Modern Slavery and Human Trafficking Statement

Introduction

The Prax Group is opposed to all forms of modern slavery and has put procedures in place to ensure that it does not occur within the Group.  The Prax Group is working towards eradicating any risk of modern slavery from its supply chains.

This statement relates to the financial year 2023-2024, ending 28th February 2024.  This statement covers State Oil Limited and its UK-based subsidiaries.

About The Prax Group

Headquartered in London, the Prax Group is a British multinational, independent global energy conglomerate dealing in crude oil, petroleum products and bio-fuels, with a complete integration across the oil value chain, from upstream to midstream and downstream.  Our ability to deliver innovative customer solutions across the world has secured our reputation as a leading presence in the global energy market.  Our mission is to conduct business responsibly, placing excellence, integrity and philanthropy at the heart of everything we do.

Our success has been achieved through our entrepreneurial spirit, dynamic team and lean structure.  We are driven, forward-thinking and passionate about our products, with a perpetual quest for quality performance across the board.  We strive to limit our carbon footprint and to embrace the advent of transitional fuels.

Organisation Structure & Supply Chains

The Prax Group expects its suppliers and customers to obey national and international laws and regulations, including those that require them to treat workers and employees fairly, and comply with the Prax Fair Treatment Policy, which is designed to ensure a safe working environment and to protect the quality of that working environment.

The Prax Group is introducing anti-modern slavery wording into its contracts in order to comply with all applicable anti-slavery and human trafficking laws, statutes and regulations, and with the UK Modern Slavery Act 2015.

The Group has a zero-tolerance policy towards human trafficking and slavery.  Any allegations of practices that are contrary to the Group’s values and ethics will be investigated and, where appropriate, will result in suppliers or customers being required to take corrective action or, in serious cases, contracts with offending suppliers or customers will be terminated.

Policies In Relation To Modern Slavery & Human Trafficking

The Prax Group Code of Conduct reasserts the Group’s commitment to ensuring that modern slavery does not take place within the business.  Onboarding of new staff includes training on the Code of Conduct, which includes fair treatment and raising concerns.

There is now a dedicated Code of Conduct for third parties, which is published on all Prax websites.  Employees, agency staff and contractors are encouraged to report any possible breach of the Code of Conduct through the Prax Group’s ‘‘Raising Concerns’’ policy, by reporting matters of concern in the first instance to their immediate Line Manager, a senior manager within Prax, or a Prax Compliance Officer.  The Prax Group also has an external reporting mechanism for raising concerns – an e-mail address and dedicated telephone number hosted by an external law firm.

Joint business ventures which are not operated by the Prax Group are encouraged to apply equivalent standards.

Recruitment

The Prax Group uses its own internal recruitment teams, along with selected reputable employment agencies, to source labour.  The Group verifies the practices of any new agency it is using before accepting workers from that agency.

The Group has policies and procedures covering Right To Work checks.  Immigration & Work Permit Policy and fair working practices are in place, in accordance with the Prax Fair Treatment Policy.

‘‘Know Your Customer’’ & Due Diligence Processes

As its global operations expand, the Prax Group will continue to ensure that it understands its suppliers and customers, particularly in regions and industries that are considered high-risk for human trafficking and slavery.  The Group’s ‘‘Know Your Customer’’ and Due Diligence processes are aimed at ensuring that the Group meets its commitments in terms of acting not only legally, but also ethically, in all of its business relationships.

Risk Assessment & Management

The Prax Group is in the process of identifying specific parts of the business and supply chains where there is an increased risk of modern slavery and human trafficking, and assessing how to manage those risks.  Various areas of higher risk for modern slavery have been identified.  Processes have been put in place to mitigate the associated risks, including the risk of illegal working.

Key Performance Indicators To Measure The Effectiveness Of Steps Being Taken & Training On Modern Slavery

For further awareness regarding modern slavery, the Prax Group continues to distribute an e-learning module to its personnel, which reinforces the Prax Group Code of Conduct.

The Prax Group publishes a monthly Compliance newsletter to all personnel, which regularly communicates the issue of modern slavery, how to identify it, and what action to take if modern slavery is suspected.  The Group is continually improving its ‘‘Know Your Customer’’ and Due Diligence processes, which in turn form part of a rigorous governance process.

In 2024, the Prax Group continues to engage with its counterparties to help to prevent modern slavery and human trafficking within the business and integrates mandatory modern slavery due diligence questions to be completed by all potential new counterparties and customers.

This statement has been approved by the Board of Directors of each of the Prax Group companies.  It is published on the Prax website at: prax.com and on the Home Office Modern Slavery Statement Registry at: modern-slavery-statement-registry.service.gov.uk.

If you have any questions regarding the above, please contact: compliance@prax.com.

Sanjeev Kumar Soosaipillai,
Director of State Oil Limited, for and on behalf of the Prax Group, 7th October 2024