This Anti-slavery and human trafficking policy applies to all persons working in any capacity on behalf of the Siem Industries group of companies (as defined below).


Policy statement


Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.


Siem Industries S.A. and all companies acting under its control (but excluding companies of the British Solar Renewables Group which operate under the “BSR Policy”) (referred to as “we” or “the Siem Industries group of companies”), have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or in any of our supply chains.


We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the UK Modern Slavery Act 2015.


We require the same high standards from all of our lessors, contractors, suppliers and other business partners, and we achieve this through the following actions:


  • Lessors, contractors, suppliers and other business partners must confirm that they have their own policy which is equivalent to this Policy, or that they agree to follow this Policy;
  • We carry out a risk assessment to identify those lessors, contractors, suppliers or other business partners which carry a heightened risk;
  • We carry out due diligence (as part of the onboarding process) to identify any allegation that any lessor, contractor, supplier or other business partner is associated with any form of modern slavery;
  • All contracts must include the specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children which are included in our Standard Terms and Conditions;
  • All crew and other employees must have a written contract of employment and may not be asked to pay any direct or indirect fees to obtain work;
  • All suppliers must confirm that they hold their own suppliers to the same high standards, either via incorporation of similar prohibitions in their contracts, or through similar measures;
  • We are alert to any allegations of modern slavery and treat any such allegations seriously;
  •  We refuse to conduct business with any person where there is reason to believe that they engage in any such conduct or do not comply with local laws and regulations.


We take a risk-based approach to our contracting processes and keep them under review. We also conduct an annual, systematic review of our supply chains to identify areas in which the greatest risk of modern slavery exists, taking steps to minimise such risks.


The Siem Industries group of companies operates in compliance with the following principles, which they also expect counterparties to follow:


  • Employment is to be freely chosen, so that there is no forced or bonded labour;
  • No use of child labour;
  • Working hours should not be excessive; and
  • There should be no harsh or inhumane treatment of workers.


The Siem Industries group of companies will not conduct business with a person that does not comply with these principles.


This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.