Modern Slavery and Human Trafficking Policy Statement

Adopted by the Board of Directors on 20 May 2017

  1. This policy applies to all directors, officers and employees of both Lamprell plc (the Company) and its various subsidiary or affiliated companies (the Group). The Company understands the risks around modern slavery and fully supports the Modern Slavery Act 2015. This Policy Statement for the FY2016 is a demonstration of that support and the Company aims to identify our responsibility by alerting staff to the risks of such practices in its business and in its wider supply chain, and to prevent them.
  2. The Group is a leading provider of diversified fabrication, engineering and contracting services to the onshore and offshore oil & gas and renewable energy industries, with the majority of our activity taking place in the United Arab Emirates (UAE).
  3. We will not tolerate any slavery or human trafficking within our business operations and we take a risk-based approach to procurement activities through our supply chain. Our procurement activities are aligned to the Company’s values and to the laws of the countries in which we operate. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chain.
  4. This Policy Statement takes into account, and supports, the Group’s policies, procedures and requirements as documented in the Lamprell HSES Management System, which is compliant with the requirements of ISO 9001:2015, ISO 14001:2015 and OHSAS 18001:2007. Together with the Lamprell Business Code of Conduct, implementation and operation of our HSES MS underpins our commitment to this Policy Statement and management will ensure that this is understood and communicated to employees at all levels within the Group, as well as being regularly reviewed by the Directors to ensure its continuing suitability and relevance to the Company’s activities at the highest levels.
  5. Our Business Code of Conduct outlines our commitment to uphold ethical business practices and to meet or exceed applicable legal requirements. It applies to all of our employees, directors, officers, contractors and suppliers. For all our goods and services, we engage our suppliers through relevant contractual arrangements, applicable regulatory frameworks, our core values and our Business Code of Conduct.
  6. We will deliver on these aims by identifying and mitigating the risk of modern slavery and human trafficking in the following ways (but not limited to):
    1. Zero tolerance towards slavery and human trafficking by the Group and in our supply chain;
    2. Effective and fit-for-purpose due diligence and testing of our contractors and suppliers, in terms of policies, practices and contracts;
    3. Flow-down of contractual obligations to ensure that all those participating in our supply chain will comply with our values and zero tolerance in this regard;
    4. Regular auditing & review of practices to confirm that employees within the Group and contracting staff in the supply chain are paid a wage and benefits in compliance with the national legal standards as a minimum, and preferably at higher levels (and are paid with any applicable wage protection system);
    5. Compliance by our suppliers with (i) safe and healthy working facilities and appropriate measures & systems to maintain that; (ii) HSE training for employees; and (iii) all applicable legislation to provide a safe and healthy workplace; and
    6. Use of a whistleblowing policy and hotline to encourage the reporting of concerns and to protect whistleblowers.
  7. To ensure a high level of understanding, we make training on the risks of modern slavery and human trafficking in our supply chains and our business available to relevant members of staff. All Directors have been briefed on the subject.
  8. We will use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business:
    1. Completion of audits by Procurement & Supply Chain Dept., Internal Audit and/or the HSES Dept.;
    2. Use of labour monitoring and payroll systems; and
    3. Robust communication with key contacts at our suppliers to confirm their understanding of, and compliance with, our expectations around this Policy Statement.
  9. For transparency the Company will publish this Modern Slavery & Human Trafficking Policy Statement on its website for all stakeholders including the employees, clients, suppliers and/or investors to inspect.
  10. Staff are expected and encouraged to report concerns to management, where they are expected to act upon them. Failure to comply with this Policy Statement may result in internal disciplinary action. It may also mean that you have committed a civil and/or criminal offence.
  11. If there are any questions about this Policy Statement at any particular time, please contact the Group’s Company Secretary.