Modern Slavery Statement

For the financial year 2019

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that the Unifeeder Group has taken and the steps we will continue to develop to ensure that modern slavery or human trafficking is not taking place within our business.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Unifeeder Group has a zero-tolerance approach to any form of modern slavery. We are committed to act ethical and with integrity and transparency in all business areas and to put effective systems in place to safeguard against any form of modern slavery.

Our business

The Unifeeder Group represents a dynamic logistics company providing efficient and sustainable transport solutions through a large feeder and short sea network in mainly Northern Europe, the Black Sea and the Mediterranean. Our suppliers range from vessel owners, trucking companies to ports and terminals.

Our risk areas

The Unifeeder Group only conducts business with suppliers with whom we have a contractual relationship and to whom our ethics of business are known and accepted. In the event where information received from the supplier, employees, media, the public, or law enforcement agencies indicate that there is a risk of modern slavery practices at the supplier, this supplier shall be identified as a risk area and shall be investigated further by the Group Compliance Officer.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner, i.a.:

• Internal Code of Conduct. This code explains the manner in which we behave as an organisation and as an employer and how we expect our employees to act.
• External Code of Conduct. This code explains the manner in which we expect and demand our customers, suppliers etc. to act.
• Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can assist the Group in identifying any instances of this and where they can go for help.
• Whistleblowing policy. We operate a whistleblowing policy to facilitate a neutral reporting of any suspected breaches of our Code of Conduct or policies in general. The whistleblowing facility is available for employees as well as third parties.
• Compliance policies. We have a full compliance program obligating all employees to act in accordance with our internal and external legislation, rules and guidelines.

Our suppliers

The Unifeeder Group enforces an external Code of Conduct. All suppliers must comply with the Code of Conduct and Unifeeder Group is committed to enforce the compliance. The Code of Conduct imposes obligations on the suppliers to act in an ethical manner, respect human rights and take responsibility for its employees, when supplying to the Unifeeder Group. The Unifeeder Group is prepared to make audits should there be a suspicion of breach of obligations.

Training

We conduct compliance training for all our employees and ensure that everyone knows how to report to management or via our whistleblowing channel to raise a concern, if any violations are detected or suspected.

Our performance indicators

We closely follow any reports received from employees, the public, or law enforcement agencies to indicate any potential breach of the principles of our Anti-Slavery policy.

Approval for this statement

This statement was approved by the Board of Directors on 19^th of May 2020.