsite quality audits in order to enforce awareness that their business is an extension of the OEG business. We will develop questions to be more in depth, with fewer ‘yes’ or ‘no’ responses, which we hope will give us more detail on each of our key critical suppliers.
- Encourage our own staff and suppliers to use the STOP APP where we are operating in higher risk environments. It’s the first app of its kind to combine community empowerment, big data management and anti-trafficking expertise to disrupt and prevent human trafficking. (https://www.stopthetraffik.org)
- We want to increase awareness of our whistleblowing policy and to create a culture where anyone who is worried about an ethical issue feels confident to speak up about it, even if they just have a suspicion. They can report their concerns on the phone or online through our website – anonymously if they prefer (subject to local laws). It’s open to employees, contractors and suppliers
In summary, we will work towards achieving;
|Make our Governance Stronger||Improve Awareness||Collaborate More||Check our Approach|
|Strengthen our Supplier questionnaire and evaluation criteria||Provide advance training to our senior management on modern slavery||Use online resources to ensure that we are sharing up to date and relevant information on Modern Slavery to all our staff||Monitor our Suppliers and report our findings|
|Update our supplier code of ethics||Launch a global poster campaign on Modern Slavery to all staff||Encourage sharing of lesson learnt from our suppliers and other companies||Check our Modern Slavery policy is reflecting our approach|
|Ensure that we have Modern Slavery clauses incorporated across all procurement activities||Engage with suppliers on Modern Slavery during Audits|
|Increase awareness of our whistleblowing policy|
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 2017 and is approved by the Board.
Northstar Midco Limited (OEG)
John Heiton – Chief Executive Officer