Modern Slavery & Human Trafficking Statement
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and has been approved by the Board of Directors of Storegga Limited (the Company or Storegga)
Modern slavery is a morally reprehensive and heinous crime that deprives a person’s liberty and dignity for another person’s gain. At Storegga, we have a zero-tolerance approach to modern slavery and human trafficking across all areas of our organisation, as well as in our supply chains. We are committed to ensuring we are not connected to modern slavery or human trafficking in any way.
Storegga is an independent developer of low carbon solutions, including carbon capture, storage and hydrogen projects in the United Kingdom and internationally. We have a team of around 90 staff members with offices located in both the United Kingdom and the United States.
Further information about the Company can be found at www.storegga.earth
Governance, Policies and Training
Storegga’s commitment to combating modern slavery and human trafficking is set out in its Code of Conduct published on our website. In support of this, the Company has an Anti-Slavery & Human Trafficking and Human Rights Policy, which has been rolled out to all staff to formalise the principle-based approach adopted. In addition, all staff are required to carry out online training focused on tackling modern slavery in the workplace.
All personnel are supported in taking action to avoid any activity that might lead to, or suggest, a breach of this statement. Personnel are encouraged to raise concerns about any issue or suspicion of modern slavery or human trafficking in any part of our organisation or supply chain, in line with the Company’s Whistleblowing Policy. We encourage all employees and contract personnel to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.
We deliver our services through our high-quality staff and as such we have robust recruitment practices supported by representatives in our Human Resources team. Checks include requiring evidence to support candidates’ ‘right to work’. This close involvement and oversight limits the risk of employing anyone who is forced or trafficked labour.
Suppliers & Business Partners – Due Diligence
We are committed as an organisation to tackling modern slavery and human trafficking and want to work with suppliers and business partners who share our values. During 2023, the Company updated its Third Parties Policy and introduced an onboarding process to be carried out on all third parties prior to engagement, including new suppliers and business partners.
As a minimum, all third parties are screened using the Dun & Bradstreet “Onboard” tool, the results of which are checked by the Company’s legal and finance teams. A risk assessment is then carried out to determine whether the proposed transaction is affected by any warning signs or “red flags” which would require additional due diligence to be carried out. Where additional due diligence is required, the next level requires the completion of a due diligence questionnaire, which includes a specific section on commitment to anti-modern slavery and human rights and is reviewed by the Company’s compliance officer. Enhanced due diligence may also be carried out on third parties by a third-party provider where considered necessary by the Company’s compliance officer.
We work in partnership with all our contractors, suppliers and other business partners and we aim to leverage those collaborative relationships to ensure that they share and work towards our opposition to slavery and human trafficking.
Storegga is committed to improving its practices to combat modern slavery and human trafficking. We will continue to review the steps being taken to combat modern slavery and human trafficking in our business and supply chains and to make improvements where necessary.
This statement was reviewed and approved by the Company’s board of directors on 06 December 2023.