White sea waves

Modern slavery statement

This modern slavery and human trafficking transparency statement is made in accordance with the requirements of the Modern Slavery Act 2015 (“the Act”) for the financial year 2025-2026.

This statement is made pursuant to Section 54(6) of the Modern Slavery Act 2015 and sets out the steps that OEG Energy Group Limited (“OEG”) has taken during the previous financial year to ensure that slavery and human trafficking is not operating within either its own business or its supply chains. At OEG we respect human rights and do not tolerate any form of slavery. We recognise that no supply chain is without risk of modern slavery, and it is our responsibility to ensure we understand these risks and work in partnership with our suppliers to mitigate them.

OEG and its subsidiaries support the objectives of the Act of eliminating slavery and human trafficking. This statement is made on behalf of the following OEG group companies;

  • OEG Energy Group Ltd
  • OEG Offshore Group Ltd
  • OEG Renewables Group Ltd

Our company structure

OEG is headquartered in Aberdeen, Scotland, and was established in January 2010. As a global provider of high-quality certified cargo carrying units (CCUs), OEG serves the offshore energy industry worldwide. The company employs over one thousand colleagues directly and caters to customers in various countries, with hub locations in all major energy provinces. Additionally, OEG has formed several distribution agency agreements with key partners in specific countries to enhance its product range. OEG has built an international reputation for quality, safety, and cost-effective offshore containers and modular solutions for customers worldwide.

 

Our supply chain

OEG procures a range of goods and services from a variety of suppliers. We have undertaken a risk-based approach to the assessment of our business and supply chain, which has involved taking geographical, industry and market factors into account in order to identify categories of supply that may present a higher risk of modern slavery being present.

 

Our organisational policies

It is OEG’s policy to conduct its business in an honest and ethical manner. OEG takes a zero-tolerance approach to modern slavery and human trafficking and is committed to acting professionally, fairly and with integrity in all of its business dealings and relationships wherever OEG operates. We provide policy awareness training and enhanced training where necessary to ensure that we have a robust system in place to prevent slavery and human trafficking.
We are committed to the prevention, deterrence and detection of modern slavery. We aim to maintain slavery and human trafficking compliance as “business as usual”, rather than as a one-off exercise.
The following resource links are provided for website visitors to further expand awareness and updates on the latest online information available;

https://www.gov.uk/government/collections/modern-slavery

Modern day slavery policy statement - in January 2017, we established our Modern Slavery Act Policy which details OEG’s approach to fulfilling its commitment to support the elimination of modern slavery and fully meet its obligations under the Act. This policy is now part of our global management system which is a Group mandatory requirement for all group companies.
Suppliers code of ethics – this policy covers commitments against corrupt practices and commitments to ethical and environmental standards. This code relates to suppliers to our local and global operations and exists to protect the relationship and to help us set out the OEG high standards of expectations.
Whistleblowing policy – in 2016 specific reference to modern slavery was added to our Whistleblowing Policy which has been posted on our website to raise awareness on how anyone can raise a concern.

These policies cover statutory requirements and internationally recognised standards set out in the UN Universal Declaration of Human Rights, the International Labour Organisation Conventions and the Act. We continue to monitor these key policies in relation to modern slavery and human trafficking.

 

Our due diligence processes for modern slavery and human trafficking

In those areas of our businesses where we source goods from countries where modern forms of slavery are more likely to be prevalent, we are undertaking the following activities to assess and address this risk:

  • Consulting with those suppliers whom we have identified as presenting significant inherent risk in order to understand more about their own businesses, supply chains and the steps they have taken to reduce the risk of slavery and human trafficking;
  • Conducting an internal risk assessment to identify which of the Group’s suppliers are most likely to manufacture goods or provide services in countries and/or sectors where instances of modern slavery are more likely to be prevalent;
  • Reviewing the Group’s existing contractual agreements and identifying ways these can be strengthened to further reduce the risk of modern slavery and human trafficking in our businesses and supply chains;
  • Maintain our policies and systems to enable whistleblowing;

We will continue to monitor the Group’s businesses and our supply chain to assess ongoing risks and develop measures to further reduce the risk of slavery and human trafficking taking place.

We recognise the importance of maintaining constant vigilance to identify and address any impacts associated with modern slavery and human trafficking throughout our supply chains. In recognition of these issues, we are committed to continuing to enhance our capacity to identify, prevent and mitigate any impacts in this field. Our various management teams will be required to consider its own supply chain and to assess the level of risk relating to modern slavery and human trafficking. 

 

Review of evaluation process and monitoring

We measure our effectiveness in ensuring that modern slavery and human trafficking are not taking place in our business or supply chains in a number of ways. As part of our supplier engagement campaign, we have integrated modern slavery clauses within our contracts and have continued to process new supplier enrolment forms. Further monitoring continues to be undertaken during key/critical supplier audits.

We shall use the following key performance indicators (“KPIs”) to measure how effective we have been to ensure that modern slavery and human trafficking is not taking place in any part of our business or supply chain:

  • Annual declaration from senior management on their compliance with our policy and the Act;
  • Annual declaration on compliance from our key/critical suppliers;
  • Completion of supplier audits;
  • Our continued commitment to develop new methods of raising awareness within OEG and our supply chain.

It is important that we continually develop and improve our awareness, understanding and performance in relation to human rights and modern slavery and will report on our progress each year. In addition, we will specifically look at integrating the following elements;

  • We will increase our modern slavery and human trafficking training/awareness across our business through the introduction of global campaigns including posters and online training for all our staff. It is also important that our senior management are provided with an advanced level of training in order to provide guidance and information to employees or suppliers if necessary.
  • We plan to strengthen the ethical questions we discuss with existing key critical suppliers. We are looking at incorporating specific questions on modern slavery and human trafficking during our onsite quality audits in order to enforce awareness that their business is an extension of the OEG business. We will develop questions to be more in depth, with fewer ‘yes’ or ‘no’ responses, which we hope will give us more detail on each of our key critical suppliers.
  • Encourage our own staff and suppliers to use the STOP APP where we are operating in higher risk environments. It’s the first app of its kind to combine community empowerment, big data management and anti-trafficking expertise to disrupt and prevent human trafficking.
  • We want to increase awareness of our whistleblowing policy and to create a culture where anyone who is worried about an ethical issue feels confident to speak up about it, even if they just have a suspicion. They can report their concerns on the phone or online through our website – anonymously if they prefer (subject to local laws). It’s open to employees, contractors and suppliers.

In summary, we will work towards achieving;

  • Making our governance stronger by:
  • Updating our supplier code of ethics
  • Strengthening our supplier questionnaire and evaluation criteria
  • Ensuring that we have modern slavery clauses incorporated across all procurement activities

Improving awareness by:

  • Engaging with suppliers on modern slavery during audits
  • Providing advance training to our senior management on modern slavery
  • Launching a global poster campaign on modern slavery to all staff
  • Increasing awareness of our whistleblowing policy

Collaborating more by:

  • Using online resources to ensure that we are sharing up to date and relevant information on modern slavery to all our staff
  • Encouraging sharing of lesson learnt from our suppliers and other companies

Checking our approach by:

  • Monitoring our suppliers and reporting our findings
  • Checking our modern slavery policy is reflecting our approach

Declaration

This Statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and sets out OEG’s slavery and human trafficking statement for the financial year ending 26 and is approved by the Board.

 

OEG Group Ltd

John Heiton – Chief Executive Officer

Date:06/06/2025