Anti-Slavery Policy

1. About this policy
Modern Slavery is not just a heinous crime but a serious violation of fundamental human rights. Modern slavery can be manifested in various forms including servitude, slavery, forced labour and human trafficking, all of which involve the deprivation of a person’s liberty for the purposes of exploiting him or her for commercial or personal gain.

The Company adopts a zero-tolerance policy towards all forms of modern slavery and is fully committed to implementing and maintaining systems to combat modern slavery. 

2. Scope
This policy applies to:

• All person working for us or on our behalf in any capacity, including but not limited to employees, directors, officers, executives, agents, interns, contractors, managers and business partners
• All subsidiaries and affiliates of the Company

3. Legal Framework
While Singapore does not currently mandate specific modern slavery legislation akin to the UK’s Modern Slavery Act, the Company adheres to:

• The Employment Act of Singapore
• The Penal Code and other relevant laws prohibiting trafficking and exploitation
• International standards including the UN Guiding Principles on Business and Human Rights and the International Labour Organization (ILO) conventions
 
4. Our Commitment
We will:
• Not tolerate any form of modern slavery or human trafficking
• Conduct due diligence on vendors, customers, contractors, agents and business partners to assess risks
• Include anti-slavery clauses in contracts where appropriate
• Provide awareness to staff on identifying and reporting concerns
• Encourage whistleblowing and protect those who report in good faith

5. Compliance
All employees, vendors, customers, contractors, agents and business partners must read, understand and comply with this policy. All employees, vendors, customers, contractors, agents and business partners must do their utmost best to prevent and report modern slavery if discovered.

In the event where anyone becomes aware of or suspects that modern slavery is present in the business or operations processes of the Company, they should immediately report this to the Designated Officers or via email to whistleblower@britoil.com.sg . Openness is encouraged and the Company will support and protect anyone who raises genuine concerns in good faith.
 
6. Communication and Awareness
Our zero-tolerance approach to modern slavery is communicated at the outset to all significant stakeholders including employees, agents, contractors, vendors, customers and business partners.
 
7. Breaches of this Policy
Any employee who breaches this policy shall be subject to disciplinary action which could include dismissal for misconduct. We may terminate our relationship with other parties and organizations if they are found to have breached this policy.

8. Responsibility for the policy
The Governance Committee (which comprises of CEO, CFO and HR) has overall responsibility for this policy and the Designated Officer has day-to-day responsibility for it, including but not limited, investigation on any complaint. This policy will be reviewed periodically.

9. Contact
 DESIGNATED OFFICER Iris Chua
 HR & Administrative Manager
 Email: whistleblower@britoil.com.sg