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"). Dana Petroleum is committed to combatting all forms of Modern Slavery within its group.
This is Dana Petroleum's Modern Slavery Statement for the financial year ending 31 December 2020 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.
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.
Suppliers to Dana Petroleum's business in the UK and Netherlands should 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. FPAL assesses suppliers across a range of compliance criteria.
Dana Petroleum's procurement processes 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.
Dana Petroleum's Business Integrity Policy focuses on creating a culture where concerns over practices which breach our ethical standards can be raised by stakeholders. An integrity hotline is in place which is promoted on notice boards, our intranet and as a part of on-boarding.
This statement was approved by the board of Dana Petroleum on 3rd March 2021.
Signed by Jongwoo Kim
Director for and on behalf of Dana Petroleum Limited