Dana Petroleum Limited is the parent company of the Dana Petroleum group ("Dana"). This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes Dana's slavery and human trafficking statement ("Modern Slavery Statement") for the year ending 31 December 2022. This Modern Slavery Statement has been adopted by Dana Petroleum (E&P) Limited.
The Act creates offences in respect of slavery, servitude, forced or compulsory labour and human
trafficking ("Modern Slavery"). The board and management of Dana has a zero-tolerance approach
to Modern Slavery and are committed to combatting all forms of Modern Slavery and human trafficking
within its group, including in our supply chain.
Dana is an oil and gas exploration, development and production company with group operations
(including joint ventures) in the UK, the Netherlands and Egypt. Dana is headquartered in the UK.
Further information can be found here.
During 2022, Dana continued to take steps not only to ensure compliance with the Act but also to ensure
that we conducted our business in an ethical and responsible manner. This 2022 Modern Slavery
Statement documents the key steps Dana has put in place to reduce the risk of Modern Slavery affecting
its business and supply chain.
Our Business Integrity Policy promotes working within the laws and regulations of the countries in which
we operate, promoting high ethical standards and a culture whereby people are empowered to report
issues of concern. Business integrity is a key standard in the selection of partners, suppliers and other
organisations with which Dana works. In 2022 Dana launched “Supplier’s Corner” which is an area on
our external website where relevant Dana policies can be downloaded by our contractors. In doing this,
we ensure that all contractors are fully aware of the standards and principles upon which Dana conducts
Dana favours having suppliers who are registered with an industry recognised supplier verification
scheme such as First Point Assessment Ltd ("FPAL"). FPAL is an Achilles service which identifies,
evaluates and provides pre-qualification information about suppliers on behalf of major buyers in oil and
gas. FPAL request that suppliers complete a corporate social responsibility questionnaire answering
questions that relate specifically to Modern Slavery within their organisation. The answers to these
questions are then fed back to Dana for review. In 2022 Dana completed Compliance Checklists for
suppliers not registered with FPAL or an industry recognised supplier verification scheme to ensure
appropriate due diligence was completed prior to contracting with a supplier.
Dana aims to procure products and services from high quality and high integrity suppliers. We achieve
this through our procurement processes which require that a Supply Chain Management representative
is involved from the initiation of procurement through to the award of contract. This includes carrying
out appropriate risk checks with a third party provider. The third party provider is instructed to complete
a search against each potential supplier against drivers of third party risk such as Modern Slavery.
Goods and services of higher risk and monetary value are subject to more involved tendering
processes. Consideration of quality management systems, policies and related information is a part of
Dana requires that all suppliers comply with all applicable laws which encompasses not only full
compliance with the Act but other matters such as anti-bribery and corruption, GDPR and tax evasion.
Further, Dana's Personnel Services Agreements with recruitment agencies all require that provisions
are in place to protect agency workers supplied by contractors, to require that such workers are legally
employed and remunerated appropriately. Such provisions seek to protect the status of agency workers
and their health and safety.
Dana is committed to conducting its business in a fair, honest and transparent manner. Dana
encourages all employees to “speak up” and raise any issues of concern by using our independent third
party phone line.
Dana has in place a modern slavery risk assessment to identify and assess potential risks within our
business and in our supply chain relating to modern slavery and human trafficking. As part of this risk
assessment process, Dana audits our joint venture partners to ensure that they comply with the same
high standards as Dana does. This risk assessment is kept under regular review to ensure it is up to
Dana provides online Modern Slavery training for all employees and contractors to ensure there is an
understanding and awareness around Modern Slavery and human trafficking and the provisions of the
On 18th October 2022 Dana promoted Anti-Slavery Day by sending a communication to all employees
and contractors to raise awareness of Modern Slavery and human trafficking.
At the time of writing, Dana is not aware of any current or recent incidents, nor accusations of
forced/involuntary labour or human trafficking in our operations or those of our business partners.
This statement was approved by the board of Dana on 2023.
Signed by Jaegu Nam
Director for and on behalf of Dana Petroleum Limited