Brandel Marine Modern Slavery
Act Statement

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Brandel Marine Limited and its subsidiaries (“Brandel Marine”) have taken and will continue to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labor. Brandel Marine has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Policies and Procedures

We operate a number of internal procedures to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Code of Business Conduct and Ethics. Our Code explains the manner in which we behave as an organization and how we expect our employees and suppliers to act.
  2. Compliance Hotline. We operate a Compliance Hotline so that all employees and contractors know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
  3. Supplier Approval Policy. Brandel Marine operates a Supplier Policy and maintains an approved supplier list. We conduct due diligence on certain high risk suppliers, before partnering with them.
  4. Due Diligence Procedure. Our due diligence process includes research and inquiries to ensure that a particular organization has never been convicted of offenses relating to modern slavery.

Operations

Brandel Marine operations are managed in accordance with fundamental labor standards and we follow a practice that conforms to international standards for human rights.

In addition, we ensure that each contract contains appropriate compliance language to prevent modern slavery, including references to the Modern Slavery Act and Maritime Labor Convention, where applicable.

Training

Brandel Marine continues to incorporate training on topics such as Anti-Corruption, Human Rights Laws and the Modern Slavery Act into its compliance training program.

Modern Slavery Act Statement

December 30,2018

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