UK Modern slavery statement

In this statement "modern slavery” means the extraction of work or services through coercion, control or the deprivation of a person’s liberty, for the purpose of exploiting them for another’s personal or commercial gain. It includes (but is not limited to) slavery, servitude, forced or compulsory labour, and human trafficking. It is a crime and a violation of fundamental human rights.

Policy Statement

We take a zero-tolerance approach to modern slavery, and we are committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains. We expect the same standards from all of our business partners, contractors and suppliers.

Our opposition to modern slavery is reflected in our unwavering commitment to the highest ethical and legal standards in conducting our business. Our approach is anchored by our corporate values of integrity, excellence, safety, accountability and citizenship.

Steps to prevent modern slavery

We operate as a business support services entity, providing a range of administrative, technical and strategic services in support of Saudi Arabian Oil Company’s (‘Saudi Aramco’) international operations. We do not manufacture physical products for commercial sale. Instead, our activities primarily involve the coordination and delivery of corporate support functions. As such, our supply chain consists of recruitment and human resources consultancies, manufacturers and suppliers as well as other local service providers. We are committed to improving our processes, practices and policies in an effort to eliminate modern slavery in the global supply chain, and we expect all our suppliers to support our goal of tackling modern slavery.

We require our suppliers (in this statement "suppliers" means all third parties that provide goods of services to AOC including vendors, business partners, consultants, agents and contractors, whether individuals or corporate entities) to source all goods or services from third parties that meet, as a minimum, country of origin standards for health, safety, working hours, pay and employment conditions. Suppliers with which we conduct business are required to acknowledge and agree to abide by the policies and principles set forth in our Supplier Code of Conduct, or have sufficiently similar policies and principles set out in their own code of conduct, as verified by AOC's legal team, in order to commence or to continue business with us. The Supplier Code of Conduct includes provisions prohibiting modern slavery. Future procurement engagements will not be developed without either (i) a signed Supplier Code of Conduct or (ii) evidence that that supplier adopts a sufficiently similar code or codes of conduct as verified by AOC's legal team and a commitment made to adhere to such similar code(s) of conduct.

In addition to the above, we continue to implement the measures outlined below to ensure that modern slavery is not present in our business or our supply chains:

• carry out due diligence and utilise appropriate vendor selection criteria in our procurement processes, in light of the ethical standard and corporate values that are reflected in the United Kingdom's Modern Slavery Act 2015; and
• identify, monitor and assess potential risk areas of our supply chains as part of supplier screening and onboarding.

All of our employees and suppliers are expected to conduct themselves with the highest levels of integrity and in full compliance with the laws and regulations that govern our global business. This includes taking steps to prevent, detect and report incidents of modern slavery in any part of our business.

As part of our approach to preventing and mitigating the risk of modern slavery, we maintain established grievance and concerns reporting channels through which, as applicable, concerns may be raised by employees, suppliers (including employees of suppliers) and then addressed by AOC. These mechanisms are designed to ensure that individuals can report issues and concerns regarding the core business and supply chain safely, confidentially and without fear of retaliation. 

This statement constitutes AOC's modern slavery statement for the financial year ending 31 December 2025 and is made in connection with the requirement by the Government of the United Kingdom to publish a statement pursuant to section 54(1) of the Modern Slavery Act 2015.

The statement has been approved by the AOC Board of Directors.