Modern Slavery and Human Trafficking Statement 2018
This Modern Slavery Statement (“Statement”) relates to the financial year ending 31 December 2018. 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 our employees and those individuals who work in our 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 has been successfully engaged in the production and exportation of oil for almost 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, 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. 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.
Due Diligence and Assessing Risk in Bunduq’s Business and Supply Chain
As part of our due diligence and risk assessment process we have in place systems to identify and assess potential risk areas in our business and supply chain. Bunduq has a whistleblowing process through which employees can anonymously report any signs or suspicions of wrongdoing or weakness. Bunduq normally has the right to audit its contractors. This is affected by way of audit clauses included in contractor agreements.
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”). The team report biannually to Bunduq’s board of directors and, as of this year, modern slavery and human trafficking has been added as an item. Bunduq has in place a clear process to capture, mitigate and follow up on potential risks.
In 2018 there were no complaints raised against Bunduq or by our employees with regard to wrongdoing as defined in the Act.
Bunduq will circulate a copy of this statement to its employees and emphasise its commitment to eliminating modern slavery and human trafficking in its business and supply chains. Following the production of this statement, Bunduq will internally conduct awareness and training sessions on the risks of, and the identification of, modern slavery and human trafficking.
Bunduq’s Anti-Modern Slavery and Human Trafficking Commitments
We are committed to ensuring that there is no modern slavery in our supply chains or in any part of our business. Bunduq has a code of conduct (the “Code of Conduct”) in which it has a clear commitment to the prevention of forced labour and child labour; both forms of modern slavery. Compliance with the Code of Conduct is required 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. Bunduq’s commitment to the elimination of modern slavery and human trafficking is codified in its key performance indicator for compliance with all laws, regulations, contracts and company policies.
As part of Bunduq’s commitment to combating modern slavery, Bunduq intends to take the following steps over the next 12 months:
- Incorporating appropriate anti-slavery provisions into our Quality, Health, Safety and Environmental Supplier Questionnaire, which all suppliers complete when participating in a tender process;
- Utilising our risk register and whistleblowing process to broaden our staff escalation procedure so to enable any stakeholder to escalate any incidents, risks or suspicions of modern slavery or human trafficking in Bunduq’s business or supply chain;
- Regularly updating, maintaining and promoting the Code of Conduct, which already requires employees to, among other things, uphold Bunduq’s commitment to doing its business ethically and legitimately, with specific reference to modern slavery; and
- Providing information and training to our employees on Bunduq’s obligations under the Act and our commitments to anti-modern slavery and human trafficking practices and controls.
This statement is made further to section 54(1) of the Act and constitutes Bunduq’s slavery and human trafficking statement for the 2018 financial year (ending 31 December 2018).This Statement has been approved by the Board of Directors of Bunduq Company Limited on 09 July, 2019. The Board has authorised Mr. Yutaka Yamada to sign this Statement.
Chief Executive Officer
Date approved: 09 July 2019
Bunduq Company Limited
Hays Galleria, 1 Hays Lane, London, SE1 2RD