Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
We are committed to improving our practices to combat slavery and human trafficking.
This statement is published on behalf of Braemar Plc and its subsidiary companies (together “Braemar”) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 28 February 2022.
About Braemar
Braemar is a leading international provider of expert advice in shipping investment, chartering, and shipping risk management.
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We offer a unique combination of skills and advice, with the Group’s integrated teams delivering creative solutions and tailored support for our customers around the world, placing Braemar at the forefront of the shipbroking industry.
We provide a range of highly skilled services to our clients in the shipping and energy markets through our global network of offices. We also provide technical consultancy and other services to shipowners and charterers of vessels and major energy companies.
We aim to build long-term relationships with our clients based on a deep understanding of their needs and delivery of a top-quality service. Sometimes clients are looking for a “one-stop shop” of commercial and financial services that we are well-equipped to provide.
Our assets are our people and their expertise, their client relationships, our reputation, and our corporate brand. The name “Braemar” embodies expertise, trust, reliability, respectability, and ethical conduct.
Our Supply Chains
Our services are focused on the people that underpin our operations. They are supported by functions including professional services, IT, communications, travel, and office services.
Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no form of slavery or human trafficking in any part of our business or in our supply chain.
We have policies and procedures in place to support our commitment to acting ethically and with integrity in all our business relationships. A review of our policies and procedures was completed in 2017 to determine they effectively identify, and help us to tackle, modern slavery issues. Subsequently, annual reviews of our policies and procedures have been completed, with consideration given to assessing the potential risks of slavery and human trafficking taking place in our supply chains and business.
Our internal policies have been updated and several new client-related policies have been implemented as a result of our annual reviews. Policy and process updates have included Know Your Client (KYC) due diligence processes for new client onboarding, and revised policies for ongoing periodic monitoring of all clients with monitoring frequency determined by client risk assessment rating.
Braemar’s governance training programme, which is mandatory for all employees, includes measures to help ensure workforce awareness of potential slavery and human trafficking indicators, and endeavors to ensure that slavery and human trafficking are not taking place anywhere across our business. The training programme is organised and overseen by our Group Risk and Compliance Manager to ensure a high level of understanding of the risks of modern slavery and human trafficking throughout Braemar.
In the last twelve months, we have not identified any instances of slavery or human trafficking. We continue to monitor our policies and procedures, in particular in relation to any increased risk presented due to the coronavirus pandemic.
Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk we have reflected the requirements of the Modern Slavery Act 2015 in our policies and procedures and in our working documents. We have implemented new versions of several internal policies and procedures to mitigate any risk of slavery and human trafficking within our supply chains and to ensure those procedures allow us to monitor potential risk areas within our supply chains and identify any risks that may arise.
Our KYC due diligence processes, including identification of risks presented by new and prospective clients and ongoing periodic monitoring for all clients, allows us to mitigate the risk of slavery and human trafficking occurring in our supply chains.
We have a whistleblowing policy, which looks to protect genuine whistleblowers and pursuant to which employees can highlight any risk of slavery or human trafficking within our business.
Next Steps
We periodically monitor and review all of our relevant policies and procedures to ensure that we are effectively mitigating the risks of modern slavery and human trafficking in our business.
We ensure our staff are appropriately trained to be alert to such risks through our bi-annual Governance Training Programme which is regularly reviewed and updated as deemed appropriate.
We will also continue to review the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our business, and to consider how we can improve further in the future.
This statement was approved by the board on 29 September 2022.
James Gundy
Group Chief Executive Officer
Braemar Shipping Services plc
Date: 29 September 2021
Previous versions of Braemar’s Slavery & Human Trafficking Statement can be found here: 2016/17; 2017/18; 2018/19; 2019/20; 2020/21.