Slavery and Human Trafficking Statement

Introduction

The Prax Group is opposed to all forms of modern slavery and is committed to ensuring that slavery and human trafficking is not taking place in supply chains, or in any other part of the business.

This statement relates to the financial year 2020-2021, ending 29th February 2021.

This statement covers State Oil Limited and its subsidiaries which have an annual turnover in the United Kingdom of at least £36 million (please see the list below for the names of those companies).

About the Prax Group

Headquartered in London, the Prax Group is a British multinational independent oil refining, trading, storage, distribution and retail conglomerate dealing in crude oil, petroleum products and bio-fuels. The Group has established principal offices in London, Houston and Singapore, and additional satellite offices across the world.

All Prax Group companies comply with local legislation and regulations. The Group is committed to operating with integrity and respecting human rights; acting with integrity is one of the Prax core business values. The Prax Group recognises that a reputation for high ethical standards is a key factor in the company’s overall success within the oil and gas industry.

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, to provide a safe working environment and to protect the quality of the working environment.

Wherever possible, the Group includes in contracts with suppliers and customers obligations ensuring that both they and Prax are held accountable to those regulations. The Prax Group is moving towards requiring compulsory acceptance of these obligations in order to do business with those counterparties.

The Prax Group has a zero-tolerance policy to 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 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.

Staff, temporary external staff and contractors are encouraged to report any possible breach of the Code of Conduct through the Prax Group ‘Raising Concerns’ policy. They may report matters of concern in the first instance to their immediate Line Manager or the Prax Compliance Officer, or otherwise to a person of trust within the Prax Group organisation.
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.

‘Know Your Customer’ and ‘Due Diligence’ Processes
As its global operations expand, the Prax Group will continue to ensure that it knows the practices of 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 company meets its commitments to acting not only legally, but also ethically, in all of its business relationships.

Risk Assessment & Management

The Prax Group is in the process of performing a comprehensive risk assessment, identifying specific parts of the business and supply chains where there is an increased risk of slavery and human trafficking, and assessing how to manage those risks. The Group intends to review the risk of modern slavery within the various sectors of the oil and gas industry.

Key Performance Indicators to measure effectiveness of steps being taken & Training on Modern Slavery & Trafficking

[The Prax Group intends to further increase awareness through e-learning to reinforce the Prax Code of Conduct and specifically, the issue of Modern Slavery.] The Prax Group intends to launch a training module for Modern Slavery to all employees during this financial year. The completion and proof of understanding of this module will
be compulsory for all employees.

The Group is continually improving its ‘Know Your Customer’ and ‘Due Diligence’ processes, which in turn form part of a rigorous governance process. The Group intends to engage further with its counterparties to help to prevent modern slavery and human trafficking within the business.

This statement has been approved by the Board of Directors of each of the Prax Group companies listed below. It is published on the Prax website at: Prax Group — Fuelling the future (prax.com ) and on the Home Office modern slavery statement registry at: Modern slavery statement registry — GOV.UK (modern-slavery-statement-registry.service.gov.uk).

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

Signed By:
Don Camillo,
Managing Director for Europe & Africa, for and on behalf of the Prax Group
1st September 2021

 

Companies covered by this statement:
Brobot Petroleum Limited
H.K.S Retail Limited
Harvest Energy (Dealerships) Limited
Harvest Energy Limited
Prax Petroleum Limited
Prax Lindsey Oil Refinery Limited
State Oil Limited