o OPET INTERNATIONAL LIMITED - 2024 TAX STRATEGY

o MODERN SLAVERY STATEMENT

Introduction

This statement sets out Opet International�s commitment to identifying modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business.

Opet recognises that it has a responsibility under the Modern Slavery Act 2015 to take a robust approach to slavery and human trafficking and we are committed to preventing slavery and human trafficking.

Organisational Structure and Supply Chains

We are an oil trading and distribution Company (within the UK we are an administration office only and our Head Office is based in Istanbul, Turkey). We arrange purchase and sales of liquid fuels globally with well-established, reputable Companies based in India, Israel, Russia, Turkey etc. and our primary function is to supply liquid fuels to our Parent entity (Opet Petrolculuk.A.S.) which has petrol stations in Turkey, which operates a number of environmental and social initiatives.

Relevant Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:  

• HR Policy - We have zero tolerance policy of any threat of violence or intimidation against employee. Our policies are clearly defined and communicated to all employees. All our employees are treated fairly and equally, and are paid at least the national minimum wage. Our employees won�t be forced to work in excess of the number of hours permitted in law, and normal working hours won�t exceed 48 hours per week average unless the employee agrees.

• Purchasing Policy - The organisation is committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and internal controls. We use suppliers and service providers with excellent reputations that demonstrate recognisable environmental commitments, along with Social Responsible standards including but not limited to compliance with laws and regulations, respect for human rights, labour working conditions, equal opportunities, maintenance and promotion of information security and acceptable corporate ethics.

• Recruitment Policy - At Opet International, we often advertise and recruit directly from the market, in a fair and legal manner. Alternatively, when the use of a specific Agency is required, Opet only employs well known agencies to source workers and always verifies the practices of any new agency it is using before accepting workers from that agency.

• Whistleblowing Policy - We encourage all of our employees to report anything untoward including but not limited to anything related to the possibility of Slavery/Human Trafficking. Any conversation/report of this type is treated with delicacy and urgency it requires. Any person making such a report is guaranteed anonymity.

• Our values - Opet International values integrity above all things. Employees are made aware of the excellent personal code of conduct expected of them at all times. Opet also endeavours to ensure that this is filtered down when operating abroad and (via our Parent Company) throughout the supply chain.

Due Diligence

We undertake due diligence when considering taking on new suppliers, and review our existing suppliers on a periodic basis. Our due diligence and reviews include:

• Evaluating the modern slavery and human trafficking risks of each new supplier, included within a General Review of the Company

• We would not hesitate to terminate a business relationship with a supplier who proved to be in contravention of any legal requirements, including but not limited to the laws relating to Human Rights and Anti-Slavery/Human Trafficking.

Awareness-Raising Programme

As well as training employees, the organisation has raised awareness of modern slavery issues by circulating information to employees by way of discussing the Modern Slavery Act and all related updates and drawing their attention to the Home Office Website, for further details.

March 2019 Update

Upon retrospective review, we did not identify any high-risk Modern Slavery concerns in 2017/2018.

Opet International Ltd continues to be committed to operating in a fair and honest way with all employees, suppliers, counter-parties etc. We remain dedicated to ensuring that we do everything we can to prevent Modern Slavery and/or Human Trafficking.

Jan 2021 Update

Further to an internal review, we did not identify any new or high-risk Modern Slavery concerns on the period from 2019 to date. We are aware of the issues and remain committed to preventing all forms of Modern Slavery.

January 2023

Update OPET International Ltd continues to be committed to the eradication of Modern Slavery in all its forms. KYC processes (as carried out by our Parent Entity) have become even more rigorous over the last 12-18 months to ensure that we check, as far possible, that our supply chain is in line with our commitment to ethical working practices.

January 2024 – OPET continue to carry out rigorous KYC processes on suppliers/customers to ensure, as far as we are able, that all Companies we work with demonstrate the same excellent codes of conduct and ethical work practices. Although no new high-risk factors for Modern Slavery have been identified, we remain vigilant and committed to eradicating all forms of Modern Slavery/Human trafficking.

Board Approval

This statement has been approved by our Board of Directors (as per the company Board Resolution dated 9^th April 2019) and will be updated annually. For your further information, Opet International�s Financial Year runs from January to December.  

4^th Floor, 180 Piccadilly,London W1J 9ER

Telephone: +44 (0) 20 7930 7950 -  Facsimile: +44 (0) 20 7930 3798  - E-mail: opetint@opetint.com

�Parent Company website: http://www.opet.com.tr/en/ �