Modern Slavery
Modern Slavery Statement of Holt Energy Advisors Ltd
Introduction
The statement sets down Holt Energy Advisors Ltd commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Organisational structure and supply chains
This statement covers the business activities of Holt Energy Advisors which are as follows:
Commercial Consultancy and Transaction Advisory to the Energy Industry.
The Company currently operates from London in the United Kingdom with team members based also in Aberdeen and Qatar. Projects and assignments are conducted globally.
High Risk Activities
The following activities are considered to be at high risk of modern slavery or human trafficking: Overseas projects in high-risk countries or overseas suppliers based in the same.
Responsibility for the Company's anti-slavery initiatives is as follows:
1.1 Policies: The Managing Director is responsible for creating and reviewing policies. The process by which policies are developed is by following industry best practice and adapting as the company evolves.
1.2 Risk assessments: The Managing Director is responsible for risk assessments in respect of human rights and modern by a process of appropriate led reviews and
1.3 Due diligence: The Managing Director is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
Training
To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company provides an update of the policy and procedures annually to one of the team monthly meeting and provides a copy of all its policies on its website.
Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
2.1 Whistleblowing policy - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
2.2 Employee Code of Conduct - The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
2.3 Corporate Social Responsibility (CSR) Policy - The Company's CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.
Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company's due diligence process includes e.g. building long-standing relationships with suppliers and making clear our expectations of business partners as well as evaluating the modern slavery and human trafficking risks of each new supplier and/or invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Board of Directors endorses this policy statement and is fully committed to its implementation.
This Modern Slavery and Human Trafficking Statement has been approved and authorised by:
Signed by: Chris Starling
Position: Managing Director
Date: 25th July 2023
Review date: 1st July 2024
