Modern Slavery Act 2015

We are committed to improving our practices to combat slavery and human trafficking. Our commitment is formalised in the CMA CGM Code of Ethics which embodies the high standards demanded of our employees and our suppliers. We are convinced that by proudly demonstrating strong core values, we project our corporate practice and ethics throughout our supply chain.

1. Our Business and Organisation’s Structure

We are a provider in the transportation sector. We are a part of the CMA CGM Group, and our ultimate parent company is CMA CGM SA, which has its head office in France. The Group has over 22,000 employees worldwide and operates in more than 160 countries.

2. Our Supply Chains

Our supply chains includes, but is not limited to, the procurement of; terminal services, vessel tonnage, containers, bunkers and ship supplies, crew, warehousing, inland transportation services, information technology services and office supplies.

3. Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective safeguards to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

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 4. Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk we have in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • We mitigate the risk of slavery and human trafficking occurring in our supply chains. We ensure MLC (‘Maritime Labour Convention’) compliant seafarer employment agreements supported by internationally recognised collective bargaining agreements, negotiated with the Maritime unions. Our crewing activity is undertaken by Members of the International Maritime Employers Council based in London (‘IMEC’) a body that represents quality Ship Owners, Managers and Employers of seafarers from around the world that seeks to provide seafarers with enhanced employment terms and conditions, superior training facilities and safer working conditions onboard their members vessels. IMEC actively participates in the negotiation of collective bargaining agreements that cover all these aspects both with the International Transport Federation (‘ITF’) and their affiliated maritime unions on a global basis by means of the now well established International Bargaining Forum (IBF), together with representation at the ILO.
  • We have a positive commitment and open approach to whistleblowing. Our policy and procedure is intended to be in line with the Public Interest Disclosure Act 1998 (PIDA), the Employment Rights Act 1996 and the Enterprise and Regulatory Reform Act 2013 (ERRA). Our policy encourages our employees to raise concerns with the Company in the first instance.

5. Supplier Adherence to Our Values and Ethics

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and subcontractors understand and comply with our values, we created a Third Party Code of Conduct. This includes;

  • Human Rights, Labour Standards, Child Labour, Working Hours, Non-Discrimination
  • Health, Safety & Environment, Protection of Goods and Recourses
  • Business Integrity: Competition Laws, Corruption, Confidentiality & Compliance, Conflict of Interests and Economic Sanctions & Embargoes

We have a dedicated team, which consists of involvement from the following personnel/departments:

  • The Directors
  • Local Legal Compliance
  • Group Legal Counsel
  • Human Resources

6. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we continually assess the need to provide training to our staff.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes slavery and human trafficking statement for the financial year ending 31st December 2016.

Geoffrey Smith
Chief Executive Officer
MacAndrews & Company Limited
Date: Friday, 07 October 2016