Dana Petroleum Limited is the parent company of the Dana Petroleum group ("Dana Petroleum"). This statement is made pursuant to section 54(1 ) of the Modern Slavery Act 2015 (the "Act") and constitutes Dana Petroleum's slavery and human trafficking statement ("Modern Slavery Statement").
The Act creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking ("Modern Slavery"). The board and management of Dana Petroleum has a zero-tolerance approach to Modem Slavery and are committed to combatting all forms of Modern Slavery and human trafficking within its group, including in our supply chain.
This is Dana Petroleum's Modern Slavery Statement for the financial year ending 31 December 2021 and has been adopted by Dana Petroleum (E&P) Limited, a member of the Dana Petroleum group.
Dana Petroleum is an oil and gas exploration, development and production company with group operations (including joint ventures) in the UK, the Netherlands and Egypt. Dana Petroleum is headquartered in the UK. Further information can be found here.
Compliance with the Act rests with Dana Petroleum's Ethics & Compliance Committee. Dana Petroleum has the following steps in place to reduce the risk of Modern Slavery affecting its business and supply chain:
Dana Petroleum has a Business Integrity Policy focused on maintaining positive relationships with all stakeholders, including business partners, suppliers and the wider communities in which we work. The 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 Petroleum works. This Policy is available to all employees and compliance with its requirements is a condition of employment with Dana Petroleum.
Suppliers to Dana Petroleum's business in the UK and Netherlands should preferably be registered with 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 Petroleum for review. Further information on FPAL can be found here Achilles. FPAL assesses suppliers across a range of compliance criteria. In 2021 Dana Petroleum adopted a Compliance Checklist for any supplier not registered with FPAL to ensure appropriate due diligence is completed prior to contracting with a supplier
Dana Petroleum 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. 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 this process.
Dana Petroleum's template contractual terms require the highest standards of business ethics, compliance with applicable laws and commitment to health, safety and the protection of the environment. Dana Petroleum is robust in ensuring that all contracts entered into contain provisions in respect of Modern Slavery. Dana Petroleum'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 and that the relevant recruitment agency complies with all applicable laws, including the Act. Such provisions seek to protect the status of agency workers and their health and safety.
By encouraging a culture of openness within our organisation, Dana Petroleum aims to prevent malpractice. We encourage all employees to raise issues which concern them at work through our Integrity Policy. An integrity hotline is in place which is promoted on notice boards, our intranet and as a part of on-boarding.
Dana Petroleum has completed 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. The outcome of that risk assessment showed that Dana Petroleum does not operate in jurisdictions or in a sector which has particular risks associated with slavery and human trafficking. To the extent that any risks were identified, it was clear that the company already had appropriate measures in place to mitigate and monitor any risks on a regular basis.
Dana Petroleum is committed to ensuring that there is no Modern Slavery or human trafficking in our supply chain or in any part of our business, and that the same high standards are applied by our business partners. In 2021 Dana Petroleum adopted a Compliance Checklist for audit purposes on our suppliers and business partners.
Dana Petroleum has a robust set of guidelines and policies in place that inform our work, and ensure we are considering the impact of our corporate behaviour as appropriate.
In 2021, Dana Petroleum put in place an online Modern Slavery training course. This was sent to all employees and contractors in all jurisdictions in which Dana Petroleum operates to ensure there is an understanding and awareness around Modern Slavery and human trafficking and the provisions of the Act.
At the time of writing, Dana Petroleum 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 Petroleum on 16 February 2022.
Signed by Jongwoo Kim
Director for and on behalf of Dana Petroleum Limited