Rowan International Ltd Modern slavery statement 2025

Modern slavery is a term used to describe slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking.  Modern slavery is a crime and a violation of fundamental human rights

We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our company.  This policy applies to all people working for us or on our behalf in any capacity.

We expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• A zero-tolerance approach to modern slavery
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain.
• Employees must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy

Our policies

To ensure we raise awareness of modern slavery and colleague responsibilities, we have the following internal policies:

• Code of conduct that includes how we expect colleagues to behave towards each other and outside agencies whilst at work and the requirement to obey the law. This policy also encourages colleagues to speak up about anything they experience or hear that concerns them
• Raising concerns including whistleblowing policy that covers reporting criminal acts, non-compliance with legal obligations, health and safety breaches or modern slavery concerns.
• Health and safety policy that sets responsibilities on working safely and to take care of the safety of others who may be affected by what we do or fail to do
• Our Equality statement that shares our commitment and expectations of promoting fairness and inclusion throughout the company, so our working practises and culture is respectful and encouraging of everyone, so they can give their best.

These policies form part of our employee handbook which is sent to all new starters and is available for current colleagues via our company intranet and information drives.

Due diligence processes

We undertake an annual review of our top 10 customers and suppliers to check they have publicly shared their actions against modern slavery, if they are required to do so.

We also commit to checking that third party organisations (recruitment agencies, contractors, most frequently used logistics companies) have a commitment in place to prevent modern slavery, if required.

Risk assessment and management

We commit to acting transparently and disclosing information about any modern slavery risks we have identified and what actions we have taken in response to them. 

We understand that preventing modern slavery is an ongoing, evolving process and we commit to developing our approach to identify and prevent risks appearing in our operations and supply chains.

Training on modern slavery and trafficking

We have on-demand modern slavery and trafficking awareness training available for our colleagues.  This is so they are informed of how to identify modern slavery and what action they can take to share their concerns.

Progress

We committed to undertaking 4 specific actions to better understand the risks of Modern Slavery in our Company and we have worked through these, summary below. 

1. Our first action was to review our people policies and update our handbook to include anti-modern slavery commitments and responsibilities. This has been completed and will be an annual ongoing action.
2. We committed to making modern slavery and trafficking awareness training available for all colleagues. The purpose was to inform colleagues on how to identify modern slavery and what action they can take to share any concerns.  We now have awareness videos available on-demand via our intranet site for all colleagues to access.
3. We pledged to review our top 10 customers, suppliers and hauliers, to check whether they have publicly shared their actions against modern slavery. We found that of the companies who met the criteria required to publish a modern slavery statement, they have done so.
4. In 2023 we stated that we would develop KPIs to measure the effectiveness of our due diligence procedures in preventing modern slavery risks appearing in our operations, suppliers, customers and third party partners. We did not feel it was necessary to create KPIs but instead to proactively check statements and commitments as part of our due diligence process.  This will be a continued area of focus for us over the next 12 months.   

Commitment for the next 12 months

Over the next 12 months we plan to focus on 2 specific actions that will help us in our duty to prevent modern slavery.  These are:

1. Working with our logistics providers who do not have a modern slavery statement, to understand how they identify and prevent modern slavery risks in their organisations. This is specific to haulier companies because we feel they are at higher risk of being exposed to human trafficking and modern slavery.
2. We will continue to inform and raise awareness of modern slavery amongst our colleagues so they know how to detect modern slavery and know what action to take.

The responsible officer for ensuring compliance with our Modern Slavery statement is Sarah Guest, Managing Director.  The Board of Directors have reviewed and approved this statement on (June 2025)

Signed by Sarah Guest, Managing Director