Introduction
This statement sets out the Petroplan Group's commitment to:
a) Understanding the potential modern slavery risks related to its business; and
b) Implementing and maintaining company processes to preclude any slavery and human trafficking from occurring within its business and its supply chains.
This statement relates to Petroplan Group business activities during the financial year ending 31st December 2021.
As a member of the recruitment and talent solutions industry, the Petroplan Group recognises its responsibility to take an uncompromising approach to slavery and human trafficking, with zero tolerance for slavery and trafficking of people. The Petroplan Group is committed to not only preventing slavery and human trafficking in its own corporate activities, but also to ensuring, insofar as possible, that its supply chains are free from slavery and human trafficking activities.
Organisational Structure and Supply Chains
This statement covers the activities for the Petroplan Group and its ultimate parent company Petroplan Holdings.
The Petroplan Group has around 100 employees worldwide, supplying talent solutions and recruitment services and managing contractor and permanent placements via our worldwide network of offices throughout Europe, North America, the Middle East, Africa and Asia Pacific. The Petroplan Group is a member of The Association of Professional Staffing Companies (APSCo) and our Business Management system is ISO 9001:2015 accredited. Providing specialist recruitment services exclusively within the oil, gas and energy sector since 1976, the Petroplan Group has exceptional technical expertise and the experience to deliver services in line with our global clients’ expectations.
Our supply chains include, but are not limited to, companies sourcing candidates for our clients. This may involve the introduction of external agencies to the Petroplan Group for onward supply to our clients. We therefore expect our suppliers to operate in a principled, legally compliant and professional manner by adhering to our Supplier Code of Conduct, and to advocate similar standards within their own supply chains. The Petroplan Group relies on its employees to be vigilant in monitoring potential risks, with employees expected to immediately report any concerns, in line with relevant company policies and procedures.
Assessment of Risk
The Group assesses whether or not particular activities or countries are particularly high-risk in relation to slavery and human trafficking. In doing so, consideration is given to the services provided over the duration of the contract and the supply chain involved. Consideration is also given to suppliers’ current compliance through a review of their website, their code/s of conduct and other available information, including:
- A code of conduct that addresses slavery
- Sourcing policies that address slavery
- Demonstrable management processes in place to manage the risk of slavery in their supply chain
- Modern slavery risks or occurrences identified by the media or risk monitoring organisations
Responsibilities
Responsibilities for Petroplan Group’s anti-slavery initiatives are as follows:
- Policies: The CEO is responsible for ensuring Group policies are up to date and reflective of the Modern Slavery Statement.
- Risk assessments: In line with Petroplan’s ISO-accredited integrated Business Management system and as appropriate, the Group undertakes risk assessments in relation to our business activities and suppliers.
- Due Diligence: The Global Head of Compliance and Risk is responsible for ensuring that all the appropriate due diligence is undertaken in respect of identifying any risk of slavery and/or human trafficking within our supply chains.
- Notices: The Petroplan Group Global Head of Compliance and Risk will be accountable for staying up to date in respect of Petroplan’s responsibilities regarding slavery and human trafficking in the supply of services and in receipt of services from suppliers and will disseminate this information to the wider business as appropriate.
Relevant policies and procedures
Petroplan Group’s Guide to Business Conduct sets out the Group’s position on business ethics and its approach to the identification of modern slavery risks and human trafficking and steps to be taken to prevent such activity; some policy extracts are included below:
Whistleblowing and Duty to Report: Petroplan’s Guide to Business Conduct empowers its workers, customers and other stakeholders to report any concerns about the company’s business activities or its supply chains. This includes anything that may increase the risk of slavery and human trafficking. The Petroplan Group’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of any negative consequences.
Human Rights and Labour Policy: Petroplan Group supports and respects the protection of internationally proclaimed human rights for all, including the basic human rights of the employees and workers within our supply chain. We believe in treating people with respect and dignity and do not condone the use of our services to infringe on the basic human rights of others. We expect our suppliers to adhere to these same standards and take reasonable steps to ensure that they do.
Supply Chain: Petroplan Group purchases goods and services from a variety of suppliers (local and international) and we seek to promote the application of our core company values in all our interaction with these suppliers ensuring that the suppliers adhere to the highest ethical standards at all times. We are committed to encouraging suppliers to adopt business policies that align with our Guide to Business Conduct and provide contractual assurances that the same standards will be maintained and adhered to.
In addition to the principles set out in our Guide to Business Conduct, Petroplan Group’s HSEQ & SR Policy, our Employee Handbook and our Risk Assessment Procedure all underpin our commitment to the avoidance of slavery and human trafficking risks within our business. All employees of Petroplan sign a copy of the Employee Handbook confirming they have read and understand its contents at the time of joining the business.
Petroplan audits all policies and procedures annually to ensure they are legally compliant and fit for purpose.
Supplier Code of Conduct
All our suppliers must agree to Petroplan Group’s Supplier Code of Conduct, which provides that they will:
- Refrain from holding any person in slavery or servitude or from enforcing any forced or compulsory labour;
- Not abet or facilitate the trafficking of any persons;
- Not in any way associate with companies using involuntary labour or participating in human trafficking;
- Treat and reward employees equally on the basis of the quality of their work;
- Provide a safe, hygienic and healthy working environment for all employees;
- Provide, as a minimum, rates of pay at national legal standards; and
- Comply with the applicable national and regional laws and regulations at all times.
Due Diligence
The Petroplan Group undertakes the appropriate due diligence in the provision of workers to clients and in working with clients, taking on new suppliers, and monitoring its existing supply chain as appropriate.
The organisation's due diligence process includes the following elements:
- broadly mapping the supply chain to assess the regional risks of modern slavery and human trafficking;
- evaluating the modern slavery and human trafficking risks of each new supplier’s activities; and
- conducting an annual due diligence review for each supplier.
Internal Awareness
General communication of Petroplan Group policies and procedures is facilitated by email, briefings, presentations or classroom training as appropriate.
Specifically, awareness of the Group’s position on modern slavery and human trafficking is communicated to all employees at induction, with Petroplan Group’s policies and procedures in this regard stored centrally on the company’s HR system and required to be signed as an acknowledgement of receipt by all new starters.
This statement has been approved 25th May 2023 by the Petroplan Group Board of Directors, who review and approve the statement annually.
Christopher Honeyman Brown (CEO)
July 2023