U.K. Modern Slavery Act Statement
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 Dril-Quip (Europe) Limited.
As a leading manufacturer of highly engineered drilling and production equipment for onshore and offshore use by oil and gas and energy transition 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, Caspian, USA, Latin America, Singapore and Africa.
Our employment processes ensure that all employees are legally entitled to work in the UK 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.
We have a significant supply chain in the UK and also have an increasing number of suppliers located in the EU, US and Singapore, and we are committed to ensure that our supply chains will comply with the Act.
We provide periodic in-person and/or online training to our applicable HSE, QA, HR, contracts, procurement and supply chain staff on the Act to continue to raise awareness as to the requirements of the Act; help employees identify any potential slavery and human trafficking issues that may arise in our business and wider supply chain; and how to address any such issues.
Dril-Quip (Europe) Limited includes 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 will be reviewed during 2023 to ensure Dril-Quip (Europe) Limited’s expectations are being met in relation to its vendors’ compliance with the Act.
During 2022 we continued to carry out a number of meetings with vendors in relation to their due diligence questionnaire submissions and to provide guidance on the requirements of the Act. We will continue to carry out such meetings in 2023 with vendors to ensure they understand and met Dril-Quip’s expectations with regard to compliance. 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.
In addition to the above, Dril-Quip’s Supply Chain Code of Conduct and Human Rights Policy Statement further sets out our expectations of our supply chain in relation to, amongst other things, compliance with human rights and modern slavery laws. We 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.
We carry out periodical risk assessments on our own business and supply chain specifically focussing on geographic location, value and type of goods/services procured. We perform additional due diligence exercises as a result.
During 2022, we improved our current vendor verification and onboarding processes via our supply chain teams to streamline the supply chain modern slavery due diligence exercise process.
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 2022 and was approved by the board of Dril-Quip (Europe) Limited on 10 May 2023.
Dril-Quip (Europe) Limited
James Webster, Director
Date: 10 May 2023