Modern Slavery Statement

Modern Slavery and Human Trafficking Statement 2024

Slavery and Human Trafficking are terrible crimes which we are fully committed to preventing at any level in our global operations. This statement sets out the steps we have taken to identify potential risks relating to our business and to address and prevent modern slavery.

Our Business

To be recognized as the leading value creator in the well construction space, known for maximizing investment, value and a sustainable future.

Organization

Downhole Products Limited (referred to as “Varel”, “we” or “us”) is a service to the Oil & Gas global companies.

Policy on Slavery and Human Trafficking

We are a global business that runs our day-to-day operations in a consistent manner with a clear focus on proper governance of the business. Our governance model, Varel Code of Conduct, describes our Core Purpose & Strategic Intent of working throughout the entire organization. A central part of our governance structure is our Code of Conduct. The Code of Conduct applies to all parts of Varel's organization and contains details how to report potential breaches of the Code of Conduct.

Slavery and trafficking are prohibited in most national legislations which Varel complies with. Several global applicable legislations to certain countries are the ten principles in the UN Global Compact, OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and the UK Modern Slavery Act 2015. All of these international regulations and guidelines prohibit slavery and forced labor. We make these rules readily available to all employees on our intranet under the Compliance portal.

Our Code of Conduct expresses ZERO TOLERANCE for any form of modern slavery including forced - or compulsory labor, as well as for any form of child labor in any part of our business or in our supply chain. Breaches against our Varel Business Partner Code of Conduct, policies, or applicable law, can be directly reported to a manager or through our reporting tool, Ethics Hotline, which allows anonymous reporting in all jurisdictions where this is possible. All reports received are evaluated and responded to.

The Varel Business Partner Code of Conduct requires all our suppliers to not engage in or support the use of any form of forced, compulsory or illegal labor, including trafficking, child, prison labor or bonded labor. We evaluate the risk of violations of our Supplier Code of Conduct and perform audits of identified high risk suppliers. We require that suppliers, contractors, distributors, and agents make every effort to comply with the Supplier Code of Conduct, which shall be part of the business agreement any supplier has with Varel.

Derek Nixon, President & CEO
May 1, 2024