Dril-Quip is committed to taking all reasonable steps to ensure that slavery and human trafficking is not taking place in any part of our business or in our supply chains. This Statement is made pursuant to s.54 of the Modern Slavery Act 2015 (the "Act") by DrilQuip (Europe) Limited.
As a leading manufacturer of drilling and production equipment for use by oil and gas companies in areas throughout the world, we place a high value on ethical practices and recognize that some areas pose higher risks for slavery and human trafficking. We have aftermarket and manufacturing facilities in Aberdeen, Scotland, and provide goods and services in the UK, Europe, Caspain, USA, Singapore, and Africa.
Our employment processes ensure that all employees are legally entitled to work in the country of employment and we have various safeguards in place to ensure employees are protected whilst in our employment. These include:-
- Pre-employment checks;
- Adherence to legislation in respect of the minimum wage and national living wage requirements;
- Any overtime working for hourly employees is voluntary and recompensed;
- Employee Handbook;
- Grievance, disciplinary and confidential whistleblowing procedures;
- Code of Business Conduct and Ethical Practices;
- HSE policies and procedures to ensure safe working environments.
To further demonstrate our commitment to ensuring that slavery and human trafficking is not taking place in our business, we implemented a global Human Rights Policy Statement during the financial year ending December 2020.
We have a significant supply chain in the UK and also have a small number of suppliers located in the EU, US and Singapore, working with a range of different subcontractors and vendors and we are committed to ensure that our supply chains will comply with the Act.
We provide training to our applicable HSE, QA, HR, contracts, procurement and supply chain staff on the Act to help identify any potential slavery and human trafficking and how to respond if slavery or human trafficking is suspected. This process was supervised by our legal department. We aim to provide updated training to the relevant personnel during 2021 to continue to raise awareness of the requirements of the Act and any potential slavery and human trafficking issues that may arise in our business and wider supply chain.
Dril-Quip (Europe) Limited has also included the Act as part of its vendor qualification processes by requiring vendors to complete and submit a modern slavery due diligence questionnaire together with supporting documentation to demonstrate their compliance with the Act. The due diligence questionnaire, together with supply chain procurement practices, were updated during 2020 to ensure Dril-Quip (Europe) Limited's expectations are being met in relation to its vendors’ compliance with the Act. The content of the due diligence questionnaire will be reviewed again in 2021 to ensure our expectations continue to be met. Dril-Quip (Europe) Limited's terms and conditions of purchase and supply chain contracts contain provisions to ensure our vendors comply with the Act and have the same commitment to prevent slavery and human trafficking as we do. We will not work with vendors who do not demonstrate a commitment to compliance with the Act.
During 2021, as part of the implementation of a new Environment, Social and Governance "ESG" program, a new Supply Chain Code of Conduct will also be introduced which will further set out our expectations of our supply chain in relation to, amongst other things, human rights and modern slavery. We will also continue to assess our existing practices and procedures and create additional key performance indicators to monitor and address human trafficking and modern slavery in our business and our supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2020 and was approved by the board of Dril-Quip (Europe) Limited on 12 May 2021.
Dril-Quip (Europe) Limited
James Webster, Director
Date: 14 May 2021