Dana Petroleum Limited is the parent company of the Dana Petroleum group ("Dana"). This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes Dana's slavery and human trafficking statement ("Modern Slavery Statement") for the year ending 31 December 2025. This Modern Slavery Statement has been adopted by Dana Petroleum (E&P) Limited.
The Act creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking ("Modern Slavery"). It continues to be a priority for Dana’s board, management and staff to ensure that we do business ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our business and in our supply chain. This Modern Slavery Statement highlights the key activities we have undertaken during 2025 not only to ensure compliance with the Act but also to ensure that we conducted our business in an ethical and responsible manner.
In April 2025, Dana marked 10 years since the Modern Slavery Act 2015 came into force. As part of that, a business wide communication was sent by the Head of Dana’s Ethics & Compliance Committee to reiterate the fact that Modern Slavery is not a thing of the past and that it continues to happen today. Since the introduction of the Act, Dana has strengthened our due diligence processes, enhanced accountability of our suppliers and continues to practice responsible supply chain management. During the last 10 years, progress has inevitably been made but there is still more to do. Looking forward, Dana remains committed to taking whatever steps we can to address Modern Slavery, and we encourage all Dana staff to work with us to prevent further exploitation from occurring.
Dana is an oil and gas exploration, development and production company with group operations (including joint ventures) in the UK, the Netherlands and Egypt. Dana is headquartered in Aberdeen, United Kingdom. Further information can be found here.
Dana’s Code of Conduct (“Code”) which underpins how we do business, helps us when making day to day decisions on behalf of Dana and to help us “Do the Right Thing”. It is a central part of our commitment to conducting all our business to the very highest ethical standards. The Code makes it clear that Dana does business in a manner that respects the human rights and dignity of all and that we are committed to combatting all forms of Modern Slavery.
Our Code promotes working within the laws and regulations of the countries in which we operate, in order to meet high ethical standards and foster a culture whereby people are empowered to report issues of concern. Dana chooses to work with business partners that share their commitment to their Values of Safety, Respect and Integrity. The Code applies to everyone at Dana regardless of where they work and we expect and encourage all our contractors and their employees to act in a way that is consistent with our Code. The Code is available in our core languages of English, Arabic, Dutch and Korean.
Dana favours having suppliers who are registered with an industry recognised supplier verification scheme which identifies, evaluates and provides pre-qualification information about suppliers on behalf of major buyers in oil and gas and request that suppliers complete a corporate social responsibility questionnaire answering questions that relate specifically to Modern Slavery within their organisation. The answers to these questions are then fed back to Dana for review. Dana has compiled our own Compliance Checklists for suppliers not registered with an industry-recognised supplier verification scheme to ensure appropriate due diligence is completed prior to contracting with a supplier.
Dana aims to procure products and services from high quality and high integrity suppliers. We achieve this through our procurement processes which require that a Supply Chain Management representative is involved from the initiation of procurement through to the award of contract. This includes carrying out appropriate risk checks with a third-party provider. The third-party provider is instructed to complete a search in relation to each potential supplier against drivers of third-party risk such as Modern Slavery. Goods and services of higher risk and monetary value are subject to more involved tendering processes. Consideration of quality management systems, policies and related information is a part of this process.
Dana requires that our suppliers comply with all applicable laws which encompass not only full compliance with the Act but other matters such as anti-bribery and corruption, fraud, GDPR and tax evasion. Dana’s standard clauses in contracts include an obligation for contractors' subcontracts to include anti-slavery and human trafficking provisions that are no less onerous than those Dana has in place.
In one of our countries of operation, Egypt, there is no specific legislation applicable to Modern Slavery. Dana has assessed the risks associated with this and have included that we have sufficient robust internal controls in place such that the risk of any Modern Slavery taking place in our Egypt business is low.
Dana is committed to conducting its business in a fair, honest and transparent manner. Dana encourages all employees to “speak up” and raise any behaviours which may conflict with our Code by using our independent third-party phone line which offers assistance in our core languages of English, Arabic, Dutch and Korean or by registering the concerns by web reporting online or using a QR code.
An Integrity Policy is in place which supports the reporting of behaviour which may conflict with Dana’s values.
Dana promotes how to report a concern by advertising posters on and offshore in all our locations and by sharing our third-party reporting tools on our intranet.
Dana has in place a business risk assessment which includes the topic of Modern Slavery. This helps to identify and assess potential risks within our business and in our supply chain relating to Modern Slavery and Human Trafficking. As part of this risk assessment process, Dana audits our joint venture partners to ensure that they comply with the same high standards as Dana does. This risk assessment is reviewed quarterly at our Ethics & Compliance Committee meetings to ensure it is up to date, with our latest review being completed in November 2025.
Our Code training is completed by every new start. All employees must complete the training on an annual basis. This training provides specific training on Modern Slavery which ensures all employees and contractors have an understanding and awareness around Modern Slavery and Human Trafficking and the provisions of the Act.
In March 2025, a short video on our Code was developed for all offshore personnel to watch as they arrive on our offshore assets. This ensures we capture not just our employees but all contractors who work on our offshore assets to ensure they know how Dana does business and to reinforce the message of doing the right thing.
At the time of writing, Dana is not aware of any current or recent incidents, nor accusations of forced/involuntary labour or human trafficking in our operations or those of our business partners.
This statement was approved by the board of Dana on 20th March 2026.
Signed by Jongweon Choi
Director for and on behalf of Dana Petroleum Limited
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