Modern Slavery Act Statement of Siem Industries S.A.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 December 2020.
It sets out the steps taken by various subsidiaries with the Siem Industries’ group companies, as discussed below, to ensure that no slavery, servitude, forced or compulsory labour or human trafficking is taking place in their supply chains and in any part of their own business during the financial year ending 31 December 2020.
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 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. To find out more about the Siem Industries group please see the following link: https://www.siemindustries.com/about-us/
Star Reefers Inc. is a subsidiary of Siem Industries and has a wholly owned subsidiary (Star Chartering Inc.). Both Star Reefers Inc. and Star Chartering Inc. have a UK branch. Star Reefers Inc. is an operator of eight refrigerated vessels (reefers), with an average age of 9 years and total fleet capacity of 5 million cubic feet. The vessels are engaged on long-term charters and are predominantly involved in the fruit trade, in particular bananas, but can accommodate a wide range of commodities. To find out more about Star Reefers Inc. please see the following link: https://www.star-reefers.com/company/.
Siem Shipowning Inc. is a subsidiary of Siem Industries and has a UK branch. Siem Shipowning Inc. manages and charters a fleet of 23 vessels through its own subsidiaries Siem Bulk Inc., SSI Shipowning I Inc., Siem Shipping UK Ltd., Siem Shipowning RORO Inc., Siem Shipowning I Norway AS and Siem Shipping Norway AS and conducts further commercial operations through its other subsidiaries. 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 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. To find out more about Siem Shipping UK Ltd please see the following link: https://www.siemshipping.com/about-us.
Siem Capital UK Ltd provides legal and accounting assistance to subsidiaries of the group.
Siem Car Carriers AS is an indirect Norwegian subsidiary of Siem Industries SA 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. To find out more about Siem Car Carriers AS, please visit https://www.siemcarcarriers.com/.
Seven Yield Holding Pte Ltd is a Singapore subsidiary which delivers long term ship leasing solutions to the industrial shipping, oil 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.sevenyield.com/.
Seven Yield Renewables Ltd. is a wholly owned subsidiary of Siem Investments S.a r.l., which in turn is a wholly owned subsidiary of Siem Industries, and during the financial year ending 31 December 2020, was the owner of a ground mounted solar park in England.
BSR Group Holdings Limited is a subsidiary of Siem Europe S.a r.l. A copy of BSR Group Holding Limited’s anti-slavery and human trafficking statement is available at https://britishrenewables.com/policies.
The group’s policies in relation to slavery and human trafficking
The Siem Industries group is committed to ensuring that there is no modern slavery or human trafficking in any part of its businesses or supply chains.
Our Anti-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, servitude, forced or compulsory labour and human trafficking.
The group’s due diligence processes
The Siem Industries group has a zero tolerance attitude towards slavery, servitude, forced or compulsory 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:
- employment is to be freely chosen, so that there is no forced or bonded labour;
- there must be no use of child labour whatsoever;
- working hours should not be excessive; and
- there must be no harsh or inhumane treatment of workers.
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 a systematic review of their supply chains to identify areas in which the greatest risk of slavery and human trafficking exists.
The following risk areas were identified:
For Star Reefers Inc. and Siem Shipowning Inc. and their respective subsidiaries 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.
Steps taken to manage risk: inclusion in Star Reefers Inc, 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 and the principles outlined above.
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. are not treated in compliance with the principles outlined above.
Steps taken to manage risk: inclusion in Star Reefers Inc., Siem Shipowning Inc and Siem Car Carrier’s 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 and the principles outlined above.
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 and the principles outlined above.
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 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.
For Seven Yield Renewables Ltd:
Risk: low risk of modern slavery and human trafficking in sub-contractors and consultants carrying out works at the solar park. A greater risk exists in respect of overseas based suppliers of the component parts of the solar park where the company may have no direct control over activities or their own supply chain.
Steps taken to manage risk: as the solar park was sold in January 2021 the risks outlined above are redundant.
Overview of the measures which are adopted to determine the effectiveness of the steps being taken
We recognise that preventing any risk of slavery or human trafficking within our supply chains is an ongoing process. Accordingly, we will keep our Anti-Modern Slavery Policy under regular review (at least annually), updating and improving the Policy where risk assessments determine this is required.
The board of directors of Siem Industries has ultimate responsibility for implementing this statement and providing adequate resources and investment to ensure that slavery, servitude, forced or compulsory 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 UK 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 UK subsidiaries are required to confirm that they have read and understood the Anti-Modern Slavery Policy and are required to complete a training session delivered by external experts on an annual basis.
Updates to the Anti-Modern Slavery Policy are communicated to all persons working for Siem Industries and its UK subsidiaries via email.
This statement was approved by the board of directors of Siem Industries on 16 July 2021.
Jorgen Westad, Director
Siem Industries S.A.
Date: 9 September 2021