Modern Slavery and Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1 April 2024 to 31 March 2025. It sets down Sterling Petroleum Ltd’s commitment to preventing slavery and human trafficking in our business activities and the steps we have in place to help ensure there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small; staff are expected to report concerns and management will act upon them. 

Organisational structure and supply chains

Who we are. Sterling Petroleum Ltd operates multi–site fuel service stations and forecourt retail stores across the UK. Activities include fuel retailing, forecourt shop operations, car- wash/jet–wash services and related property maintenance. 

Where we operate. United Kingdom (primarily England and Wales). 

Our supply chain. Major and independent fuels wholesalers; FMCG and convenience wholesalers; facilities, cleaning and security contractors; maintenance and engineering providers; construction and fit–out contractors; waste management; IT, POS and payment services; and providers of uniforms/PPE and other goods that may be manufactured overseas. 

How we assess risk. We apply risk–based supplier tiering that considers: sector (e.g., labour- intensive services), geography of manufacture, use of subcontracting/agency labour, and spend/criticality. Higher–risk categories (e.g., cleaning, construction/fit–out, agency labour, imported merchandise) receive enhanced due diligence and contractual controls. 

High–risk activities: 

  • Use of temporary or agency labour on forecourts and in shops. 
  • Construction/fit–out and reactive maintenance involving multiple subcontractors.
  • Procurement of uniforms/PPE and certain retail goods manufactured outside the UK.

Responsibility for our anti-slavery initiatives

Policies: Owned by the Operations & HR function, reviewed annually against sector best practice. 

Risk assessments: Led by Health, Safety & Compliance, with input from Procurement and Operations. 

Due diligence: Procurement performs supplier onboarding checks; Site Operations monitor labour practices day–to–day; Finance/Legal maintain contractual clauses and audit rights.

Training

All new starters complete modern slavery awareness training during induction (within 30 days). Managers, buyers, and site leaders complete annual refresher e–learning covering red flags in labour practices, supplier risk indicators, and reporting channels.

Policies

  • Whistleblowing Policy – encourages workers, customers, and partners to report concerns relating to our activities or supply chains, with protections for whistleblowers.
  • Code of Conduct – sets expected behaviours for colleagues and contractors on human rights and labour standards. 
  • Supplier Code of Conduct – requires suppliers to prohibit forced labour, child labour, and human trafficking; to provide safe working conditions; and to allow audits.
  • Recruitment & Agency Workers Policy – mandates right–to–work checks, prohibits recruitment fees, and requires agency vetting. 
  • Anti–Bribery & Corruption Policy – supports transparent supply–chain conduct.

Due diligence in our supply chains

When onboarding or renewing suppliers, we: 

  1. Require acceptance of the Supplier Code of Conduct and relevant contractual clauses (including audit/termination rights). 
  1. Screen for sector/geography risks and, where applicable, obtain modern–slavery questionnaires/certifications. 
  1. Verify labour agency licensing and right–to–work processes; prohibit retention of identity documents. 
  1. Conduct site visits or independent audits for higher–risk categories; require corrective- action plans where issues are found. 
  1. Maintain a central register of concerns and outcomes; escalate serious issues to senior management/Board.

Measuring effectiveness (KPIs)

  • 100% completion of induction training for new starters; >95% annual refresher completion for managers/buyers/site leaders. 
  • Supplier coverage: 100% of new higher–risk suppliers risk–assessed before first order; annual re–assessment for existing higher–risk suppliers. 
  • Right–to–work: 100% verification for employees and agency workers engaged on our sites. 
  • Incidents & remediation: number of concerns raised, audits conducted, findings closed within agreed timelines; zero tolerance for unresolved serious breaches.

Continuous improvement

In FY2025/26 we will: extend supplier training materials; pilot unannounced spot–checks with selected labour providers; enhance subcontractor mapping on maintenance projects; and publish a short guide for store managers on spotting and escalating labour–exploitation risks.

Approval

This Statement was approved by the Board of Directors of Sterling Petroleum Ltd on 1 September 2025

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