CENTURION GROUP MODERN SLAVERY STATEMENT

APRIL 2018

Introduction

The Modern Slavery Act 2015 (the Act) prohibits slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”). 

Modern Slavery is an international crime, affecting around an estimated 30 million slaves around the world.  It is a growing global issue that transcends age, gender and ethnicities.  It includes victims who have been brought from overseas and vulnerable people in the UK, who are forced to illegally work against their will across many different industry and service sectors.

This statement also takes cognisance of the requirements of the Human Trafficking and Exploitation (Scotland) Act 2015.

Centurion Group Limited (“Centurion Group” or “the Group”) is committed to protecting and respecting human rights and have a zero tolerance approach to Modern Slavery in all its forms.

This statement is made pursuant to Section 54, Part 6 of the Act and sets out the steps the Group and its subsidiaries have taken in relation to slavery and human trafficking during the financial years ending 31 December 2016 and 31 December 2017 and its general approach to the issue of Modern Slavery. 

The Group is headquartered in the UK and operates worldwide, with operational corporate entities in the UK, the USA, Canada, Singapore, Azerbaijan, Kazakhstan and Australia.  This Modern Slavery Statement applies to all its entities, operations and locations.

This statement has been approved by the Group’s Board of Directors, who will review and update it annually.

The Group’s Structure and Activities

Throughout the financial years ending 31 December 2016 and 31 December 2017, Centurion Group provided specialist services for the management, supply, rental, testing, inspection, and maintenance of equipment, certified cargo/waste carrying appliances and chemicals tanks in the tooling, lifting, power units and subsea markets.

In December 2017, the Group acquired Waste Treatment Solutions Ltd, a rental equipment and services primarily to the oil and gas industry in Canada, and its associated subsidiaries. In the same month, the Group also acquired Site Energy Services Partnership and its associated subsidiaries, a provider of project management, access, clearing and piling solutions for industrial infrastructure in western Canada.

During the financial years ending 31st December 2016 and 31st December 2017, Centurion Group comprised the following business units and entities:

  • Jacks Winches Pte
  • Jacks Winches Pty
  • Tristar Water Solutions Pty
  • MC Australia Holdings Pty (known as Mining Camps Australia or MCA)
  • Mako Deepwater Inc. (known as Seanic)
  • Rentair Ltd
  • Rentair Offshore Ltd
  • Conserve Oilfield Services Ltd
  • ATR Equipment Solutions Ltd
  • ATR Lifting Solutions Ltd
  • Safety & Technical Hydraulics Ltd (known as STH)
  • ATR Caspian Ltd
  • ATR Equipment Solutions (Kazakhstan) LLP
  • Seanic Ocean Systems Ltd (formerly known as Underwater Engineering Services (UES)   
  • Site Energy Services Partnership and associated subsidiaries (2017 only)
  • Waste Treatment Solutions Ltd (2017 only)
  • Artic Crane Service Inc. (2017 only)
  • Prospector Energy Services Inc. (2017 only)

In January 2018, the Group acquired Oil Patch Group Inc and its subsidiaries. These entities provide equipment rental and other services primarily to the oil and gas industry in the United States of America.

The Modern Slavery Statement for the financial year ending 31 December 2018 will also include this additional part of the Group when it is published. 

The Group’s supply chains and adherence to values

The Group’s supply chain includes the provision of products/equipment and services to allow it to deliver the scope of service identified under the previous section entitled “The Group’s Structure and Activities”. 

The majority of the Group’s relationships with members of the supply chain have been established over a number of years or are Client nominated.

The Group has a supplier approval and evaluation process in place and maintain preferred supplier lists.   As and when it has new contractors or suppliers come on-board, it conducts due diligence on them through a series of checks which can include but not be limited to company performance, compliance – including HSEQ and references from other customers to establish suitability.

To date the Group has not been made aware of any human trafficking / slavery activities within the supply chain but if any were highlighted to it then it would act immediately in accordance with its legal and moral obligations. 

Some of the Group’s suppliers are based in countries with a moderate to higher risk rating for Modern Slavery according to the Global Slavery Index, such as Azerbaijan and Kazakhstan.  Suppliers in these areas would be subject, when identified, to additional checks and audits.

Due to the nature of its business and supplies, as well as the Group’s approach to governance, it considers the risk of Modern Slavery to be very low however, it continues to periodically review the effectiveness of the relevant policies and procedures that it has in place.  It also conducts regular audits of a sample of the supply chain to ensure their continued suitability, including compliance with this statement.

The Group’s Policies and Procedures

The Group operates a number of internal policies to ensure that it is conducting business in an ethical and transparent manner. These include:

  • Business Ethics & Conduct Policy: the code makes clear to employees the actions and behaviour expected of them when representing the organisation. The Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.  The code also describes how it expects those with whom it does business, including the supply chain, to behave.
  • Recruitment Policy: the Group operates a robust recruitment policy, including conducting checks on eligibility to work for all employees, to safeguard against human trafficking or individuals being forced to work against their will.
  • Whistleblowing Policy: the Group encourages all employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of Modern Slavery.  The Whistleblowing Policy is designed to make it easy for workers to make disclosures, without fear of reprisals. 

Awareness

The Group is committed to raising awareness of Modern Slavery through various means, including training courses, distributing flyers to staff, putting up posters across the Group’s premises and circulating emails to staff. 

These will explain what Modern Slavery is, the basic principles of the Act, how it can identify and prevent slavery and human trafficking, what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Group, and what external help is available.