This statement is made pursuant to (i) section 54(1) of the Modern Slavery Act 2015; and (ii) The Norwegian Transparency Act 2021 (Norwegian: "Åpenhetsloven", with respect to the Norwegian subsidiaries outlined below), and constitutes our slavery, human rights, working conditions and human trafficking statement for the financial year ended 31 December 2024.
The Transparency Act promotes enterprises’ respect for fundamental human rights and decent working conditions and ensures that the public have access to information about how enterprises address adverse impacts on fundamental human rights and decent working conditions.
This statement sets out the steps taken by various subsidiaries within the Siem Industries’ group companies to ensure that no slavery, servitude, breaches of human rights, poor working conditions, forced labour or human trafficking is taking place in their supply chains and in any part of their own business during the financial year ended 31 December 2024.
Siem Industries is committed to promote an ethical culture where our employees and business partners always endeavour to act in the right way. Siem Industries is committed to safeguarding human rights across our businesses, irrespective of the countries in which they operate. In accordance with Siem Industries governing elements, there are clear principles and expectations for all our entities and supply chain partners to comply with the same standards regarding human rights.
The average number of employees in the Siem Industries’ group companies was 765 for 2024 (2023: 792), including onshore and offshore employees. As for the Norwegian subsidiaries, the average number of employees totalled 7 for 2024.
The company's structure and supply chains
The companies listed below are all part of the Siem Industries S.A. (“Siem Industries”) group.
Siem Industries S.A. is an industrial holding company that operates through autonomous affiliates. It
currently holds interests in the oil and gas services industry and renewable energy sector, ocean
transportation of refrigerated cargoes and automobiles, and finance leasing. To find out more about the Siem Industries group please see the following link: https://www.siemindustries.com/about-us/.
Reefers Norway AS is a 50% indirectly owned Norwegian subsidiary of Siem Shipowning Inc. and is an owner and operator of 6 reefer vessels.
Siem Shipowning Inc. is a subsidiary of Siem Industries and has a UK branch. Siem Shipowning Inc. group is an owner and operator of vessels engaged in international shipping. It had a fleet of six vessels per 31 December 2024. The vessels are operated through subsidiaries; SSI Shipowning I Inc., Siem Shipping UK Ltd., Auto Marine Transport Inc. and Siem Shipowning I Norway AS. To find out more about Siem Shipowning Inc. please see the following link: https://www.siemshipowning.com/company/.
Siem Shipping UK Ltd. is a wholly owned UK subsidiary of Siem Shipowning Inc. and provides commercial, operational, administrative and management support services to the companies in the Siem Industries group of companies and to the ships managed and/or chartered by the other subsidiaries of the group. Siem Shipping UK Ltd owns one reefer vessel. Siem Ship Management Sp. Z.o.o. is a subsidiary of Siem Shipping UK Ltd. To find out more about Siem Shipping UK Ltd please see the following link: https://www.siemshipping.com.
Siem Capital UK Ltd provides legal, corporate and accounting assistance to subsidiaries of the group.
Siem Car Carriers AS is an indirect Norwegian subsidiary of Siem Industries, which manages vessels, and operates a global liner service, specialising in the movement of new autos, roll on roll off (RO-RO) and project cargo. Seven Yield 7500 PCTC 1 AS and Seven Yield 7500 PCTC 2 AS are subsidiaries of Siem Car Carriers AS, where both companies lease one PCTC vessel each from an external party. Siem Car Carriers Pte Ltd is a wholly owned subsidiary of Siem Car Carriers AS and provides ship management services to vessels that are bareboat chartered in under Singapore flag. To find out more about Siem Car Carriers AS, please visit https://www.siemshipping.com/services/siem-car-carriers/.
Siem Kapital AS is a wholly owned subsidiary of Momentum S.a r.l., which in turn is a wholly owned subsidiary of Siem Industries. Siem Kapital AS is the owner of Siem Car Carriers AS, and also owns and manages a few other minor investments.
Siem Offshore AS is an indirect Norwegian subsidiary of Siem Industries. The wholly owned subsidiaries of Siem Offshore AS owned 9 offshore vessels (OSCV, AHTS and PSV) which are time chartered out in the offshore services industry.
Seven Yield Holding Pte Ltd is a Singapore subsidiary which delivers long term ship leasing solutions to the industrial shipping and offshore sector, through long-term bareboat charter contracts of existing and newbuild vessels. To find out more about Seven Yield, please visit https://www.siemshipping.com/services/seven-yield/.
Siem Oil Service Invest Holdings Ltd was owned 20% by Siem Industries, which through its subsidiaries owned and operated two offshore vessels that were employed in the offshore services industry.
The group's policies in relation to human rights, working conditions, slavery and human trafficking
The Siem Industries group is committed to respecting human and labour rights, and to ensuring that there is no modern slavery, breaches of human rights, poor working conditions or human trafficking in any part of its businesses or supply chains. The Siem Industries group has established due diligence routines in this respect for assessing and managing risks.
Our Anti-Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing controls to ensure that none of the following are taking place anywhere in our business or supply chains: slavery, breaches of human rights, poor working conditions, servitude, forced labour and human trafficking.
Siem Industries group of companies has procedures and measures in place to ensure decent working
conditions and a safe, healthy and equal work environment for all relevant staff in accordance with
applicable laws and regulations and carries out relevant training in this regard. Our whistleblowing
procedures provide staff with guidance as to how to raise concerns on actual or suspected wrongdoings,
including in terms of human rights and decent working conditions.
The group's due diligence processes
The Siem Industries group has a zero tolerance attitude towards slavery, breaches of human rights, poor
working conditions, servitude, forced labour and human trafficking. We will not conduct business with any person where there is good reason to believe that they engage in any such conduct or do not comply with local laws and regulations.
In addition, the Siem Industries group complies with and requires compliance with the following principles:
The Siem Industries group will not conduct business with a person that does not comply with these
principles.
Overview of the risk assessment which has been carried out and actions taken to manage the risk
The companies within the Siem Industries group have carried out extensive due diligence and a systematic review of their supply chains to identify areas in which the greatest risk of slavery, breaches of human rights or decent working conditions, and human trafficking exists. The assessment is risk-based, emphasising e.g. general knowledge of the industry or product risk, geographical risk, information obtained from or about the supplier, own experiences and evaluations, the size and significance of the agreement, and our connection with the risk and leverage towards the supplier.
According to our latest assessments, the following risk areas were identified:
For Siem Shipowning Inc. and its respective subsidiaries, including Siem
Shipowning I Norway AS and Auto Marine Transport Inc., as well as Siem Car Carriers AS:
Risks: Charterers and shippers of cargoes (e.g. fruit, vehicles, frozen foods) not adhering to principles
outlined above. Suppliers, agents and contractors (e.g. suppliers of provisions, repair yards, stevedores)
who do not adhere to these principles in the provision of goods and/or services to the Siem Industries group of companies. While our operations and supply chain have a global reach, the risk is particularly heightened in regions with a general higher risk of human and labour rights violations.
Steps taken to manage risk: inclusion in Siem Shipowning Inc. and Siem Car Carriers AS Standard Terms and Conditions of wording requiring counterparties (such as charterers) to warrant that all parties to the intended trade (including their agents, suppliers, contractors and shippers (of any tier)) comply with local laws and regulations (including the UK Modern Slavery Act and the Norwegian Transparency Act) and the principles outlined above. In addition, counterparties are made aware of the content of Siem Industries' Anti-Modern Slavery Policy by receiving a copy of the Policy on request. Furthermore, we conduct general due diligence and risk assessments of our supply chain, including screening of counterparties (though e.g. World-Check), to identify, assess, and address risks as necessary. The due diligence process is strengthened based on factors such as the geographical area and other risk factors.
Risk: Crew on board the vessels managed by the shipowning companies through Siem Shipping UK Ltd and their subsidiary Siem Ship Management Sp. z.o.o. but supplied by third party crewing agencies are not treated in compliance with the principles outlined above.
Steps taken to manage risk: inclusion in Siem Shipowning Inc. and Siem Car Carriers’
Standard Terms and Conditions, to be included in all management contracts with Siem Shipping UK Ltd., wording requiring counterparties (such as crewing agencies) to warrant that all parties to the intended contract comply with local laws and regulations (including the UK Modern Slavery Act and the Norwegian Transparency Act) and the principles outlined above. Furthermore, we conduct assessments and screenings of the supply chain / counterparties, as outlined above. Our assessments have not revealed any actual adverse impacts or significant risks of adverse impacts that requires specific measures, besides the general measures implemented towards our suppliers and supply chain.
Siem Industries recognise that there are health and safety risks related to work at sea where operations are done 24/7 throughout the year. Onshore employees have risks related to prolonged sitting time, screens/light, etc. Health and safety is our number one priority and we have a strong focus on improvement and follow up of safety and management systems, improvement of health and safety culture, internal assessments and audits, and towards our suppliers. There is a zero-tolerance of bullying or harassment in any work environment. Employees are encouraged to use the whistleblowing channel to report any incident and expect our employees to follow our Code of Conduct and comply with our human rights commitment.
For Reefers Norway AS:
Risk: Charterers and shippers of cargoes not adhering to principles
outlined above. Suppliers, agents and contractors (e.g. suppliers of provisions, repair yards, stevedores)
who do not adhere to these principles in the provision of goods and/or services to the Siem Industries group of companies. As outlined above, the risk is increased is certain geographical areas.
Steps taken to manage risk: Inclusion of standard contracting conditions in all vessel charter parties that all counterparts warrant that all parties to the intended contract comply with local laws and regulations (including the UK Modern Slavery Act and the Norwegian Transparency Act) and the principles outlined above. Furthermore, we conduct assessments and screenings of the supply chain / counterparties, as outlined above. Our assessments have not revealed any actual adverse impacts or significant risks of adverse impacts that requires specific measures, besides the general measures implemented towards our suppliers and supply chain.
For Siem Shipping UK Ltd:
Risk: an indirect risk to Siem Shipping UK Ltd via the companies it provides services to, suppliers/
manufacturers of cargoes not adhering to principles outlined above.
Steps taken to manage risk: Inclusion in Siem Shipping UK Ltd's Standard Terms and Conditions of wording requiring charterers to warrant that all parties to the trade (including suppliers) comply with local laws and regulations (including the UK Modern Slavery Act and the Norwegian Transparency Act) and the principles outlined above. In addition, counterparties are made aware of the content of Siem's Anti-Modern Slavery Policy by receiving a copy of the Policy or a link to the website where it is available.
For Siem Capital UK Ltd:
Risk: Siem Capital UK does not itself deal directly or indirectly with any entities other than group entities. Accordingly, the review of the company's supply chains has not identified any risks other than those addressed elsewhere in this statement.
Steps taken to manage risk: ongoing monitoring and review of risks.
For Siem Offshore AS:
Risk: Charterers, agents and contractors not adhering to principles outlined above. Crew on board the vessels supplied by third party crewing agencies are not treated in compliance with the principles outlined above. As outlined above, the risk is increased is certain geographical areas.
Steps taken to manage risk: Siem Offshore AS will not allow it nor any of its subsidiaries to lease vessels to any individual entity which is reasonably believed not to adhere to the principals outlined above. Furthermore, we conduct assessments and screenings of the supply chain / counterparties, as outlined above. Our assessments have not revealed any actual adverse impacts or significant risks of adverse impacts that requires specific measures, besides the general measures implemented towards our suppliers and supply chain.
For Seven Yield Holding Pte Ltd:
Risk: Owners and operators of vessels financed by Seven Yield not adhering to principles outlined above.
Steps taken to manage risk: Seven Yield will not lease vessels to any individual entity which is reasonably believed not to adhere to the principles outlined above. Furthermore, we conduct assessments and screenings of the supply chain / counterparties, as outlined above. Our assessments have not revealed any actual adverse impacts or significant risks of adverse impacts that requires specific measures, besides the general measures implemented towards our suppliers and supply chain.
For Siem Oil Service Invest Holdings Ltd:
Risk: Charterers of vessels owned by subsidiaries of Siem Oil Service Invest Holdings Ltd not adhering to the principles outlined above.
Steps taken to manage risk: Siem Oil Service Invest Holdings Ltd will not allow it nor any of its subsidiaries to lease vessels to any individual entity which is reasonably believed not to adhere to the principals outlined above. Furthermore, we conduct assessments and screenings of the supply chain / counterparties, as outlined above. Our assessments have not revealed any actual adverse impacts or significant risks of adverse impacts that requires specific measures, besides the general measures implemented towards our suppliers and supply chain.
Overview of the measures which are adopted to determine the effectiveness of the steps being taken
Employee safety and wellbeing is important for Siem Industries. Employees can expect to be treated fair and equal and be given the opportunity to develop and grow. They should feel respected for who they are and what they stand for, and they should feel safe to voice their opinion. There is a zero-tolerance for bullying, harassment, and discrimination on any grounds.
We recognise that preventing any risk of slavery, violations of human rights or decent working conditions, or human trafficking within our supply chains is an ongoing process. Accordingly, we keep our Anti-Modern Slavery Policy and due diligence process under regular review (at least annually), updating and improving assessments, procedures, measures and the Policy where risk assessments determine this is required.
The day-to-day responsibility for our work on due diligence and ensuring human rights, are placed within various units within the group and within the different subsidiaries, such as within management,
legal/compliance, HR, procurement, etc. The board of directors of Siem Industries has ultimate responsibility for implementing this statement and providing adequate resources and investment to ensure that slavery, breaches of human rights, poor working conditions, servitude, forced labour and human trafficking is not taking place within our businesses or their supply chains.
Details of training which is carried out on modern slavery and trafficking
We provide all our staff with a copy of the Anti-Modern Slavery Policy, in order to ensure that all persons working in any capacity for Siem Industries and its subsidiaries have a high level of understanding of the risks of modern slavery and human trafficking in our business supply chains.
All persons working for Siem Industries and its subsidiaries are required to confirm that they have read and understood the Anti-Modern Slavery Policy and are required to complete a training session on an annual basis.
Updates to the Anti-Modern Slavery Policy are communicated to all persons working for Siem Industries and its subsidiaries via email.
Key steps taken during the year ended 31 December 2024
Specific steps taken by the Siem Industries group during the year ended 31 December 2024 to address the risks of slavery, breaches of human rights, working conditions and human trafficking within our own supply chains and operations include:
Siem Industries will provide annual updates to this statement.
The directors and CEOs of each subsidiary referred to in this statement have reviewed and approved the content of this statement.