Modern slavery and human trafficking statement
What we do to keep forced labour and trafficking out of our own workforce, out of the partner network we use at ports where we hold no base, and out of what we buy.
Nacrt — nije pravni savjet. Ova je stranica izrađena kao nacrt za pregled i nije odobrena od strane pravnog savjetnika. Mora se pregledati prije nego što se ova web-stranica otvori tražilicama.
This statement
This statement sets out the steps ShipCertify takes to satisfy itself that slavery, servitude, forced or compulsory labour and human trafficking have no place in its own operations or in its supply chain. ShipCertify is a Seaway Group company. It covers the trading operation and the entities behind it, including the Turkish entity Ekinek Tarım Gıda ve Denizcilik Ltd Şti, Karşıyaka tax office, tax number 329 120 5309, and the United Kingdom registered office at Office 7408, 58 Peregrine Road, Hainault, Ilford, Essex IG6 3SZ. It applies to every attendance sold under the ShipCertify name, wherever in the group the contracting entity sits and whoever delivers the work: the requirements set out here travel with the order rather than with a company name, and they are placed in the order itself. Where a supplier-qualification process needs the contracting entity for a particular scope identified, it is named in writing with the quotation, and a request to compliance@shipcertify.com is answered within five working days.
The legal position
The duty in section 54 of the UK Modern Slavery Act 2015 applies to a body corporate that carries on a business, or part of a business, in any part of the United Kingdom, supplies goods or services, and has a total turnover of not less than £36 million — the figure prescribed by regulation 2 of the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. Total turnover is measured across the organisation and its subsidiary undertakings, including those operating wholly outside the United Kingdom, so it is a group question. This page is published as supplier information and stands whichever side of that threshold the group falls: it neither claims to be made under section 54 nor asserts that the duty does not apply. It is published because customers’ supplier-qualification requirements ask for it, and because a supplier who sends technicians aboard other people’s vessels should be able to answer the question. Where the section 54 duty applies to the group for a financial year, a statement meeting the requirements of that section is approved and signed for that year as section 54(6) requires, and says so on its face; nothing on this page should be read as that statement.
Our business and our people
ShipCertify inspects, services, calibrates and tests fire-fighting appliances, life-saving appliances, bridge and navigation equipment, radio and GMDSS installations, instruments, electrical and electronic systems and lifting appliances aboard commercial vessels, issues reports and servicing or test certificates for that work, and supplies the parts and consumables that go with it. The people who do it are 28 technicians, 8 operations directors, 3 documentation staff and 2 logistics staff, working from six service bases — İstanbul, İzmir and İskenderun in Türkiye, Varna in Bulgaria, Constanța in Romania and London in the United Kingdom — on three daily shifts, 24 hours a day, every day of the year. They attend more than 1,000 vessels a year at ports drawn from the 299 in our published coverage index, across 15 regions. That workforce is recruited and engaged by us directly: we do not staff our own bases through a manning agency or a labour contractor, and where a specialist is engaged for a single attendance the engagement is direct and on written terms. Nobody pays a fee of any kind to be recruited by us or placed with us; the cost of recruitment is borne by the company and is never advanced as a loan, deducted from pay or recovered afterwards, and everyone who works for us keeps their own passport and identity documents.
Our supply chain
Work reaches a vessel in one of three ways: from one of our own six service bases; by regional mobilisation of our own technicians from a base to a nearby port; or, at a port where we hold no base, through a partner in our network. The third route is the one where the labour is not ours, and it is the larger part of our supply chain. Below it sit the local providers a partner in turn engages — launch and boat hire, transport, port labour and riggers — and the liferaft and lifeboat servicing stations whose attendances we arrange and coordinate at many ports but do not staff. Separately, the equipment, spare parts and consumables we supply are manufactured and distributed by others, several tiers away from us and largely outside the countries we operate in.
Where the risk is highest
We treat three areas as higher risk. The first is subcontracted and locally hired labour at ports where we have no base: short-notice mobilisation, payment through an intermediary and distance between us and the person actually doing the work are the conditions in which forced labour survives. The second is manufactured goods, where components in fire-fighting, life-saving and electronic equipment come from production we never see. The third is the vessels themselves, which we do not control at all and which are dealt with below. Risk is assessed by port and by partner rather than by country alone, because conditions differ sharply between terminals in the same jurisdiction. That assessment is reviewed at least once every 12 months, and again out of cycle whenever a partner joins the network, a base opens, or a concern is reported about a port or a partner; it is owned by an operations director accountable for compliance, who records what was reviewed, what changed and the date it was done. Our own model is short-notice cross-border mobilisation, and the company carries the whole cost of it: the visa and any permit, flights, ground transport, accommodation and subsistence are paid by the company directly, none of it is advanced as a loan, set against pay or recovered afterwards, and the technician keeps their own passport and travel documents throughout.
What we require of a partner
A partner is selected on technical competence first, and engaged on written terms. Those terms require the partner to pay its personnel directly and at or above the lawful local minimum, to hold no worker’s passport or identity document, to charge no recruitment fee to any worker, to use no forced, bonded, prison or child labour, and to impose the same requirements on anyone it subcontracts in turn. We ask to be told who will actually attend the vessel. A partner that will not accept those terms is not appointed; a partner found in breach is suspended from the network while we establish what happened, and removed if the breach is made out. The terms are written into the order we place for every partner attendance, so they bind the work whatever the date of the agreement underneath it, and they are carried into each partner agreement as it is issued or renewed. Acceptance is confirmed in writing before the first attendance and again at each renewal, and a partner that has not confirmed is not instructed.
Seafarers aboard the vessels we attend
Our technicians work aboard vessels crewed by others. Conditions of employment for those seafarers are governed by the Maritime Labour Convention, 2006 and are the responsibility of the shipowner and the flag State, not of us — but our people are in the accommodation, the machinery spaces and the store rooms, and they see what a shore-based audit does not. Technicians are told to notice and report crew held aboard beyond the end of their agreements, wages unpaid for months, passports or seafarers’ identity documents retained by the master or a manning agent, crew unable to go ashore, an absence of stores, fuel or fresh water, and a vessel that appears to have been abandoned by its owner. A technician who sees any of it reports it the same day to the operations director for that base, where it is recorded; the technician does not confront the master alone, and the attendance proceeds as instructed. Where the indicators point to abandonment or to unpaid wages, the route out is the port State control authority, the flag State and the ITF inspector at that port. We do not withhold a report or a certificate as leverage, and we do not make an allegation we cannot evidence — we pass on what was observed, to the body whose job it is. The operations director for the base refers the record the same day to an operations director accountable for compliance, who decides within 24 hours of receiving it whether it is escalated and to which of those bodies. Twenty-four hours is the deadline because a port stay is 12 to 48 hours, and a report that arrives after the ship has sailed helps no one aboard her; where the indicators point to someone in immediate danger, the port authority is told the same day and the decision follows.
Training
Technicians, operations directors, documentation staff and logistics staff are briefed on the ILO Indicators of Forced Labour (2012) — abuse of vulnerability, deception, restriction of movement, isolation, physical or sexual violence, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions and excessive overtime — on where those indicators show up in this trade, and on the reporting routes set out above. The two places to look are the rigger a partner brings to a Black Sea terminal at two hours’ notice, and the launch crew that runs a technician out to a vessel at anchorage: both are hired quickly, paid through someone else, and gone before anyone has asked their name. Operations directors carry the most of it, because they are the people who appoint and instruct a partner at a port we do not staff. The briefing is delivered in-house by an operations director accountable for compliance, against a written brief: at induction, before a technician’s first unaccompanied attendance, and again every 12 months, with the brief reissued out of cycle when the indicators or the reporting routes change. Operations directors take a longer session covering partner appointment and the labour terms carried in the order. Completion is recorded by the documentation staff against each person’s training record, with the date and the version of the brief, and that record is produced on request in a supplier-qualification pack.
How we measure this
Section 54(5)(e) of the Modern Slavery Act 2015 names performance indicators as one of the things a statement may cover, and a supplier-qualification pack asks for them. Four figures are stated in the reissue of this statement for each financial year: the number of firms in the partner network; how many of them have confirmed the labour terms set out above in writing; how many concerns were reported in the period and what came of each; and how many of our people completed the training. Where a figure is nil, this statement says so rather than omitting it, and a figure we cannot yet stand behind is not published in place of one we can.
Raising a concern
Anyone may report a suspected case of forced labour, trafficking or exploitation connected to our work — an employee, a partner’s worker, a crew member, a port agent, a customer or a supplier. Write to compliance@shipcertify.com, or use the hotline and WhatsApp number +90 532 657 48 78. A report does not have to be in English. compliance@shipcertify.com, the hotline and WhatsApp are not anonymous channels: an email carries your address, and a call or a WhatsApp message carries your number. We do not disclose a reporter’s identity outside the people looking into the report without their agreement. A report that must not carry a name can be sent by post instead, marked for compliance, to Office 7408, 58 Peregrine Road, Hainault, Ilford, Essex IG6 3SZ; it needs neither a name nor a return address, it is recorded and looked into like any other, and the only thing lost is that we cannot come back for detail or tell the sender the outcome. No one who raises a concern on reasonable grounds will be penalised for it, including where the concern turns out to be mistaken, and that applies equally to a person employed by a partner or by a customer. Concerns are acknowledged within the period set out in the complaints and appeals procedure on this site, and where the person has given us a way to reach them, we tell them the outcome.
Approval
This statement is published as supplier information. It is reviewed and reissued for each financial year, and the version on this page is the current one. It carries no director’s signature and is not to be read as a statement approved under section 54(6) of the Modern Slavery Act 2015; where that duty applies to the group for a financial year, the statement made for that year is approved and signed as the section requires and says so on its face. Responsibility for keeping this page current, and for reissuing it at each financial year end, rests with an operations director accountable for compliance. A supplier-qualification question about it goes to compliance@shipcertify.com and is answered within five working days.
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