Modern Slavery Statement

Modern Slavery Statement for Financial Year 2017/18

The Alderley plc board, and the boards of our subsidiary companies, seek to operate our businesses in an ethical and as environmentally sustainable way as possible.

We recognise and support the requirements of transparency set out in section 54 of the UK Modern Slavery Act and seek to apply it across our global group.

We acknowledge the risk of bonded labour and unacceptable working practices within all countries and of the enhanced risk within certain of the countries in which we operate. We are further alive to the risk of modern slavery or human trafficking within our core supply chain.

We are committed to ensuring that our employees, in whichever country they are resident, are paid an amount which exceeds or meets the applicable minimum wage. We further ensure that they enjoy the employment protections of the relevant country, and in many cases, provide benefits in excess of local minimum standards.

All of our employees are required to undertake training on the issues raised by the Modern Slavery Act which includes guidance as to how to identify issues that may be evidence of human trafficking or modern slavery and what action to take.

We acknowledge that further work is required. The entire Alderley Group is committed to continuous improvement in this area, both internally and within our relationships with core suppliers. We further recognise the need to improve contracting processes so that the requirement to take positive action against the issues raised by Modern Slavery are highlighted and the risk of any breach is reduced.

Philippa Slatter

Director, Alderley plc

Purpose

This document sets out the steps the Alderley Group have taken to detect and or prevent human trafficking and modern slavery within its core supply chain. This covers the 12-month period ending on 30 September 2018.

The Alderley Group Overview

Alderley is a multi-disciplined engineering company operating in the oil, gas and petrochemical industries producing effective and efficient solutions for the metering, processing, treatment and control of hydrocarbon products. Alderley has a long heritage in the industry and has supplied solutions to more than 50 countries.

The Alderley Group is made up of several trading subsidiaries with Alderley plc as the UK parent company.  The trading group of Alderley is as follows:

 

The Alderley Group Approach

We recognise that we have further work to do in eliminating the risk of modern slavery and human trafficking in our core supply chain.  Central to this improvement is the Alderley Code of Business Ethics which all employees, directors, workers and contractors will be required to comply with. A comparable version will apply to all companies who wish to supply the Alderley Group.  This will raise greater awareness of the issues raised by Modern Slavery at a practical daily level.

Alderley ensures that its employees in non-UK countries, wherever possible, exceed local minimum wages and enjoy enhanced employee protections and benefits. Alderley seeks to promote and develop employees based on merit and ability and supports diversity and equal opportunity for all.

The oil and gas industry requires the very highest standards of health and safety compliance. Alderley ensures that robust health and safety procedures are in place at all times, both at a project level and within the working environment to ensure the safety and wellbeing of employees and workers.

Alderley companies seek to support local communities with donations to charities in their local communities, e.g. sponsoring a Iftar breakfast in Dammam. In the UK the companies actively support the governments STEM initiative.

Assessing Risk Areas

Different Cultures and local laws

The Alderley Group recognises the different local customs and cultures of the countries in which we carry on business.  We recognise the challenges this can bring and seek to navigate them with sensitivity, whilst always requiring that all employees and workers are treated with respect and dignity.

Contracting

Alderley have identified improvements that can be made in internal procurement practices. This includes the requirement that all suppliers meet or exceed the standards which will be set out in the Code of Business Ethics for Suppliers.

Training

All employees are required to complete training on the issues covered by the Modern Slavery Act. This training forms part of the induction process and is repeated by each employee at least bi-annually.

As part of the training, employees are made aware of how to report concerns relating to any aspect of human slavery. This includes use of the Group’s Whistleblowing process to support the requirement of continuous transparency.