Modern Slavery and Human Trafficking Policy Statement

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1st April 2019 to 31st March 2020

The statement sets down Celtic Energy Limited’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small.? Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

Celtic Energy Limited “the company” is a leading surface mining company with its current activities being carried out solely within the UK, in South Wales.

Whilst we do not export ourselves, we sell to UK and other country buyers who do export.? Those countries are Norway, Germany, France, Belgium, Ireland and Holland.

The company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intent to act ethically in our business relationships.

This policy takes into account, and supports, the policies, procedures and requirements documented in our company handbook.

The company will achieve these aims by our initiative to identify and mitigate risk in the following, but not limited to, ways:-

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the company provides training to relevant members of staff.

Whistle Blowing

The company encourages all if its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

Risk Assessment

The Directors of Celtic Energy Limited will take into account the extent of the?organisation?s exposure to potential and external risks in relation to slavery and human trafficking acting on its behalf or by people associated with it. This?assessment will be reviewed and discussed at Board meetings as and when deemed
appropriate to assess any changes to markets, supply chains etc and will be both?informed and documented.

Due Diligence Processes

The company undertakes due diligence when considering taking on new suppliers,
and regularly reviews its existing suppliers. The company applies the following
procedures:

  • We require all new and existing members of our supply chain to comply with
    the Modern Slavery Act.
  • If a supply chain member does not comply or is convicted of any offence in
    relation to this activity then they will be removed from our supply chain.

Monitoring and Review

We use the following key performance indicators (KPI?s) to measure how effective we
are in ensuring slavery and human trafficking is not taking place in any part of our
business or supply chains including:

  • Completion of Audits by Directors, Managers, Safety Managers and Safety
    Advisors;
  • Use of labour monitoring and payroll systems; and
  • Level of communication and personal contact with the next link in the supply
    chain and their understanding of, and compliance with, our expectations.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and
updated as necessary. Celtic Energy Limited?s Board of Directors endorses this
policy statement and is fully committed to its implementation.