Modern Slavery and Human Trafficking Statement 2021
This Modern Slavery Statement (“Statement”) relates to the financial year ended 31 December 2021. It is published by Bunduq Company Limited (“Bunduq”) in compliance with the UK’s Modern Slavery Act 2015 (“the Act”).
The term “modern slavery” as used in this Statement includes all forms of slavery including forced labour, child labour, bonded labour, domestic servitude, human trafficking and forced sexual exploitation.
Bunduq supports the elimination of all forms of modern slavery. Bunduq is committed to protecting and safeguarding the rights of its employees and those individuals who work in its supply chain. Bunduq’s commitment to undertaking its business ethically and legitimately, along with its proud record of corporate social responsibility, is fundamental to its growth strategy.
Bunduq employs 143 members of staff as of 31 December 2021, all of whom are full-time employees.
Bunduq has been successfully engaged in the production and exportation of oil for more than fifty years, operating in the offshore El Bunduq field located on the border of the Emirate of Abu Dhabi and the state of Qatar. Bunduq continues its energy and production business in the United Arab Emirates and Qatar through providing safe, stable and efficient oil production.
Bunduq is wholly owned by the Japanese company: United Petroleum Development Co. Ltd (“UPD”), which, together with its own shareholders, provides financial support and human resources to help Bunduq with its continued success and growth in the Middle Eastern region.
As Bunduq’s sole shareholder and customer, UPD is integral to its downstream supply chain. UPD appoints four directors to Bunduq’s Board including the Chairman and the CEO. This level of control ensures that UPD partners Bunduq’s commitment to the elimination of modern slavery. Bunduq has no subsidiaries but engages with and manages contractors to extract and transport oil, before it is blended, packaged and shipped to Japan on vessels.
Bunduq’s upstream supply chain includes contracts with approximately 700 suppliers. Bunduq’s supply chain involves the purchase of those products and services central to its business and administrative operations. The majority of these suppliers are based in the UAE, with no suppliers operating out of those top ten countries considered by the Global Slavery Index to have the the highest prevalence for modern slavery.
Bunduq’s central policy in respect of modern slavery and human trafficking is its code of conduct (the “Code of Conduct”). This was updated on 25 December 2019 to include references to modern slavery and sets out clear commitments to the prevention of forced labour and child labour; both forms of modern slavery within the business and Bunduq’s supply chain. Compliance with the Code of Conduct remains a requirement for every contractor submitting and / or winning a bid with Bunduq. Additionally, each employee must confirm their compliance with the Code of Conduct in their annual review. The employee sign off rate for the Code of Conduct in 2022 was, as previously, 100%.
The “preventing modern slavery and human trafficking” section in the Code of Conduct refers to this Statement and Bunduq’s commitment to eliminating all forms of modern slavery, whilst also setting out clear obligations for its employees to remain vigilant; report any suspicion or incident; and to ensure all contractors and third parties are aware of its commitments.
Bunduq’s compliance policies also set out anti-modern slavery practices. These were recently reviewed to ensure they remained adequate and robust and Bunduq is satisfied that they do. Driven by its Health, Safety and Environment (“HSE”) policy and HSE programs Bunduq has enhanced its proactivity in encouraging employees to report unsafe acts or conditions that may harm workers or damage assets or the environment. HSE matters are discussed in monthly Offshore Employee HSE Committee meetings and progress is reported company-wide on an annual basis. As part of this our HSE Campaign / Awareness targets were achieved, and a commitment to improving the initiative: Watch Carefully, Act-Timely, Think Safety and Create a Hazardless-Environment (“WATCH”) was introduced in FY2021. In 2020 Bunduq employees reported 2,469 WATCH observations, an increase of 58% compared to 2018.
In the last year, Bunduq has implemented a Business Continuity Management System to ensure continuity for critical business functions and to facilitate a prompt return to normal operations in order to strengthen Bunduq’s Risk Management processes. This is in line with government requests, and has led to the establishment of Bunduq’s Business Continuity Management Policy (“BCM”) and Business Continuity Plan (“BCP”) which launched in April 2022.
The revised Whistleblowing Procedure was communicated to all stakeholders on 19 July 2020. The purpose of the Whistleblowing Procedure is three-fold:
● Encourage stakeholders (who conduct business with Bunduq including contractors) to report any unethical matters they are or do become aware of;
● Provide these stakeholders with a confidential means for reporting any unethical matters; and
● Protect any individual who makes such a report in good faith.
This purpose is implemented in part through Bunduq’s Ethics Line, which is a confidential hotline with both telephone and email contact details available.
Bunduq established its Compliance Committee in April 2020. The purpose of the Compliance Committee is to support all Bunduq’s staff in their performance of ethical business practices. It aims to ensure there is a high level of integrity in Bunduq’s compliance with all applicable laws, regulations, policies and procedures. In particular, it focuses on anti-bribery, corruption, conflicts of interest and those commitments codified in the Code of Conduct.
The responsibilities of the Compliance Committee remain the same as in the last financial year. These are as follows:
● Overseeing a compliance program and to make decisions on all integrity and business ethics compliance matters;
● Approving changes and updates of the Code of Conduct and Compliance Committee policy and procedures;
● Establishing and implementing the channels to report unethical practices; and
● Overseeing the Whistleblowing Procedure.
Due Diligence and Assessing Risk in Bunduq’s Business and Supply Chain
A central element of Bunduq’s due diligence and risk assessment process is the maintenance of strong systems which identify and assess potential risk areas in the business and supply chain. All selected suppliers are required to pass Bunduq’s stringent technical, quality and safety standards. Bunduq’s Ethics Line allows employees to anonymously report any signs or suspicions of wrongdoing or weakness. Separately Bunduq typically includes audit clauses in its contractor agreements giving it the right to audit its contractors.
Bunduq has a full-time internal audit team who are responsible for assessing and reporting risks in the business and updating Bunduq’s risk register (the “Risk Register”). Since 2020 this team has reported biannually to Bunduq’s Board on factors such as modern slavery and human trafficking. Bunduq is pleased to report that to date no related issues have been reported. A further demonstration of our commitment to a safe working environment is that in 2020 Bunduq achieved a further “no lost-time injury milestone”. This reflects that during 29 years working in the warehouse, 15 years offshore, 11 years in the office, and 3 years companywide, there have been no major employee workplace injuries or deaths. Bunduq continues to demonstrate an exemplary safety record, which is a clear sign of the effectiveness of its HSE systems and programs. In 2020, Bunduq achieved both a lost-time injury frequency and a total recordable injury rate per 1 million man hours of zero.
Bunduq has in place a clear process to capture, mitigate and follow up on potential risks, and maintains a commitment to the UN Guiding Principles on Business and Human Rights. It conducts regular risk assessments of its top 10 business risks and assigns each a risk rating. Non-compliance with law and regulation (including the Act) is considered one of the lowest risks faced by the business and one that can be mitigated through internal controls and broad awareness of the Code of Conduct by all employees.
In the last financial year, Bunduq has identified acts of terrorism that threaten its plants and offices, pipelines, transportation and / or computer systems as a principle risk for the business. Bunduq now has measures in place to ensure vendors are not on the US Office of Foreign Assets Control Sanctions List and operates with enhanced processes for the prevention of money laundering in line with Article 1 of the Code of Conduct. These processes include utilising the money transfer safeguards available from Bunduq’s bank and retaining a company lawyer.
Neither through the Ethics Line nor any other reporting method has there been any complaints for the years 2018 to 2021 with regards to suspected or actual wrongdoing as defined in the Act.
Since 2019, Bunduq has circulated a copy of its Statement to its employees annually and emphasises its commitment to eliminating modern slavery and human trafficking in its business and supply chains. Following the publication of its previous Statement, Bunduq provided anti-modern slavery compliance information to its employees. This outlined its obligations and commitments with regards to anti-modern slavery and human trafficking practices and controls.
More recently, staff events and training have been introduced that promote broader social growth and facilitate opportunities. These include hosting a “Blue Week” with ADNOC, a presentation of Bunduq’s Fish Reef Project and events for International Women’s Day. Events in this period have been limited by, and held in accordance with relevant guidelines on, the Covid-19 pandemic.
Bunduq’s Anti-Modern Slavery and Human Trafficking Commitments
Bunduq remains committed to ensuring that there is no modern slavery in its supply chains or in any part of the business. It continues to follow internal policies countering forced labour and child labour and ensuring appropriate minimum wages and working hours are adhered to. In 2020, Bunduq included its commitment to anti-modern slavery practices in the Code of Conduct and launched the Ethics Line to facilitate the anonymised escalation of any suspicion or actual knowledge of unethical behaviour. Bunduq’s commitment to the elimination of modern slavery and human trafficking continues to be codified in its key performance indicators (“KPIs”) for compliance with all laws, regulations, contracts and company policies.
The Code of Conduct is promoted throughout the company to set employee standards. This is monitored through an Annual Performance Appraisal System where performance, achievements and major tasks completed during the performance year are assessed against relevant annual objectives.
As part of Bunduq’s commitment to combating modern slavery, Bunduq stated its intention to take certain steps throughout FY2021. In consideration of these aims, Bunduq has made considerable progress over the last 12 months through the following:
● Incorporating anti-slavery provisions into Bunduq’s Quality, Health, Safety and Environment (QHSE) Policy Supplier Questionnaire;
● The internal audit team’s work in ensuring relevant updates are made to the risk register twice a year and that all registered risks for the business are captured;
● Implementing a multi-tasking initiative through the modification of job descriptions for all sections of the business, in order to help empower employees to think about the future and how Bunduq can shape it for the better and contribute to social development;
● Conducting an annual review of the Code of Conduct to ensure that it remains valid and establishing the BCM and BCP in April 2022; and
● Maintenance of a Compliance Committee to support all its staff in performing ethical business practices and acting with integrity in interactions and arrangements with applicable laws, regulations, policies and procedures.
As part of Bunduq’s ongoing commitment to combating modern slavery, its KPIs for FY2022 include all of those it set out for FY2021, with a repeated commitment to compliance with relevant laws, regulations, contracts and company policy. Bunduq also intends to take the following steps over the next 12 months to further its efforts to combat modern slavery:
● Build in additional anti-slavery provisions for suppliers to address beyond the current QHSE Supplier Questionnaire.
● Uphold Bunduq’s five-year business plan, which includes a commitment for the Board to consider the consequences of its decisions through to 2026 on matters such as monitoring the integrity of wells and facilities / structures and further developments of the reservoirs. As part of this strategy more broadly, the Board aims to reduce energy consumption, waste volume and participate in ADNOC’s Environmental forum studies and initiatives. Bunduq recognises the inextricable link between climate and social commitments.
Protection of health
Bunduq works to ensure that its workplaces are free of health and safety hazards and that employees’ have a high level of job satisfaction. In 2019 and 2020, several initiatives and campaigns to facilitate employees’ abilities to improve their physical and mental health and wellness were launched. These included the ADNOC Marathon, Heat Stress Campaign, Mental Health Campaign and Winter Campaign.
In response to the Covid-19 pandemic, Bunduq took numerous measures to protect its workers and prevent the spread of the virus while maintaining business continuity. These measures included assigning a doctor and nurse offshore to screen all personnel and support hygiene awareness, extending offshore worker cycles in keeping with new immigration restrictions and efforts to prevent the spread of infection by implementing physical distancing and remote working where practicable. Beyond this, Bunduq ensured the implementation of 100 VPN connections, increased connection speeds, vendor access through newly adopted systems and technological upgrades.
This Statement is made further to section 54(1) of the Act and constitutes Bunduq’s slavery and human trafficking Statement for the 2021 financial year (ending 31 December 2021). This Statement has been approved by the Board of Directors of Bunduq Company Limited on 26 July 2022 with an effective date of 30 June 2022. The Board has authorised Mr. Yutaka Yamada to sign this Statement.
Chief Executive Officer
Date approved: 26 July 2022
Bunduq Company Limited
1 Chamberlain Square Cs, Birmingham, United Kingdom, B3 3AX