1.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.

2.

The Lamprell Group 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 putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

3.

This policy statement is made pursuant to the UK’s Modern Slavery Act 2015 (the Act) and sets out the steps that we, the Lamprell Group, have taken and will be taking to ensure that slavery and human trafficking is not taking place in any part of our business or our supply chain. It applies directly to all directors, officers and employees of both Lamprell plc (the Company) and its various subsidiary or affiliated companies (the Group) and those whom the Company appoints to act on its behalf. The Company understands the risks around modern slavery and fully supports the Act and this statement for the 2020 financial year sets out how we communicate and implement the principles of that support.

4.

The Group is a leading provider of diversified fabrication, engineering and contracting services to the onshore and offshore renewable energy and oil & gas industries. Our workforce levels can vary depending on the number of active projects but, as at 31 December 2020, there were around 5,000 people working for the Group. The vast majority of our business activities and our workforce are located in the United Arab Emirates.

5.

Our Business Code of Conduct (the Code) is a governing document that 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 and those whom the Company appoints to act on its behalf, and is applicable wherever in the world we are operating and whatever we are working on. For all our goods and services, we engage our suppliers through relevant contractual arrangements, applicable regulatory frameworks, our core values and the Code.

6.

Lamprell has five core values – Safety, Integrity, Fiscal Responsibility, Accountability and Teamwork; they define our culture, what it means to work for Lamprell and are a consideration in our everyday decisions and actions. Management communicates the importance of the core values to the wider workforce on a regular basis. At all times, employees are expected to demonstrate behaviours consistent with our values.

7.

Creating and developing the right culture is another important aspect to our business model. Our purpose, values and resulting culture are interdependent and we are proud of the culture that exists at Lamprell. Our values define our behaviours and frame the everyday business decisions based on a culture of honesty, curiosity and high performance. We are driven by open communication; we ask our workforce to be enquiring and to challenge the way things are done. Above all, we aim to deliver safe, high-quality products and services – the stronger our performance, the more we can accomplish, so we want our employees to excel and we want to recognise their achievements.

8.

We will not tolerate any slavery or human trafficking within our business operations and we take a risk-based approach to manpower supply, procurement and subcontract activities through our human resource and supply chain departments. We have in place systems to identify and assess potential risk areas in our supply chain and to mitigate any identified areas of risk. Our employees, suppliers and contractors are also encouraged to report any concerns that slavery or human trafficking may be, or is, taking place. An area of focus for us is on the management of our agency partners to ensure full compliance with the principles and intent of this statement, particularly with the additional challenges presented in 2020 with the spread of the COVID-19 virus and its impact on workers (see below). 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 are not taking place in our supply chain.

9.

This statement takes into account, and supports, the Group’s policies, procedures and requirements as documented in the Lamprell HSES Management System (HSES MS), which is compliant with the requirements of ISO 9001:2015, ISO 14001:2015 and the new global safety management system standard ISO 45001:2018. Together with the Code, implementation and operation of our HSES MS underpin our commitment to this 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..

10.

We will deliver on these aims by identifying and mitigating the risk of modern slavery and human trafficking in the following ways, among others:

11.

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.

12.

COVID-19 has forced changes in industrial businesses, including at Lamprell, and at a pace nobody could have possibly foreseen. The dedication and resilience of our personnel to respond to multiple, constantly-changing and complex challenges resulting from the pandemic has been exceptional. It has affected every aspect of our business and especially our workforce. The Group has also endeavoured to continuously engage with all major parts of its supply chain during the year, to ensure we continued to deliver for our customers.

13.

Our yard employees have been required to go through vigorous health checks, in particular when the pandemic first hit and also during 2H when construction on our ongoing major projects started in earnest. Where an employee was found to have COVID-19 or have been in close contact with someone who had it, we undertook rigorous testing and tracing, established isolation blocks and required affected staff, as well as their close contacts, to undergo strict quarantine periods to ensure their safety and that of those around them.

14.

We have maintained open lines of communication from management to our workforce through weekly communications from our CEO, regular COVID-19 newsletters and training and education around our protocols. The Board has made efforts to understand concerns of our yard employees through participation in online employee welfare committees and a series of virtual ‘chat with the Chair’ gatherings.

15.

In April 2020, the Board took the difficult decision to reduce the fees, salaries and allowances for our Board, senior management and all of our professional staff by 25% to conserve cash and protect the business during this period of unprecedented market conditions. However, it became clear that this reduction was causing undue pressure on some employees, so in October 2020 we restored the salaries for those in the lowest paid tiers to better balance the needs of the business and its employees.

16.

The Board has considered the impact of COVID-19 on our business and the supply chain, and have not identified any material issues or circumstances that have changed our modern slavery procedures and monitoring. However this is an issue that will be kept under regular review given the pressure on the supply chain in light of the continuing impact of the virus on businesses and the wider industry.