Modern Slavery Statement
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking: all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Policies and Supplier Adherence
Ocean Partners Holdings Limited and its various worldwide subsidiaries (collectively “OPHL”) have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in our business dealings and relationships throughout the world and to implementing controls to safeguard against modern slavery taking place anywhere within our own business or our supply chains.
Our Business and Supply Chains
Ocean Partners is a trader of base metal ores and concentrates, primarily dealing directly with miners, smelters and refiners to whom it also offers and provides technical, commercial and financial advice. Ocean Partners primarily trades within the Copper, Lead, Zinc, Gold and Silver markets, whilst also operating in the secondary markets.
The group has a global reach and contracts with companies situated in many different countries to buy and sell material. Whilst its main trading offices are in the UK, US, Mexico and Peru it also retains a strong presence in Hong Kong, Taiwan, Canada, Mongolia, Australia, South Africa and China and has a network of agents worldwide. The group employs in the region of 120 people of which approximately 30 are based in the UK.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also require our business partners to provide training to their staff and suppliers and providers.
Commitment to our People
OPHL is committed to providing its staff with a salary which for employees in the UK at least meets the National Living Wage and offers the required statutory leave entitlement and this is consistent in the other jurisdictions we operate within whereby we offer local living wages and comply or exceed local statutory employment benefits. In the UK, we are able to utilise the skills of employees from across the world, and we ensure all our staff have provided their National Insurance Number, and Working Visa if applicable, prior to their employment and perform the necessary checks to determine their eligibility to work in the UK and ensure their salary will be monitored by HMRC.
OPHL understands that the inherent nature of international trade makes it difficult for absolute confidence in the measure of the Modern Slavery Act 2015 being adhered to throughout the chain but is confident that the following measures minimise the risk:
- All staff have been made aware of the Modern Slavery Act 2015 and its provisions.
- Strong personal relationships with customers and suppliers through all levels of a company are key to OPHL’s business and staff regularly travel worldwide to visit mines, smelters, refineries and warehouses and attend numerous industry conferences. The nature of those regular visits and close relationships allied to the competitive nature of the industry means it would be highly likely for news of improper practices to become open knowledge.
- All new customers and suppliers go through detailed compliance checks including criminal background checks for all directors and officers.
- OPHL’s Sale and Purchase contracts have clauses whereby customers and suppliers confirm initial compliance with the Modern Slavery Act 2015 and commit to ongoing compliance. A breach of this clause in our contracts permits OPHL to immediately terminate the contract.
- OPHL will not transact with any suppliers or customers who have committed an offence under the Modern Slavery Act 2015 or known to be under investigation for an offence under the Modern Slavery Act 2015.
Assessment of Effectiveness in Combating Modern Slavery.
We use the following key performance indicators to measure how effective the steps we have taken have been:
- Staff training levels.
- Actions taken to strengthen supply chain auditing.
- Steps taken to upskill high-risk suppliers and assessing their ability to detect and mitigate modern slavery in their supply chains.
- Investigations into any reports of Modern Slavery and how they were resolved.
Approved by the Board of Directors.
Issued for the year ended 31 December 2016
Ocean Partners Holdings Ltd – Annual tax strategy
Ocean Partners Holdings Ltd and all of its subsidiaries (“The Company”) is an international Metal Trading Group with operations in 8 countries across the world. The Parent Company is a private limited company incorporated in England & Wales.
Our tax risks
The key tax risks identified are:
- Compliance risk: The risk that tax submissions or payments due in a particular jurisdiction are not made when required.
- Transaction risk: The risk that trading activities undertaken are done so without sufficient regard to local tax regulations.
- Reputational risk: The risk to the Company arising from the wider impact of the tax strategy enacted, with respect to our suppliers, customers and other stakeholders.
Management of tax risks
While the board oversees the tax strategy as a whole, tax compliance in each country of operations is delegated to a local level where local specialists are engaged.
The Company assesses the tax liabilities due as a result of profits generated in a jurisdiction, and does not seek to reduce tax liabilities through the artificial rerouting of profit streams. The board feel that this practice of assessing tax as a result of trading, as opposed to trading as a result of tax, ensures that the risks identified above are mitigated.
As a result, the Company does not have a separate UK tax strategy.
Our attitude to tax planning
The board does not advocate aggressive tax planning and tax is paid where it falls due. Turnover is high due to the nature of the business but the Company considers the underlying business to be more akin to a smaller organisation. The Company’s staff numbers reflect this and it retains no specialist tax employees within the organisation. External advice may be sought on an ad hoc basis on a range of matters, in particular for areas of complexity, to ensure it meets filing obligations and other tax requirements. Furthermore, the Company does not have significant subsidiaries placed in ultra-low tax jurisdictions.
The Company would expect all employees to adhere to the relevant tax laws it is subject to and act within the spirit in which they were intended.
The level of risk in relation to UK taxation that we are prepared to accept.
Elimination of tax risk entirely is not feasible but the Company’s aim is to keep the UK tax risk as low as possible. This is to be done by:
- submitting all UK tax returns on time and have filing positions supported by appropriate evidence;
- paying the correct amount of tax on time;
- being transparent with HMRC in its dealings, in particular if the Company takes a different view to HMRC on a tax position;
- ensuring tax accounting arrangements to comply with the Senior Accounting Officer (SAO) provisions.
Working with HMRC
The Company has a good relationship relationship with HM Revenue & Customs, and has consistently been assessed as low risk. The board are proud of this and they endeavour to maintain this assessment through the policies outlined above.
The Company regards the publication of this tax strategy as complying with the duty under paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish the Company’s tax strategy in the current financial year.
Ocean Partners Holdings Limited