Montego Anti Modern Slavery and Human Trafficking Policy

1. POLICY STATEMENT

Montego is opposed to all forms of human trafficking and slavery and takes all necessary steps to ensure the promotion of sound, moral and ethical practices throughout the whole of its business.

This policy applies to all persons working for us or on behalf of Montego in any capacity, including Directors, Agency Workers, Seconded Personnel, Contractors, Suppliers, OEMs, Distributors, and Volunteers.

Montego prohibits the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls that ensure that modern slavery is not taking place anywhere within our organization. We expect that all our stakeholders will hold their stakeholders to the same standard.

2. COMMITMENTS

MODERN SLAVERY AND HUMAN TRAFFICKING
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. 

With this in mind, we pay particularly close attention to our supply chain, especially those areas which have historically proven to be at risk of the activities stated above:

• Outsourced activities such as cleaning
• Short term hire of low skilled labour
• Recruitment agencies 

COMMITMENTS
We shall be a company that expects everyone working with us or on our behalf to uphold and support the following measures:

1. We have a zero-tolerance approach to modern slavery in our organization and supply chain
2. We are committed to engaging with our stakeholders to address the risk of modern slavery in all our operations
3. We always ensure all staff have a written contract of employment and provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to. 
4. The prevention, detection and reporting of modern slavery in any part of our organization and supply chain is the responsibility of all those working for us and on our behalf. Stakeholders must not engage in, facilitate or fail to report that might lead to or suggest a breach of this policy, 
5. We take a risk-based approach to our contracting processes and keep them under view.
6. As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of stakeholders for their compliance with this policy.
7. If we find out that individuals or organizations working on our behalf have breached this policy, we will ensure that we take appropriate action. 

3. MONITORING OUR PROCEDURES

We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make.

This statement has been approved by the Board of Directors of Montego Upstream Services Limited together with all of its subsidiary undertakings from time to time and constitutes Montego's Slavery and Human Trafficking Statement.