Modern Slavery & Human Trafficking Statement 2022/23
Introduction
This statement is published in accordance with the Modern Slavery Act 2015. It sets out the E.A. Gibson Group of Companies actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 January 2023 to 31 December 2023.
Our Business
We offer our clients a highly professional platform of global shipping solutions. Providing support to clients operating in the Tanker, Dry Cargo, Offshore, Gas and Sale & Purchase markets we are able to draw on our industry experience to deliver world-class shipbroking and advisory services.
We have established offices across London, Houston, Hong Kong, Singapore, Mumbai, Athens and Dubai. The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. Employees are required to avoid any activity that might lead to a breach of this policy and use our internal policies to report any concerns.
Relevant policies
- Whistleblowing policy We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact our non-executive Trustee Directors.
- Core Principals and Code of Conduct Our core principals and code of conduct are a set of ethical guidelines, which apply to all staff worldwide, and make clear to all employees the actions and behaviour expected of them when representing our organisation.
Risk Assessment
Whilst we consider our risk of enabling modern slavery to be low, we are committed to taking the necessary steps to ensure modern slavery/human trafficking practices do not occur.
Due Diligence and Supply Chain
We do not consider suppliers to carry significant risk due to the nature of our business model. However, we look to ensure that any new supplier and existing supplier demonstrate their commitment to the Modern Slavery Act 2015, and we are committed to treating our suppliers fairly.
Training and communication
Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to employees as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.
The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
Breach of the policy
Sanctions for breach of the policy should be clearly set out and should include either:
- Disciplinary action or dismissal if the breach is by a member of staff.
- Termination of the contract if the breach is by a supplier, contractor or other business partner.
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.
Next Steps
In 2024 we are looking to introduce specific modern slavery and human trafficking training into our new staff onboarding process, as well as ensuring all staff complete the training regularly.
This statement was approved by the Board of Directors on 30th November 2023
Roger Harrison
Managing Director