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Modern Slavery Act Statement



This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes The Marcura Group’s (or the “Group” or “we”) slavery and human trafficking statement.

We are committed to preventing modern slavery and human trafficking throughout our organisation and in our supply chain. As a responsible and ethical Group, we demonstrate our commitment to social and environmental responsibility. In line with environmental, social and governance (ESG) best practices, we continuously explore ways to become a more responsible corporate citizen. This is demonstrated through our voluntary ESG initiatives led by our UN Global Compact (UNGC) Committees and through our memberships in The Baltic and International Maritime Council (BIMCO), The Baltic Exchange, and The Maritime Anti-Corruption Network (MACN).

We are committed to respecting the rights of our employees through our policies that uphold and promote principles of human rights outlined in the UNGC. We seek to do this in three spheres:
• In our operations, by upholding ethical values and adopting global best practices.
• In our work environment, by providing opportunities for individuals to grow professionally and personally.
• In our supply chain, by only doing business with those who do not tolerate any form of slavery, forced labour or human trafficking.

To manage risks in our supply chain, an integral part of our procurement process is the requirement that each Group supplier completes our Supplier Registration Form (SRF) and executes our Supplier Code of Conduct. The SRF helps us to better understand the environmental and social standing of the parties in our supply chain. In turn, this allows us to verify that our suppliers are aligned with universally accepted human rights principles, whilst also helping us to manage any business continuity-related risks.

The Marcura Group Structure
Marcura Holding Limited is part of The Marcura Group, which is headquartered in Dubai, UAE. The Group provides specialist support services to the maritime industry. The Group is organised into several business units including DA-Desk, Laytime-Desk, MarTrust, PortsDirect, PortLog, G-Ports, CP-Desk and MCaaS. The Group adheres to applicable laws and aligns itself in accordance with global best practices. We are committed to running our business in an ethical, professional, and customer-oriented manner. Thus, we expect Group Members to act with integrity and to conduct their affairs legally, ethically, and responsibly. This way, we can avoid irresponsible practices that are harmful to our customers or to society.

Policies & Procedures
Our Supplier Code of Conduct and Procurement Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

We encourage Marcurians to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously, kept confidential and investigated as appropriate. As part of this commitment, all Marcurians have access to the Group’s Reporting System for reporting unlawful or unethical behaviour within or related to the workplace, as described in the Reporting System Manual. This is to ensure that the Group remains committed to the aim of exposing important issues that may otherwise remain undisclosed and reassure Marcurians that their concerns are taken seriously.

Supplier Compliance Programme
We have zero-tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme, which includes:
• Completion of a Supplier Registration Form by the relevant supplier
• Completion of a Supplier Due Diligence Questionnaire
• Supplier Evaluation Process

As part of the supplier registration process, the Procurement Department request Suppliers to indicate their country of incorporation. If a Supplier is located in a high-risk jurisdiction, the Procurement Department may request additional KYC-related information. Moreover, the Procurement Department only pays Supplier invoices to a bank account that is located in the same jurisdiction, and which has the same beneficiary’s name as the Supplier, unless such discrepancy can be adequately explained by the Supplier in question.

Due Diligence
To help streamline and improve the visibility of our due diligence processes, we have developed a proprietary Marcura Entity Governance System (MEGS). MEGS is our dedicated master data and KYC platform, built on the three pillars of governance, operational excellence, and compliance, used to drive end-to-end KYC processes efficiently and effectively.

An integral part of our KYC process is the enhancement, cleansing, verification, and screening of supplier data prior to entry into MEGS. This task is performed by the Group’s Anti-Financial Crime (AFC) Team and any “red flags” are escalated to the Group’s dedicated Specialised Compliance Escalation Resolution Team (SCERT).

As part of the Group’s commitment to mitigating exposure to financial crime, we:
• perform Know-Your-Customer (KYC) checks before doing business with a customer or a supplier of services to the Group and/or activating an agent, vendor, supplier or bunker using third party and in-house screening tools,
• use an Automated Screening Manager (ASM) tool to perform continuous and ongoing daily screening of all the relevant entities (including vessels) in our databases,
• perform supplier audits.

These efforts, as well as this disclosure, are reviewed by the Group’s Senior Management Team annually and updated publicly.

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