Introduction

The Marcura Group ("Marcura" or "the Group") is committed to acting ethically and with integrity in all its business dealings and relationships. We have zero tolerance for any form of modern slavery, forced labor, or human trafficking within our business or supply chains. This statement outlines the actions taken by Marcura during the relevant financial year to address and mitigate the risk of modern slavery within our operations and supply chains. It is made pursuant to section 54 of the Modern Slavery Act 2015 ("MSA").

Organisation and Structure

Marcura is a global provider of technology-driven solutions for the maritime industry. Our services include payment solutions, voyage estimation tools, procurement platforms, and compliance services. We operate across multiple regions, including Europe, the Middle East, Asia, and the Americas. We carry on part of our business in the UK and are therefore required to publish this statement.

Supply Chains

Marcura’s supply chains include the procurement of goods and services necessary to support our technology platforms, as well as professional services, IT infrastructure, and facilities management. We recognise that some suppliers may operate in regions or sectors with heightened risks of modern slavery and human trafficking.

Policies and Governance

We have implemented a range of policies to combat modern slavery and human trafficking, including:

  • Anti-Slavery and Human Trafficking Policy: This outlines our zero-tolerance approach to modern slavery and our commitment to legal and ethical labor practices.

  • Supplier Code of Conduct: This sets out minimum labor standards expected from our suppliers, emphasising the prohibition of forced, bonded, or child labor.

  • Whistleblowing Policy: This provides a mechanism for employees and third parties to report any concerns regarding unethical or illegal conduct, including modern slavery.

Our compliance framework includes integrating these policies into our business processes and contractual arrangements. All suppliers are required to adhere to our standards as part of their contractual obligations with non-compliance leading to remedial action or contract termination.

Due Diligence

To mitigate the risk of modern slavery, Marcura has established due diligence processes, which include:

  • Pre-contractual assessments to identify and evaluate modern slavery risks associated with new suppliers.

  • Periodic reviews and audits of high-risk suppliers.

  • Risk assessments based on country, sector, and product-specific factors.

  • Ongoing monitoring of supplier compliance with our Code of Conduct.


Risk Management

Marcura’s risk management processes aim to identify and address areas of heightened vulnerability within our business and supply chains. Key areas of focus include:

  • Suppliers in high-risk regions identified through indices such as the Global Slavery Index.

  • Sectors with historically higher incidences of forced labor, such as manufacturing and IT hardware.

  • Subcontracting arrangements involving complex supply chains.

Training

We provide training to employees and key suppliers to raise awareness of modern slavery risks and reinforce our commitment to ethical practices. Training is tailored to meet the needs of specific roles and is delivered in multiple languages where necessary. An audit trail is maintained to track participation and completion rates.

Monitoring and KPIs

Marcura uses key performance indicators (KPIs) to evaluate the effectiveness of our actions in combating modern slavery, including:

  • Number of suppliers assessed for modern slavery risks.

  • Percentage of high-risk suppliers audited annually.

  • Number of employees and suppliers who have completed modern slavery training.

  • Reports of modern slavery concerns raised through whistleblowing channels and subsequent actions taken.

Continuous Improvement

Marcura is committed to continuous improvement in addressing modern slavery risks. Planned actions for the coming year include:

  • Expanding the scope of supplier audits.

  • Enhancing our risk assessment processes to include more detailed impact analyses.

  • Strengthening whistleblowing mechanisms to ensure accessibility and anonymity for all stakeholders.

  • Allocating additional resources to training and awareness programs.

Approval

This statement has been approved by the Board of Directors of Marcura.