Modern Slavery Statement

Our responsibility

Ship Holdco Limited (“Ship Holdco”) recognises that slavery, servitude, forced or compulsory labour and human trafficking (“modern slavery”) are serious global issues. We have a zero-tolerance approach to modern slavery in any form, in our own operations and in our supply chain.

This statement is made under section 54(1) of the Modern Slavery Act 2015. It sets out the steps Ship Holdco has taken, and continues to take, to prevent modern slavery in its business and supply chain.

Our business

Ship Holdco is based at 25 Walbrook, London EC4N 8AW. We provide bulk liquid tank storage, terminal throughput and logistics coordination for fuels, biofuels and petrochemical feedstocks, in above-ground steel tanks inspected to API 653 or EEMUA 159. Our clients are traders, brokers, cargo owners and agents.

Our supply chain

Storing and moving bulk liquids depends on many suppliers. Our supply chain includes:

• terminal and tank operators;
• tank inspection, maintenance, cleaning and repair contractors;
• scaffolding, construction and engineering contractors;
• road and rail hauliers, barge operators and shipping agents;
• labour and recruitment agencies; and
• suppliers of equipment, IT and professional services.

Construction, maintenance, tank cleaning and transport can involve agency or migrant workers. We treat these services as the highest-risk part of our supply chain and focus our due diligence on them.

Our standards

These standards apply to everyone who works for us, and to everyone who works for our suppliers on our behalf:

• all work is voluntary, and workers are free to leave their employment on reasonable notice;
• no worker pays recruitment fees or related costs to get or keep a job;
• workers keep their own passports, identity documents and permits;
• wages are paid in full and on time, at no less than the legal minimum, and working hours comply with local law;
• working conditions, and any accommodation provided, are safe; and
• no child labour is used.

Risk assessment and due diligence

We consider the main modern slavery risks in our sector to be:

• contract and agency labour used for terminal construction, maintenance, tank cleaning and inspection, particularly where workers are recruited across borders;
• recruitment fees, retention of identity documents and debt bondage linked to labour agencies; and
• subcontracted transport and logistics services.

Before we engage a new supplier, we assess the risk of the service, the country it is delivered from and the way its workers are recruited. Depending on that risk, our checks include supplier questionnaires, sanctions and adverse-media screening and, for higher-risk suppliers, site visits or audits. If we find labour practices that put workers at risk, we do not start the relationship until they are corrected.

Supplier contracts

Our supplier contracts require suppliers to:

• comply with the Modern Slavery Act 2015 and equivalent laws where they operate;
• meet the standards set out in this statement;
• tell us promptly if they become aware of modern slavery in their operations or supply chains;
• cooperate with our audits and information requests; and
• pass equivalent obligations on to their own subcontractors.

If a supplier breaches these obligations, we work with them to put things right and protect the workers affected. Where a supplier will not, we end the relationship.

Training

We train employees who manage procurement, contractors and site work to recognise the signs of modern slavery, such as workers who appear to be controlled by someone else, do not hold their own documents or owe money to a recruiter, and to know how to report a concern.

Raising a concern

Anyone, including our employees, contractors, suppliers’ workers and members of the public, can raise a concern with us in confidence. Call +44 7709 916014 and ask to speak to a director, or email sales@shipholdco.com marked “Confidential”. We do not tolerate retaliation against anyone who raises a concern in good faith.

You can also contact the Modern Slavery & Exploitation Helpline, free and in confidence, on 08000 121 700. If someone is in immediate danger, call 999.

Measuring effectiveness

We measure how well these steps are working using the following indicators:

• the proportion of new suppliers screened for modern slavery risk before onboarding;
• supplier audits completed and corrective actions closed;
• concerns raised and how they were resolved; and
• completion of modern slavery training by the employees who need it.

We review these indicators every year and report on them in our next statement.

Approval

This statement was approved by the board of directors of Ship Holdco Limited, which reviews and updates it every year, and is signed on its behalf by a director.