Port of Aberdeen Modern Slavery Statement

1. Port of Aberdeen Modern Slavery Statement 2023

Aberdeen Harbour Board, operating as the Port of Aberdeen (herein referred to as “PoA”) is publishing this statement in compliance with section 54(1) of the Modern Slavery Act 2015.

This Modern Slavery Statement has been approved by the Board of Directors of PoA on the 15th May 2023. Information contained within this statement is correct at the date of publishing. It details the steps to be taken by PoA in order to comply with the provisions of the Modern Slavery Act 2015 to aid in the prevention of modern slavery and human trafficking for the financial year ending December 2023.

2. Our Business

Port of Aberdeen is the UK’s oldest and newest port. We are building on almost 900 years of history to deliver a futureproofed expansion project.

With the largest berthage in Scotland, our extensive infrastructure, strategic location and expert supply chain make Aberdeen the port-of-choice for renewables, oil & gas, decommissioning, general cargo, cruise and ferry services.

We offer safe, professional and value-adding solutions which minimise risk and reduce project costs for our customers.

3. Our Supply Chain

PoA’s supply chain covers many goods and/or services across the harbours and covers many industry sectors. These goods and services are grouped into the following categories:

  • OPEX
  • Professional Services
  • IT Services and telecoms
  • Commercial (including operators and tenants)

Each department within the Port will have a supply chain in which it depends on, and the interdependencies of the various departments, as well as the commonality of goods and services required across the PoA results in some suppliers that have dealings with more than one department.

The PoA have in the region of 768 vendors and 500 customers across the Port estate. Many of these will have turnovers greater than £36million which will trigger the compliance requirements of the Modern Slavery Act 2015 and are required to produce a Modern Slavery Statement. PoA recognises that suppliers under this threshold can still be a risk, and in order to meet PoA’s obligations under the Modern Slavery Act 2105, these companies will need to be assessed to ensure they meet the standards necessary and there are no risks to the PoA supply chain. 

4. Our Policies

Port of Aberdeen Values

To assist in achieving the highest standards of professional behaviour from PoA employees in dealings with colleagues, customers, suppliers, and other parties with whom PoA has a relationship PoA has in place key values that all employees should encompass: Dynamic, Relevant, Respectful, Professional & Inclusive. Our values reflect a standard of behaviour that we should all aspire to in our daily activities. They are key to our joint well-being, key to the environment in which we live and key to productive relationships with our customers.

Recruitment Policy

The business has a transparent, thorough recruitment process, which serves as a deterrent for human trafficking. All applicants are required to provide documentary evidence of their right to work in the UK, and this is retained by HR on their personnel files if they are successful in their job application. PoA is committed to applying its equal opportunities policy, at all stages of recruitment and selection process.

Whistleblowing Policy

PoA is committed to conducting our business with honesty and integrity and we expect all employees to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of knowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur. As such any reports of serious malpractice will be dealt with promptly and robustly. We offer different routes of escalation to raise any concerns, as well as provide contact details for an independent whistleblowing charity to protect anyone worried about raising a concern.

5. Due Diligence

The PoA supply chain processes and procedures are currently under review to ensure they meet industry standards and carry out thorough checks on the supply chain so that there is a minimised risk to the PoA. Once in place, these processes will be reviewed on an annual basis to ensure they’re compliant and fit for purpose.

6. Risk

PoA undertakes a monthly review of all risks to the business. Once a review of the Ports processes and policies, and risk areas for modern slavery are identified, these will be included within PoA’s risk registered and monitored to ensure all risks are mitigated.

7. Training

We recognise that our employees are our greatest asset. This is why we invest in training and development opportunities for our employees to help them grow, develop and improve their level of knowledge and skills. During employee personal development reviews appropriate training will be highlighted for relevant departments and roles. As part of the continued internal training employees are to undertake, a review will be taken to identify where modern slavery awareness can be incorporated. 

8. Effectiveness in Addressing Modern Slavery

PoA understands that there is a risk of modern slavery faced by the business. We recognise that as we begin to take action to address these risks, the next steps will be to implement clear and robust processes and procedures to persistently monitor and tackle modern slavery and human trafficking. We are committed to reviewing our current approach to encompass proactive strategies that address the risk of modern slavery throughout the supply chain, as well as raise awareness throughout the Port of the potential risks associated with Modern Slavery and Human Trafficking.

Bob Sanguinetti
Chief Executive 
9th June 2023