NIPCO PLC is committed to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking are not taking place anywhere in its own business or in any of its supply chains.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including 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. NIPCO has a zero tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships.
This policy applies to all persons working for NIPCO PLC or on its behalf in any capacity, including employees, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy covers NIPCO PLC and all its subsidiaries, including NIPCO Gas Limited, NIPCO Upstream Limited, and all associated companies in which NIPCO holds a controlling interest. It applies to our operations in Nigeria and to the procurement of goods and services from our supply chain, wherever those suppliers are located.
NIPCO is committed to:
NIPCO has assessed the risk of modern slavery occurring within its operations and supply chains. We recognise that certain segments of our supply chain — including construction contractors, facility management service providers, transport and logistics subcontractors, and providers of seasonal or casual labour — carry higher inherent risk. The petroleum sector in Nigeria operates in an environment where labour informality is prevalent, and NIPCO actively manages the attendant risks through the due diligence and contractual mechanisms described in this policy.
Key risk indicators we monitor include: unusually low prices from contractors, use of third-party labour agencies without visibility of employment terms, evidence of workers living on site in inadequate conditions, inability of workers to produce personal identity documents, and patterns of unexplained absenteeism or turnover.
NIPCO takes a risk-based approach to supply chain due diligence. Our commitments include:
NIPCO provides training on modern slavery awareness to all employees in roles with supply chain, procurement, HR or contractor management responsibilities. This training covers: how to recognise the signs of modern slavery and forced labour; NIPCO's reporting obligations and internal procedures; and the legal consequences for companies and individuals who fail to address modern slavery risks. All new employees in relevant roles receive this training within 90 days of joining, and all trained employees complete a refresher course every two years.
NIPCO encourages all employees, contractors, and third parties to report any concerns related to the direct activities of NIPCO or its supply chains using the following channels:
NIPCO will not tolerate retaliation against any person who, in good faith, reports a concern about modern slavery or labour standards. Any employee found to have subjected a reporter to retaliation will face disciplinary action up to and including dismissal.
NIPCO tracks compliance with this policy through the following key performance indicators: percentage of new high-risk suppliers screened; number of supplier audits conducted annually; number of modern slavery concerns reported and resolved; and employee training completion rates. The Board Audit and Governance Committee reviews modern slavery performance annually and receives a formal report from the Group Legal Counsel. This policy is reviewed annually and updated as required to reflect changes in legislation, business activities, or risk profile.
Questions about this policy should be directed to the Group Legal Counsel at legal@nipcoplc.com.
Approved by the Board of Directors of NIPCO PLC. This policy supersedes all previous statements on modern slavery and human trafficking.