Modern Slavery Transparency Statement

This slavery and human trafficking statement has been published to demonstrate the Company’s firm commitment to ethical business practices and pursuant to section 54(1) of the UK Modern Slavery Act 2015. It constitutes our statement for the financial year ending 31 December 2021.

Introduction from the Chief Executive Officer

This statement relates to the operations of Storegga Ltd and its affiliates including Pale Blue Dot Energy Ltd. For the purposes of this statement these firms are together referred to as the “Company”, “we”, “our” or “us”. We are committed to implementing robust and appropriate procedural practices to evidence the measures that we take to combat the risk of slavery and human trafficking occurring in our operations or supply chains. We have a zero-tolerance approach to modern slavery across all areas of our organisation, as well as in our supply chains. We are committed to ensuring that we are not connected to modern slavery in any way.

Organisational structure

The Company exists to champion and deliver carbon storage (CCS), hydrogen and other subsurface renewable projects in the UK and internationally. With our team of around 90 staff members our operations are currently solely based in the UK. Further information about our global services, industries and locations can be found at

Our policies on slavery and human trafficking

An anti-slavery policy has been rolled out to all our staff to formalise the principle-based approach adopted by the Company to date. In support of this policy, existing internal compliance commitments and training includes a focus on promoting a risk-based approach to due diligence being conducted on potential suppliers.

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 in any part of our organisation or supply chains at the earliest possible stage through defined reporting lines.

We deliver our services through our high-quality staff and as such we have robust recruitment practices supported by representatives of our HR team. Checks include 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

We are committed as an organisation to tackling modern slavery and human trafficking and want to work with suppliers and other business partners who share our values. Going forward the Company will take steps to embed and enhance the implementation of a risk based approach and assessment of new suppliers and business partners. Any need for additional due diligence in support of that process is and will be assessed on a case-by-case basis.

We work in partnership with all our contractors, suppliers and other business partners and, going forward, we aim to leverage those collaborative relationships to ensure that they share and work towards our opposition to slavery and human trafficking. To manage this, as part of our contracting processes, we will work to include specific prohibitions on the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect our suppliers to hold their own suppliers to the same high standards.

Where we have sub-consultants or sub-contractors providing services on our behalf we require them to comply with terms which, going forward, will include reference to the legal obligations and principles outlined in the Company’s anti-slavery and human trafficking statement.

Further Steps

The Company has considered the effectiveness of the steps it has taken to ensure that there is no slavery or human trafficking in its supply chains. As set out in this statement, the Company has identified areas of improvement and instigated a set of actions to address these. The Company is committed to improving its practices to combat slavery and human trafficking. We will continue to review the steps being taken to combat modern slavery and human trafficking in the Company's business and its supply chains and to make improvements where necessary.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and was approved by the Company’s board of directors on 22 September 2022.