Modern Slavery Act
Introduction
Arrow Shipbroking Group (“Arrow“) is committed to ensuring acts of modern day slavery and human trafficking do not exist within its business or supply chains. Arrow acknowledges its corporate responsibility to the UK Modern Slavery Act 2015 and will seek to ensure transparency within its organisation and with suppliers to Arrow.
Arrow’s Code of Business Ethics and Conduct and Anti-slavery Policy reflect its commitment to acting ethically and with integrity in all its business relationships.
About Arrow
For more than 25 years Arrow has grown and consolidated its position as one of the world’s largest independent shipbroking groups. With offices in 14 countries Arrow offers truly global coverage. Its highly experienced and focussed teams provide professional brokerage services across a number of major commercial shipping sectors. Further details regarding Arrow Shipbroking Group and the areas and offices in which it operates are available on Arrow’s website https://arrowship.com/ .
Arrow has experts working in a number of key areas of shipbroking: dry cargo chartering, tanker chartering, ship sale and purchase, asset finance and valuations. In addition, Arrow has an in-house derivatives brokerage that covers freight futures.
Arrow’s Research division gathers and analyses global data and turns it into insightful and actionable data for the whole of Arrow, its associated companies and its many clients who wish to manage risk and make better informed decisions.
Arrow Shipbroking Group is headquartered in London and its principal parent company is Arrow Shipping (U.K.) Limited. This statement is published on behalf of Arrow Shipping (U.K.) Limited and the Arrow Shipbroking Group.
Recognition of Modern Slavery and Human Trafficking
Arrow recognises that slavery, forced labour, servitude and human trafficking is a growing global issue. Arrow is firmly committed to identifying and where applicable removing it from its operations and supply chain.
Arrow supports an ethical behavioural culture within its group. All employees, contractors, agents and third parties who undertake work on its behalf are expected to comply with applicable law and follow relevant/applicable Arrow policies.
Any concerns by an employee of Arrow are required to be notified promptly to Arrow’s legal function, who will promptly review the same in order to take such action as is required to seek to resolve the issue.
Supply Chain
Arrow has reviewed its supply chain for its most recent reporting period.
Arrow’s main business of shipbroking is carried out by its people. The broking teams are supported by Arrow central functions such as accounting, IT and legal. Arrow’s third-party supply chain is therefore limited and principally comprises legal support, IT support, company secretarial support, cleaning support and some residual COVID related hygiene support. In the latter two cases, such service providers are well known national companies that have their own modern slavery statements and professional accreditations. In the case of its main provider of legal support services, the relevant LLP has published a Slavery and Human Trafficking Statement which describes its zero tolerance approach to modern slavery and human trafficking.
Our Policies on Slavery and Human Trafficking
Arrow has zero tolerance to slavery and human trafficking and is committed to acting ethically and with integrity in all our business dealings and relationships across the world. This commitment includes maintaining internationally-recognised human rights. We expect all those in our supply chain to comply with our values.
Arrow’s Code of Business Ethics and Conduct and Anti-slavery Policy reflect its commitment to acting ethically and with integrity in all its business relationships. This is available on our website and highlighted upon request to key counterparties. This code is available at https://arrowship.com/code-of-business-ethics-and-conduct/.
Arrow takes all reasonable and practical steps to ensure that all applicable legislation and regulations are complied with, including procurement and labour laws. In addition, Arrow’s standard client terms and conditions require compliance with all applicable laws.
Arrow also has an anti-slavery policy applicable to Arrow staff, as well as a whistleblowing policy that allows employees to easily report any issues on this topic without fear of retaliation or negative consequences for them.
Our People
Individual human rights are a core element of any ethically responsible company. We value our team and believe that the diversity that they bring to our organisation makes us stronger and helps us to achieve our best. Any discrimination based upon race, religion, nationality, gender, age, marital status, disability, sexual orientation or political affiliation is strictly prohibited within Arrow and such prohibitions are expected within Arrow’s suppliers.
Arrow has a staff handbook and a number of related HR and compliance policies including on important topics such as anti-slavery, anti-corruption, anti-bullying, employee privacy notice, equal opportunities, and privacy. The handbook and policies set out the standards Arrow expects of staff.
All UK-based employees are paid at least the National Living Wage and we do not pay any employee in cash.
With regard to recruitment: (i) Arrow undertakes all right to work checks required by law; and (ii) only works with reputable recruitment agents (in the limited instances where Arrow works with such agents).
Next steps
We understand that this process is in a constant state of evolution and continual improvement and Arrow is committed to keep reviewing and where appropriate updating its policies and processes to ensure we implement the correct procedures where necessary.
We are regularly reviewing the terms and effectiveness of the current arrangements in order to improve our understanding and awareness of the risks of modern slavery and human trafficking in our supply chains and in our business, and to mitigate these risks.
We will continue to review the effectiveness of the steps we have taken to seek to ensure that there is no slavery or human trafficking in our business or in our supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Arrow Shipbroking Group’ slavery and human trafficking statement for the current financial year.
Approved and signed on behalf of the board of Arrow Shipping (U.K.) Limited on behalf of Arrow Shipping (U.K.) Limited and the Arrow Shipbroking Group.
Alexander Kinloch, Chief Financial Officer
Arrow Shipbroking Group
Dated: 27 May 2022
