This statement is made pursuant to (i) section 54(1) of the Modern Slavery Act 2015; and (ii) The Norwegian
Transparency Act 2021 (Norwegian: "Åpenhetsloven"), and constitutes our slavery, human rights, working
conditions and human trafficking statement for the financial year ended 31 December 2022.
The Transparency Act promotes enterprises’ respect for fundamental human rights and decent working
conditions and ensures that the public have access to information about how enterprises address adverse
impacts on fundamental human rights and decent working conditions.
This statement sets out the steps taken by various subsidiaries within the Siem Industries’ group companies
to ensure that no slavery, servitude, breaches of human rights, poor working conditions, forced labour or
human trafficking is taking place in their supply chains and in any part of their own business during the
financial year ending 31 December 2022.
Siem Industries is committed to promote an ethical culture where our employees and business partners
always endeavour to act in the right way. Siem Industries is committed to safeguarding human rights across
our businesses, irrespective of the countries in which they operate. In accordance with Siem Industries
governing elements, there are clear principles and expectations for all our entities and supply chain partners
to comply with the same standards regarding human rights.
The average number of employees in the Company was 765 for 2022 (2021: 792), including onshore and
offshore employees.
The companies listed below are all part of the Siem Industries S.A. (“Siem Industries”) group.
Siem Industries S.A. is an industrial holding company that operates through autonomous affiliates. It
currently holds interests in the oil and gas services industry and renewable energy sector, ocean
transportation of refrigerated cargoes and automobiles, and finance leasing. To find out more about the
Siem Industries group please see the following link: https://www.siemindustries.com/about-us/.
Star Reefers Inc. is a subsidiary of Siem Industries and has a wholly owned subsidiary (Star Chartering
Inc.). Both Star Reefers Inc. and Star Chartering Inc. have a UK branch. Star Reefers Inc. is an operator of
three refrigerated vessels (reefers), with an average age of 13 years and total fleet capacity of approximately
2 million cubic feet. The vessels are predominantly involved in the fruit trade, in particular bananas, but can
accommodate a wide range of commodities. All vessels were redelivered to owners by the end of January
2023 and both Star Reefers Inc. and Star Chartering Inc. ceased trading thereafter.
Siem Shipowning Inc. is a subsidiary of Siem Industries and has a UK branch. Siem Shipowning Inc. group
is an owner and operator of vessels engaged in international shipping. It had a fleet of 16 vessels per 31
December 2022. The vessels are operated through subsidiaries; Siem Bulk Inc., SSI Shipowning I Inc.,
Siem Shipping UK Ltd., Siem Shipowning RoRo Ltd., Auto Marine Transport Inc. and Siem Shipowning I
Norway AS. To find out more about Siem Shipowning Inc. please see the following link:
https://www.siemshipowning.com/company/.
Siem Shipping UK Ltd. is a wholly owned UK subsidiary of Siem Shipowning Inc. and provides commercial,
operational, administrative and management support services to the companies in the Siem Industries group
of companies and to the ships managed and/or chartered by the other subsidiaries of the group. Siem
Shipping UK Ltd owns one reefer vessel. Siem Ship Management Sp. z.o.o. is a subsidiary of Siem Shipping
UK Ltd. To find out more about Siem Shipping UK Ltd please see the following link:
https://www.siemshipping.com/about-us.
Siem Capital UK Ltd provides legal, corporate and accounting assistance to subsidiaries of the group.
Siem Car Carriers AS is an indirect Norwegian subsidiary of Siem Industries, which manages vessels, and
operates a global liner service, specialising in the movement of new autos, roll on roll off (RO-RO) and
project cargo. Seven Yield 7500 PCTC 1 AS and Seven Yield 7500 PCTC 2 AS are subsidiaries of Siem Car Carriers AS, where both companies lease one PCTC vessel each from an external party. To find out more
about Siem Car Carriers AS, please visit https://www.siemcarcarriers.com/.
Siem Kapital AS is a wholly owned subsidiary of Siem Europe S.a r.l. (renamed 2023 Momentum Sarl.),
which in turn is a wholly owned subsidiary of Siem Industries. Siem Kapital AS is the owner of Siem Car
Carriers AS, and also owns and manages a few other minor investments.
Seven Yield Holding Pte Ltd is a Singapore subsidiary which delivers long term ship leasing solutions to the
industrial shipping, oil and offshore sector, through long-term bareboat charter contracts of existing and
newbuild vessels. To find out more about Seven Yield, please visit https://www.sevenyield.com/.
Siem Oil Service Invest Holdings Ltd is owned 20% by Siem Industries, which through its subsidiaries owns
and operates two offshore vessels that are employed in the oil and gas service industry and renewable
industry.
The Siem Industries group is committed to respecting human and labour rights, and to ensuring that there is
no modern slavery, breaches of human rights, poor working conditions or human trafficking in any part of its
businesses or supply chains. The Siem Industries group has established due diligence routines in this
respect for assessing and managing risks.
Our Anti-Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our
business relationships, and to implementing and enforcing controls to ensure that none of the following are
taking place anywhere in our business or supply chains: slavery, breaches of human rights, poor working
conditions, servitude, forced labour and human trafficking.
Siem Industries group of companies has procedures and measures in place to ensure decent working
conditions and a safe, healthy and equal work environment for all relevant staff in accordance with
applicable laws and regulations and carries out relevant training in this regard. Our whistleblowing
procedures provide staff with guidance as to how to raise concerns on actual or suspected wrongdoings,
including in terms of human rights and decent working conditions.
The Siem Industries group has a zero tolerance attitude towards slavery, breaches of human rights, poor
working conditions, servitude, forced labour and human trafficking. We will not conduct business with any
person where there is good reason to believe that they engage in any such conduct or do not comply with
local laws and regulations.
In addition, the Siem Industries group complies with and requires compliance with the following principles:
• employment is to be freely chosen, so that there is no forced or bonded labour;
• there must be no use of child labour whatsoever;
• working hours should not be excessive;
• human rights must be respected, preserved and protected;
• decent working conditions are maintained at all times; and
• there must be no harsh or inhumane treatment of workers.
The Siem Industries group will not conduct business with a person that does not comply with these
principles.
The companies within the Siem Industries group have carried out extensive due diligence and a systematic
review of their supply chains to identify areas in which the greatest risk of slavery, breaches of human rights
or decent working conditions, and human trafficking exists. The assessment is risk-based, emphasizing e.g.
general knowledge of the industry or product risk, geographical risk, information obtained from or about the
supplier, own experiences and evaluations, the size and significance of the agreement, and our connection
with the risk and leverage towards the supplier.
According to our latest assessments, the following risk areas were identified:
For Star Reefers Inc. and Siem Shipowning Inc. and their respective subsidiaries, including Siem
Shipowning I Norway AS and Auto Marine Transport Inc., as well as Siem Car Carriers AS:
Risks: Charterers and shippers of cargoes (e.g. fruit, vehicles, frozen foods) not adhering to principles
outlined above. Suppliers, agents and contractors (e.g. suppliers of provisions, repair yards, stevedores)
who do not adhere to these principles in the provision of goods and/or services to the Siem Industries group
of companies.
Steps taken to manage risk: inclusion in Star Reefers Inc, Siem Shipowning Inc. and Siem Car Carriers AS
Standard Terms and Conditions of wording requiring counterparties (such as charterers) to warrant that all
parties to the intended trade (including their agents, suppliers, contractors and shippers (of any tier)) comply
with local laws and regulations (including the UK Modern Slavery Act and the Norwegian Transparency Act)
and the principles outlined above. In addition, counterparties are made aware of the content of Siem
Industries' Anti-Modern Slavery Policy by receiving a copy of the Policy on request.
Risk: Crew on board the vessels managed by the shipowning companies through Siem Shipping UK Ltd and
their subsidiary Siem Ship Management Sp. z.o.o. but supplied by third party crewing agencies are not
treated in compliance with the principles outlined above.
Steps taken to manage risk: inclusion in Star Reefers Inc., Siem Shipowning Inc. and Siem Car Carrier's
Standard Terms and Conditions, to be included in all management contracts with Siem Shipping UK Ltd.,
wording requiring counterparties (such as crewing agencies) to warrant that all parties to the intended
contract comply with local laws and regulations (including the UK Modern Slavery Act and the Norwegian
Transparency Act) and the principles outlined above. Our assessments have not revealed any actual
adverse impacts or significant risks of adverse impacts that requires specific measures, besides the general
measures implemented towards our suppliers and supply chain.
Siem Industries recognise that there are health and safety risks related to work at sea where operations are
done 24/7 throughout the year. Onshore employees have risks related to prolonged sitting time, screens/
light, etc. Health and safety is our number one priority and we have a strong focus on improvement and
follow up of safety and management systems, improvement of health and safety culture, internal
assessments and audits, and towards our suppliers. There is a zero-tolerance of bullying or harassment in
any work environment. Employees are encouraged to use the whistleblowing channel to report any incident
and expect our employees to follow our Code of Conduct and comply with our human rights commitment.
For Siem Shipping UK Ltd:
Risk: an indirect risk to Siem Shipping UK Ltd via the companies it provides services to, suppliers/
manufacturers of cargoes not adhering to principles outlined above.
Steps taken to manage risk: Inclusion in Siem Shipping UK Ltd's Standard Terms and Conditions of wording
requiring charterers to warrant that all parties to the trade (including suppliers) comply with local laws and
regulations (including the UK Modern Slavery Act and the Norwegian Transparency Act) and the principles
outlined above. In addition, counterparties are made aware of the content of Siem's Anti-Modern Slavery
Policy by receiving a copy of the Policy or a link to the website where it is available.
For Siem Capital UK Ltd:
Risk: Siem Capital UK does not itself deal directly or indirectly with any entities other than group entities.
Accordingly, the review of the company's supply chains has not identified any risks other than those
addressed elsewhere in this statement.
Steps taken to manage risk: ongoing monitoring and review of risks.
For Seven Yield Holding Pte Ltd:
Risk: Owners and operators of vessels financed by Seven Yield not adhering to principles outlined above.
Steps taken to manage risk: Seven Yield will not lease vessels to any individual entity which is reasonably
believed not to adhere to the principles outlined above.
For Siem Oil Service Invest Holdings Ltd:
Risk: Charterers of vessels owned by subsidiaries of Siem Oil Service Invest Holdings Ltd not adhering to
the principles outlined above.
Steps taken to manage risk: Siem Oil Service Invest Holdings Ltd will not allow its subsidiaries to lease
vessels to any individual entity which is reasonably believed not to adhere to the principles outlined above.
Employee safety and wellbeing is important for Siem Industries. Employees can expect to be treated fair and
equal and be given the opportunity to develop and grow. They should feel respected for who they are and
what they stand for, and they should feel safe to voice their opinion. There is a zero-tolerance for bullying,
harassment, and discrimination on any grounds.
We recognise that preventing any risk of slavery, violations of human rights or decent working conditions, or
human trafficking within our supply chains is an ongoing process. Accordingly, we keep our Anti-Modern
Slavery Policy and due diligence process under regular review (at least annually), updating and improving
assessments, procedures, measures and the Policy where risk assessments determine this is required.
The day-to-day responsibility for our work on due diligence and ensuring human rights, are placed within
various units within the group and within the different subsidiaries, such as within management,
legal/compliance, HR, procurement, etc. The board of directors of Siem Industries has ultimate responsibility
for implementing this statement and providing adequate resources and investment to ensure that slavery,
breaches of human rights, poor working conditions, servitude, forced labour and human trafficking is not
taking place within our businesses or their supply chains.
We provide all our staff with a copy of the Anti-Modern Slavery Policy, in order to ensure that all persons
working in any capacity for Siem Industries and its subsidiaries have a high level of understanding of the
risks of modern slavery and human trafficking in our business supply chains.
All persons working for Siem Industries and its subsidiaries are required to confirm that they have read and
understood the Anti-Modern Slavery Policy and are required to complete a training session on an annual
basis.
Updates to the Anti-Modern Slavery Policy are communicated to all persons working for Siem Industries and
its subsidiaries via email.