Modern slavery and human trafficking transparency statement.
This statement sets out the procedures that Hunting PLC (“Hunting” or “the Group”) has implemented during 2021 to evaluate the risk of slavery and human trafficking occurring within the Hunting group and within its known external supply chain. This statement also outlines the procedures to address slavery and trafficking which the Group intend to develop in future years.
In compliance to Section 54 of the Modern Slavery Act 2015 this statement, approved by the Hunting PLC Board of Directors on 1 March 2022, was signed on behalf of the Board by Jim Johnson, Hunting PLC’s Chief Executive.
Further information on Hunting’s ethical employment and trading policies can be found here.
This statement also provides compliance to the Modern Slavery Act for the following UK subsidiaries of the Hunting group:
- Enpro Subsea Limited
- Enpro Subsea Operations Limited
- Enpro Subsea Group Limited
- Hunting Energy Holdings Limited
- Hunting Energy Services (International) Limited
- Hunting Energy Services (UK) Limited
- Hunting Energy Services (Well Intervention) Ltd Limited
- Hunting Energy Services Overseas Holdings Limited
- Hunting Oil Holdings Limited
- HG Management Services Ltd
- Hunting Knightsbridge Holdings Limited
- Huntfield Trust Limited
- Huntaven Properties Limited
- Stag Line Limited
Jim Johnson, Chief Executive
31 March 2022
Group structure & business
Hunting is an international energy services group, providing high-end products and services to the global oil and gas industry. The majority of our revenues are derived from partners operating within the upstream segment of the energy industry.
Hunting’s global businesses employ approximately 1,949 members of staff in 11 countries. In 2021, Hunting reported revenues of c.$521 million.
Hunting’s global businesses are organised into four operating segments: Hunting Titan: Hunting Titan segment manufactures and distributes perforating products and accessories. The segment's products include the H-1, H-2, H-3 and ESUB Perforating Systems and the EQUAfrac™ shaped charge technology. The business has manufacturing facilities in the US, supported by a distribution centre network across North America.
North America: The North America segment incorporates Hunting’s US and Canada businesses that supply premium connections, OCTG, subsea equipment, intervention tools, electronics and complex deep-hole drilling and precision machining services for the US and overseas markets. The segment also includes the Group’s small US oil and gas production business.
Europe, Middle East and Africa: The segment derives its revenue primarily from the supply of OCTG and well intervention equipment to operators in the North Sea. Revenue from the Middle East and Africa is from the sale of in-field well intervention services across the region which also acts as a sales hub for other products manufactured globally by the Group.
Asia Pacific: Revenue from the Asia Pacific segment is primarily from the manufacture of premium connections and OCTG supply. Asia Pacific also manufactures perforating guns.
2021 market conditions & COVID-19
The COVID-19 pandemic has continued to impact the demand for oil and gas and as a result, the Group has again reported lower revenue and trading losses in the year.
The Group has, however, endeavoured to continuously engage with all major parts of its supply chain during the year, to ensure we continue to deliver for our customers. Due diligence procedures, as noted below, have continued throughout the year, with many meetings with suppliers being held virtually.
The Board has considered the impact of COVID-19 on our supply chain and no material issues have been identified or circumstances that have changed our modern slavery procedures and monitoring.
The global oil and gas industry is slowly returning to growth and in line with this trend, more normal supplier meetings and engagement will be restored.
The oil and gas sector is a global industry and as a supplier to this industry Hunting’s customer and supplier chain network involves relationships with many operators within the market.
Certain of the Group’s product lines are manufactured and supplied directly to exploration and production companies, which are termed “end-users” as these customers are ultimately responsible for the exploration, development, production and maintenance of oil and gas reserves. In 2021 approximately c.20% of revenue came from this section of our customer base. Other major customers of the Group are international oil and gas service groups, where it is common that the end-user of our products is not known to us. In 2021 approximately 75% of revenue came from this section of our customer base.
Major suppliers to the Group include global steel mills and raw material suppliers.
Hunting has published a number of policies which describe the Group’s approach to commercial business and the way it interacts with all of its stakeholders, whether that is employees, customers or suppliers.
In 2011 the Group published its Code of Conduct which can also be found here. The Code covers a broad range of ethical policies which our employees and business partners are encouraged to adhere to.
In 2017 Hunting published its Ethical Employment and Trading Policy which commits the Group to a zero tolerance stance on slavery and trafficking within the organisation and encourages our business partners to share in these values. This policy can be found at the same website location as the Code of Conduct.
Hunting also has bribery and corruption and sanctions compliance policies in place. Training on these policies is also part of our induction programme for employees, where relevant.
Since 2011, Hunting has operated a confidential reporting service whereby employees can report matters of concern including health, safety, employee welfare, ethics or any other business practice.
Reports to this service are reviewed by the Group Company Secretary and Senior Independent Director, who direct appropriate actions in response to these reports.
In 2018 the Company rolled out a new Code of Conduct training course to all employees. Included in the content of the course was information on the Modern Slavery Act and provided working examples for employees to note which raised the awareness of the issue.
Throughout 2021 each business unit within the Group continued to submit a risk assessment of its major customers and suppliers. The assessment required each business partner to be evaluated on a “country risk” basis, where those countries deemed to be higher risk locations for slavery and trafficking were highlighted. Analysis of “supply chain transparency risk” was also applied to enable each business to understand where our business partners sit in the industry supply chain whether that be as an “end-user” or “materials originator”. Approximately 1,000 customers and suppliers to the Group were evaluated by this process.
Each business partner highlighted in this process has been sent copies of our Ethical Employment and Trading Policy and Code of Conduct to encourage all our major business partners to adopt these ethical initiatives.
In parallel to this exercise the Group has also completed due diligence on its global employment practices to confirm its recruitment and ongoing employment procedures. The conclusion of this internal exercise was that slavery and trafficking was a low risk to the Hunting group, given the main locations of the Group’s operations being in North America, Europe and Singapore.
Hunting also has due diligence capabilities in the form of risk analysis software provided by Dow Jones. The software has the ability to provide information on Hunting’s customers and suppliers and provides media coverage on these third parties. Modern Slavery and general Ethics compliance of these third parties is monitored and assessed prior to entering a new business arrangement.
The Group’s risk assessment is refreshed on a six-monthly basis to ensure our policies are communicated to existing and new business partners.
Further, Hunting’s Internal Audit function has enhanced certain of its procedures to ensure business partner identification and evaluation is appropriate.
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