Xodus Modern Anti-Slavery Statement

This statement is pursuant to the Modern Slavery Act 2015 and relates to actions and activities during the financial year 2017 [January 2017 to December 2017]


Xodus Group is committed to ensuring that there is no modern slavery or human trafficking in any part of corporate activities or in supply chain.

Xodus is committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

Xodus Business

As part of the oil and gas, LNG, renewables and utilities industries worldwide, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Xodus Group currently operates representative offices in following countries:

  • United Kingdom
  • United States
  • Norway
  • UAE
  • Australia

Scope of provided business activities in all countries is assessed as low risk in relation to slavery and human trafficking.

Xodus Supply Chains

Xodus Group operates and aims to conduct its business with limited exposure to the supply chain and contractors for provision of services. Where independent services are being utilised – we expect all our contractors to comply with our business ethics and values. Noncompliance with our business ethics and values results in termination of contract.


To ensure a high level of understanding of the risk of modern slavery and human trafficking in our supply chain and business, we provide training to relevant members of staff. All senior managers have been briefed on subject.

Relevant Policies and Procedures

Xodus Group operates the following policies and procedures that aid the identification of the modern slavery risks and human trafficking in its operations:

  • Whistleblowing Policy - Xodus encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Xodus' whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. In addition to this the independent whistleblowing charity, Public Concern at Work, operates a confidential helpline.
  • Personal Conduct Policy - Xodus' code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating in country or abroad and managing relationship with contractors.
  • Recruitment and Selection Procedure - The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

We have also adapted following practice to ensure that slavery and human traffic is not taking place in any part of our business:

  • The robust recruitment process is conducted in line with UK employment laws, that includes: ‘right to work’ and ‘working age’ document checks,
  • Use of employment contract for all Xodus employees,
  • Use of payroll system for all Xodus employees, market-related pay reviewed annually,
  • Use of job descriptions for all Xodus employees,
  • Promoting wellbeing activities and initiatives to support our people’s physical and mental wellbeing and lifestyle choices.

Operations Board Approval

This statement has been approved by the Xodus Group Operations Board, who will review and update it annually.

Stephen Swindell, Managing Director

Date: 22nd January 2018