Statement under the UK Modern Slavery Act for financial year ending 31 December 2025
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and sets out the approach which ONE-Dyas UK Limited, ONE-Dyas E&P Limited and their affiliates (together “ONE-Dyas”, or “we”) have taken to understand potential modern slavery risks related to our business and the actions undertaken to mitigate any such risks during the financial year ending 31 December 2025.
Values and policies
ONE-Dyas recognises its responsibility to respect human rights in all aspects of doing business and have embedded human rights in our values, Code of Conduct, Health, Safety and Environmental (“HSE”) policy, Speak Up policy and Supply Chain Management policy. ONE‑Dyas is advancing its comprehensive Environment, Social and Governance (“ESG”) strategy and action plan—initiated already in 2020 — to further strengthen the prioritisation and ongoing improvement of the company’s material sustainability topics. As part of this process, employee well-being and impact on local communities were identified as areas of importance and focus.
In 2023, ONE‑Dyas began preparing for the EU Corporate Sustainability Reporting Directive (“CSRD”) and the European Sustainability Reporting Standards (“ESRS”), completing an initial gap assessment of data, processes and controls, as well as a Double Materiality Assessment (“DMA”) that identified the company’s key impacts, risks, and opportunities across areas such as responsible labour practices, fair and secure employment, equal opportunities, and community engagement. However, recent simplification proposals from the European Commission—introduced in February 2025 as part of the Omnibus package and politically agreed by the European Council, European Parliament, and Commission in December 2025—have significantly reshaped the CSRD framework. These reforms postpone disclosure obligations for in‑scope companies by two years and raise the threshold for mandatory reporting to entities with more than 1,000 employees. If adopted and implemented, these changes would place ONE‑Dyas out of scope of CSRD. In response, during 2025, ONE‑Dyas (re)confirmed its commitment to disclose certain information and has redirected its efforts toward a focused voluntary sustainability report for 2026 that leverages the existing CSRD groundwork, prioritises topics of material relevance to stakeholders, and ensures disclosures remain transparent, proportionate, and aligned with the company’s scale and context.
In 2025, ONE‑Dyas continued implementing its Supply Chain ESG Policy—introduced in 2022—by further embedding environmental, social, and governance considerations into daily procurement and contractor oversight. Building on 2024 progress, efforts focused on strengthening ESG elements in risk assessments, supplier screening, tender evaluations, and due‑diligence processes. Work followed the five principles of the Supply Chain action plan: raising ESG awareness, improving transparency and traceability, collaborating with suppliers to support responsible practices, integrating ESG into procurement activities, and a more consistently tracking progress.
Our internal policies cover, amongst others, freedom of association and the effective recognition of the right to collective bargaining and the prohibition of forced or compulsory labour. Next to that, our policies include principles to ensure that our ethics and human rights standards are upheld. This includes that we will seek to provide a working environment that is free from harassment and disrespectful conduct, that we will not use child labour, that we provide equal opportunities and do not discriminate with regards to gender, race, religion, age, disability, nationality, social or ethnic origin. We have reviewed and updated our policies in 2024. We believe that an integrated approach to human rights, by embedding it into our policies, business systems and processes, allows us to manage human rights effectively within our existing ways of working. Our policies apply to all our employees and contractors.
Business and supply chain
ONE-Dyas is active in the full life cycle of upstream oil and gas. The business takes place predominantly in the United Kingdom, The Netherlands as well as Germany. For the purpose of providing this Statement, we made a distinction between operated and non-operated assets, as set out below.
Operated assets
For our operated assets we manage the exploration, appraisal, development and production of crude oil, natural gas and natural gas liquids. In some instances, we also market and transport these hydrocarbons. This includes engaging suppliers and contractors to operate and maintain our on- and offshore facilities and includes purchasing equipment. The ONE-Dyas team aims to develop and strengthen relationships with contractors and suppliers. Each of our contractors and suppliers has its own supply chain and we recognise that each level in the supply chain is responsible for ensuring compliance with all applicable laws and regulations and for respecting human rights.
We recognise that also ONE-Dyas has a role to take. This Statement predominantly describes how our procurement team approaches modern slavery risks in the supply of goods and services for our operated assets as we believe this to be an area that poses higher labour rights risk, and our focus, for the purpose of this Statement, is on our direct suppliers.
Non-operated assets
For our non-operated assets, the operatorship is assigned to one of the other joint venture partners. These joint ventures, and particularly the operators, must comply with legislation and are encouraged to apply materially equivalent business principles in their operations as the principles that we apply in our own organisation and for the assets operated by us. When contracting with a third party, we encourage and monitor where possible the operator of the asset to follow guidelines that are in line with our previously mentioned values and policies.
Risk assessment
Certain areas of our supply chain may pose a higher HSE and labour rights risk due to their location and the nature of the goods and services procured. Our risk assessment is a combination of both country (predominantly UK, The Netherlands and Germany) and category risk. With respect to equipment, we carefully consider the origin of products to be bought and aim for local suppliers when feasible. As part of our procurement processes and to identify and mitigate risks, we use specific tools to assess, qualify, evaluate and monitor suppliers. Depending on the potential risk levels, suppliers are required to have a higher registration status in order to become eligible to minimise risk of non-compliance.
Due diligence
We recognize the role of due diligence in bringing our commitments to life. In accordance with our Supply Chain Management and Supply Chain ESG policies, contractors and suppliers are assessed prior to awarding a contract. We use external screening tools to support our due diligence processes. We may also carry out on-site audits. Next to that we also consider termination of a contract if serious or persistent shortcomings are found.
In our contract templates for procurement, suppliers and contractors agree to comply with applicable laws and regulations and there is specific focus on providing and maintaining safe and healthy working conditions for all supplier personnel.
Effectiveness and performance management
Through our supplier selection and qualification process, contractors and suppliers may be subject to on-site audits, which could be announced or unannounced, and which may be performed by either our own personnel or third-party auditors. These audits help us to verify if suppliers and service providers are compliant to the principles and standards required. We also perform review and feedback sessions on a project basis where we actively consider topics like HSE, ESG, quality and competence.
Allegations or concerns that are raised with us will be investigated and may result in suppliers being required to develop corrective action plans, backed up by on-site audits. We have inhouse specialists who investigate concerns or allegations about a breach of our policies or Code of Conduct. If a violation is confirmed, we take appropriate action up to and including contract termination or dismissal. We maintain a stringent, no-retaliation policy to protect any person making a good faith allegation.
In addition, we endeavour to conduct formal and informal exchanges with supplier groups to increase awareness on HSE, ESG, and labour rights topics, communicate our expectations, work to jointly identify any gaps and improvement opportunities and promote best practices.
Training
All our staff are made aware of our Code of Conduct and associated Ethics and Compliance policies. A selection of staff, with specific exposure to certain risks or areas, received more in-depth training on a specific compliance related topics. Training participation is documented, repetition cycles are clearly defined and follow-up is automated. Both our Code of Conduct, company policies and related employee guidance documents are available on the ONE-Dyas intranet.
Declaration
At ONE-Dyas we are committed to continually improve the quality of our operations. The long-term success of our business is reliant on our ability to ensure the health, safety and well-being of our employees, contractors and the public, as well as minimising our impact on the environment. ONE-Dyas therefore requires compliance with the laws and regulations applicable to our business.
We have assessed the ONE-Dyas business and supply chain, our values, policies and the implemented processes with respect to our operated and non-operated assets. We concluded that there is a relative low risk of slavery and human trafficking in the ONE-Dyas business, mainly due to the fact that we are predominantly active in The North Sea. However, we are fully committed to preventing slavery and human trafficking in our activities and supply chain.
This Statement is approved by the ONE-Dyas Management Board on 19 January 2026 and signed on its behalf by
Chris de Ruyter van Steveninck
CEO ONE-Dyas
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