modern slavery and human trafficking statement 2020

25 June 2021 Contents Introduction 03 About this statement About bp and our supply chain This statement relates to the financial year ending We are a global energy business with operations Our policies in relation to slavery and trafficking 05 31 December 2020. It is published by bp p.l.c and in Europe, North and South America, Australasia, Governance of modern slavery 06 its relevant subsidiaries1 in compliance with the Asia and Africa. We currently operate in 72 UK Modern Slavery Act 2015. countries with 63,600 employees and have Due diligence and risk assessment 07 around 46,000 suppliers. These include More information: Operating management system 09 contractors, vendors, service providers and Read our previous slavery and human contingent labour, many of whom also have Providing our workforce with access to remedy 10 trafficking statements at further suppliers. Training and capability building 11 bp.com/reportingcentre Our third-party expenditure was approximately Consultation and collaboration 12 $50 billion in 2020. We recognize the potential for labour rights violations in our industry and supply Read more about our human rights policy Assessing the effectiveness of our approach 13 chain, and we focus our efforts where we believe and labour rights and modern slavery that risk is greatest. Looking ahead 14 principles at bp.com/humanrights Our procurement teams have identified parts of Attachment – case studies 15 our supply chain as focus areas for their work to Our code of conduct is available at identify and manage labour rights risks, including bp.com/codeofconduct modern slavery.

Read more about the work of our procurement teams on pages 7 and 8

1 BP p.l.c. and its subsidiaries are separate legal entities. References to “bp”, “we”, “our” and similar terms are to BP p.l.c. and its subsidiaries generally, to one or more of them, or to those who work for them. bp subsidiaries making this statement are: Air BP Ltd, Arco British Ltd LLC, BP Amoco Exploration (In Amenas) Ltd, BP Berau Ltd, BP Chemicals Ltd, BP Commodities Trading Ltd, BP Exploration (Angola) Ltd, BP Exploration (Azerbaijan) Ltd, BP Exploration (Beta) Ltd, BP Exploration (Caspian Sea) Ltd, BP Exploration (Delta) Ltd, BP Exploration (Epsilon) Ltd, BP Exploration (El Djazair) Ltd, BP Exploration Operating Company Ltd, BP Gas Marketing Ltd, BP International Ltd, BP Marine Ltd, BP Oil UK Ltd, BP Shipping Ltd, BP Wiriagar Ltd, Britannic Energy Trading Ltd, Britannic Marketing Ltd, Britannic Strategies Ltd, Britannic Trading Ltd, Britoil Ltd, Castrol Ltd, Lubricants UK Ltd and Wiriagar Overseas Ltd.

2 bp modern slavery and human trafficking statement 2020 Introduction bp supports the elimination of all forms of modern slavery. Modern slavery is a term used in policy and law to describe forms of exploitation that constitute serious violations of human rights, including human trafficking and forced labour. This type of exploitation is contrary to our commitment to respecting the rights of our workforce. At group level, we set expectations for how our businesses conduct their activities, including through our code of conduct, human rights policy, Policy Risk assessment Due diligence Systems Access to remedy labour rights and modern slavery principles and operating management system (OMS). Each of International standards Risk assessment Desktop assessments Labour rights and Grievance mechanisms our businesses are required to conduct their and principles: based on: modern slavery at business level Supplier due activities in conformance with these expectations requirements built • UN Guiding Principles • Activity diligence and human OpenTalk and manage the risks, including modern slavery, into our operating on Business and rights assessment associated with them. Often, they establish local • Country management system requirements or other processes to help them Human rights • Workforce questionnaires • ILO Core Cross-industry do this. demographics Onsite assessments Conventions on platform to share • Impact on workers and audits Key developments in 2020 Rights at Work assessment reports In 2020, part of our group level work was to Supply chain mapping Site-level monitoring, Our standards clarify and update the policy commitments, including worker and principles: standards and expectations we set at group level inductions, site that underpin our efforts to address modern • Human rights policy walkovers, payroll slavery and trafficking. We updated our human • Code of conduct and contract checks rights policy and embedded our labour rights and • Labour rights modern slavery principles in our group OMS, Corrective action and modern meaning that our principles-based approach is plans to address slavery principles now part of the requirements that govern how findings, including we operate. We also issued guidance to our remedy for workers businesses on how to use our labour rights and modern slavery principles. – supporting decent work. Our sustainability We know that there is more work to do and Read more about our sustainability frame frame establishes a set of group-wide aims. that steps taken on decent work and the Together, these steps advance us towards a and advancing human rights at bp.com/ These include: specific objectives and targets elimination of modern slavery are often more more systematic approach – one which has been sustainability and bp.com/humanrights we have set with respect to a just transition, effective when working collaboratively, so we shaped by the lessons we have learned as bp which advances human rights, including will also continue to work with, and learn from, businesses have sought to identify, prioritize and decent work, and with respect to supporting others. External collaboration is an organizing address issues on the ground, by working with sustainable livelihoods, health and wellbeing. theme of our sustainability frame, that will our business partners. These will shape bp’s approach to sustainable inform and enrich the actions we take in pursuit In 2020, we also announced that improving development over the medium term. We will of our sustainability objectives. We expect people’s lives is one of the focus areas of our new be reporting on our progress as part of our our approach to managing the risk of modern sustainability frame. We know that in delivering sustainability reporting. slavery to continue to evolve as we learn from our sustainability frame we need to maintain a our risk reviews, refine our practices and further focus on the vulnerabilities of individual workers Read more about decent work on page 54 strengthen relevant capability in our businesses to risks of modern slavery and – more broadly of the bp sustainability report 2020 and functions.

3 bp modern slavery and human trafficking statement 2020 Introduction continued The impact of COVID-19 bp’s human resources guiding principles required For example, in our Oman production business, 2020 will be remembered for the global pain and that employees taking a period of time away from we took steps to provide workers with access disruption caused by the COVID-19 pandemic. work due to COVID-19 would continue to be paid to food, lodgings, Wi-Fi and phone cards, even In responding to the pandemic our priorities for at least 14 calendar days. The same was true though work had stopped or contracts had come were protecting our people and supporting where a bp workplace was closed due to the to an end. We also conducted work to understand communities where we live and work, as well as COVID-19 pandemic, or where restrictions are worker resilience and socio-economic conditions. strengthening bp’s finances. imposed on the movement of people or the use of public transport. Read more about supporting our workforce COVID-19 severely hampered our ability to work in Oman in the attachment on page 15 on the ground and conduct risk management Read more about supporting our workforce activities in the usual way and made engagement during the COVID-19 pandemic on page 15 with contractors on the delivery of corrective of the bp sustainability report 2020 actions more difficult. Some of bp’s operations Further guidance was issued to our procurement were reduced to essential personnel only. teams on managing relationships with contractors Supporting our workforce and suppliers during COVID-19, which also Our workforce includes bp employees and emphasized the need to take informed decisions contractor workers, recognizing that our role based on consideration of health, safety, security and responsibilities are different with respect and environmental issues, worker welfare and to these two groups. We acknowledge that corporate social responsibility. the pandemic and resulting restrictions on In response to increased risks and impacts movement and economic activity may have had associated with disrupted work patterns, a disproportionate adverse impact on people in reduction in workforce numbers, reduced job our workforce who may have already been more security, delays and changes to earning capability vulnerable, including women, migrant workers, and workers being unable to get home as those who may be subject to discrimination or contracts finished or work slowed, we issued those with underlying health conditions. specific technical guidance to bp businesses to In response we issued guidance to bp businesses consider these factors as part of their contract on measures to help vulnerable people stay management. It encouraged bp businesses safe. This included identifying health vulnerability to identify the most vulnerable members of factors as well as those that could lead to risk the workforce, including migrant, low-skilled of serious labour exploitation, recommended or indirectly recruited workers, who may have measures at work to manage the risk of infection needed additional support during the pandemic. – including hygiene measures, social distancing The guidance states that bp businesses should and identifying, isolating and managing COVID-19 treat people, including our contractor workforce, cases that occur. The guidance also covered with dignity and respect. It identifies steps bp COVID-19 risks in permit to work safely, task risk and contractors can take to reduce vulnerability, assessments and necessary mitigations, including including, communication on health and safety social distancing, cleanliness, disinfection and any protocols, changes to working conditions, access specific PPE requirements. to grievance mechanisms, proactive management of working hours, provision of accommodation and basic needs especially for stranded workers.

4 bp modern slavery and human trafficking statement 2020 Our policies in relation to slavery and trafficking We are committed to respecting workers’ rights, in line with the International Labour Organization Core Conventions on Rights at Work and we expect our contractors, suppliers and joint ventures we participate in to do the same.

Our code of conduct and human rights policy them to resolve the issue to provide remedy to Updating bp’s human rights policy with the principles underlying the commitments state bp’s support for the elimination of all forms the people affected. If a serious breach is found and embedding our labour rights set out in our policy. of modern slavery such as human trafficking, and no corrective action is taken, we reserve the We launched the bp labour rights and modern forced labour and child labour. right to terminate contracts. and modern slavery principles We developed our updated human rights slavery principles in 2019, and they have been Our code of conduct is based on our values and In addition to requiring employees to report policy, published in May 2020, by assessing our reinforced by including reference to them in our clarifies the principles and expectations for how human rights abuses, we expect them, and human rights commitments against evolving human rights policy. The principles reiterate we work at bp. It applies to all bp employees. encourage contractors, communities and expectations, industry good practice and our commitment to respecting workers’ rights Employees are required to report any human other third parties to speak up if they see advancement of our activities and standards in line with the ILO Core Conventions and rights abuse in either our operations, or those something which they think could be unsafe or in line with the UNGPs since our policy was Rights at Work and our expectation that our of our contractors and other business partners. unethical. We encourage a ‘speak up’ culture established in 2013. The development process contractors, suppliers and joint ventures do The code of conduct makes explicit reference to among employees and with our contractors included extensive consultation with internal and likewise. The principles are intended to help the role all parties can play in the elimination of and suppliers. At our worksites we help make external stakeholders, including bp practitioners, our businesses, our suppliers and our business human trafficking, forced labour and child labour. sure people are aware of our confidential and independent experts, and civil society. partners, in identifying and managing risks and anonymous global helpline OpenTalk, and where impacts from poor labour practices, including the Our human rights policy commits us to respect relevant, community complaints systems and The updated policy sets out bp’s commitment to risk of modern slavery. They do so by promoting all internationally recognized human rights as workforce grievance mechanisms. We promote respect internationally recognized human rights. the employer pays principle – that employers, set out in the International Bill of Human Rights the use of these channels without fear It clarifies and explicitly states our commitment not workers should pay fees associated with and the International Labour Organization’s of retaliation. to respecting the human rights of vulnerable recruitment – and by seeking to prevent passport (ILO) Declaration on Fundamental Principles groups and to the ILO’s core labour standards retention, supporting secure employment through and Rights at Work. It also references the core Read more about access to remedy on concerning the right of our workers to join trade fair contracts and appropriate wage payments and labour standards as described in the ILO Core page 10 unions and supporting the elimination of child promoting effective grievance mechanisms. Conventions on Rights at Work. We recognize and forced labour. It also includes more detail our responsibility to avoid complicity in human on our approach to respecting human rights in We are now driving them into action across bp rights abuses – including modern slavery – as other important areas which may be relevant and with our contractors and suppliers in higher described in the UN Guiding Principles on to our efforts to respect rights at work, such risk operations through our procurement and Business and Human Rights (UNGPs) and as promoting the importance of accessible and operations teams and systems. continue to incorporate these principles into our effective operational-level grievance mechanisms, business processes. and support for civic space and human Read more about bp’s human rights policy Where we identify failures by our employees rights defenders. and labour rights and modern slavery principles at bp.com/humanrights to adhere to our code of conduct and policy, The policy explains how we manage human rights we take appropriate steps to address those impacts across our operations. It also emphasizes failings. This may involve disciplinary action, up that we want to work with business partners that to and including termination of employment. share our commitment to human rights, safety Similarly, if a contractor or supplier fails to act in and ethics and compliance. And we seek to use a manner consistent with our expectations or our leverage, consistent with the UNGPs, to their contractual obligations, we look to work with encourage them to act in a manner consistent

5 bp modern slavery and human trafficking statement 2020 Governance of modern slavery The risk of modern slavery is a serious issue. The board of bp p.l.c. and the bp executive leadership team continue to be engaged in reviewing our progress in identifying and addressing potential modern slavery issues within higher-risk parts of our businesses and supply chains.

At bp p.l.c. board level in 2020, the board In 2020, in line with our strategy and work to reviewed and approved our 2019 slavery and reinvent bp, we reviewed the way we govern human trafficking statement and through its sustainability at board and executive level. safety, environment, and security assurance This new simplified governance structure came committee (now safety and sustainability into effect on 1 January 2021 and as a result there committee) reviewed our approach to assessing have been some changes to how we manage and managing risks associated with modern modern slavery and human trafficking issues. slavery. At executive management level, the The board-level safety and sustainability group operations risk committee reviewed committee (S&SC and formerly called SESAC) progress on managing the risks of modern has oversight of human rights, including the slavery. In previous years our internal audit review of our performance in assessing and function has tested the effectiveness of our managing risks associated with modern approach to managing labour rights and modern slavery. Our human rights working group was slavery risk and reported to the board audit consolidated into a new sustainability forum, committee on its findings. Due to the COVID-19 which, as part of its activities also considers pandemic and related travel restrictions, it current and emerging human rights risks of was not possible to do so in 2020. However, potential group significance and reviews progress we anticipate this will commence again once in managing modern slavery risks. restrictions are sufficiently eased. At executive leadership level, the group Our human rights working group, which was operational risk committee will continue to made up of representatives from across the provide oversight on all group-level operational business, considered current and emerging risks, which includes sustainability issues such as human rights risks of potential group significance. modern slavery. In 2020 this included reviewing progress in the management of modern slavery risks and our Read more about sustainability governance disclosure under the Modern Slavery Act. on page 77 of the bp sustainability report 2020

6 bp modern slavery and human trafficking statement 2020 Due diligence and risk assessment Since 2016 we have taken a risk- Pre-contract due diligence Due diligence and risk Our approach to supplier labour rights and modern slavery due diligence is prioritised and evidence- based approach to assessment management in response to based. This pre-contract due diligence enables us to identify whether suppliers are able to meet our and identification of modern labour rights and modern slavery expectations, whether additional controls are appropriate to help COVID-19 manage the risk associated with a particular supplier or contractor activity, and how to introduce them. slavery in our businesses The COVID-19 pandemic has impacted our We aim to increase the due diligence of our supply chain to meet the targets and aims outlined in our and supply chains, based on ability to carry out in-person, onsite labour sustainability frame. rights and modern slavery assessments business activity, country risk and or oversight as travel bans and access workforce demographics. to sites has been restricted for safety Supplier expectations and labour reasons. In the short-term, businesses rights and modern slavery principles were encouraged to carry out worker This has resulted in a prioritised set of sites and interviews with contractor workforces to understand the impact of and worker bp’s labour rights and modern contractors for due diligence, desktop reviews, slavery principles are communicated sentiment on changes made and identify onsite assessments, and actions to address and Communicate to our contractors and suppliers if there were any issues. In two cases this Assess risk level remedy findings. expectations through our procurement processes identified delays in salary payments to and are incorporated into bp’s Through 2019 and 2020 we have adopted a more workers. On investigation, this was due supplier expectations. systematic approach using the lessons learned to cash flow issues with their employer. since 2016. This has included: We worked with our main contractors and We also continue to integrate bp’s supplier expectations into processes • Setting requirements in our OMS for our their subcontractors to secure payment of for sourcing and contracting for goods operated businesses to identify and remedy outstanding wages. and services. labour rights and modern slavery risks, Read more about due diligence and supported by guidance and tools on how to risk management during COVID-19 in carry out key activities. the attachment on page 15 • Formalising accountabilities for labour rights Appropriate contract clauses Carry out due diligence on prioritised basis and modern slavery risk management between our procurement, health, safety, environment We continue to find ways to stay connected Our standard contract templates require In addition to our existing supplier due diligence & carbon (HSE&C) and people & culture with our workforce as well as carry out ongoing contractors and suppliers to act consistently with and human rights assessment process, in 2020 teams from 2021. With the intent that this our code and human rights policy (which refers to we began trialling a third party due diligence assessment and monitoring activities despite will enhance our capabilities to conduct due our labour rights and modern slavery principles). process through the cross-industry human rights the physical limitations. To support this, we are diligence and onsite assessment, supported by assessment platform for high risk suppliers. working to bolster ongoing monitoring activities knowledge of local labour practices and central and capabilities such as worker interviews and expertise for key activities such as remedy. contractor reviews as well as trialling remote • Building capability at site and business-level to labour rights and modern slavery assessment identify and remedy labour rights and modern methodologies including third-party remote Agree gap closure plans Remedy adverse impacts slavery issues and support contractors to worker interviews. improve their performance. Read more on building capability on page 11 Ongoing due diligence including labour rights Continuous improvement contractor and and modern slavery onsite assessments supplier performance management

7 bp modern slavery and human trafficking statement 2020 Due diligence and risk assessment continued Post award contract management Human rights assessment platform Once a contract is awarded, oversight of labour Supply chain mapping In 2020, we worked with our peers to complete the development of a cross-industry platform rights and modern slavery risks may include Our procurement team capture key data to share supplier responses to a standard human rights due diligence questionnaire and when risk assessment, ongoing monitoring activities, on suppliers that feed into our mapping applicable, onsite assessment outcomes. This platform will help our industry to perform contractor performance management and and risk assessment processes but we consistent supplier human rights due diligence assessments and audits; creating greater securing remedy as needed. This approach is part recognise there is more to do to gain better efficiency, reducing assessment fatigue for suppliers and enabling us all to focus on improving of the requirements outlined in our OMS. visibility of our supply chain. In 2020, human rights performance in our supply chains. We have piloted and rolled out the supplier bp Australia worked with a third-party Ongoing monitoring activities for the contractor assessment questionnaire for our higher risk supply chains across major procurement areas. consultant to carry out a desktop review of workforce at a bp site can, for example, its process to identify modern slavery risk Six assessment companies are affiliated with the platform and the reports are shared between include raising worker rights awareness in and piloted an approach to supply chain the companies included in the platform, so participating companies have access to assessment worker inductions, onsite worker interviews, mapping and risk assessment. We intend and audit services for both the supplier assessment questionnaire and site-level human rights sample-based payroll and contract checks. to take the learnings from that to inform assessments – including an in-depth, iterative onsite assessment process. Where warranted by the risk assessment, this further development of both bp Australia can be supplemented by onsite labour rights and bp group processes. The platform due diligence process includes options for third-party desktop assessments based and modern slavery assessments by bp and/or on the above-mentioned questionnaire and is scored accordingly. There is also an option for third- a third-party. Any issues identified are discussed party onsite assessments but bp has not issued any in 2020 primarily due to COVID-19 restricting with the contractor in their performance review site access. bp reviews the assessment report and works with the contractor to agree an meetings, corrective actions agreed and action plan. This is incorporated into the ongoing labour rights and modern slavery performance monitored to close out. management process by the businesses. In 2020, we carried out onsite assessments in In 2020, between October to December we carried out due diligence through this platform on Mauritania and Senegal and have gap closure eight suppliers, in addition to our other internal supplier assessments. We intend to increase the plans in place to address issues identified. use of the platform in 2021. Mainly due to COVID-19 restrictions, no further onsite assessment or new onsite Read more on page 52 of the bp sustainability report 2020 third-party assessments were carried out. However we did use a third-party to carry out a follow up verification visit at Port Klang Malaysia lubes plant. We work to the principles of promoting continuous improvement in managing labour rights and modern slavery risks and working with contractors and suppliers to make sure findings are remedied.

8 bp modern slavery and human trafficking statement 2020 Operating management system Our practice for the management of environmental & social performance is included in our OMS.

Our OMS applies to both operations and Within our OMS, we have a performance Our performance improvement cycle projects and includes practices, procedures improvement cycle (PIC). The OMS PIC, as and guides, with supporting training materials, applied to labour rights and modern slavery risks, to help operations and projects understand involves the systematic review and development how to deliver requirements in practical terms. of risk management plans to identify and resource OMS requires bp operations and projects to needed gap closure. At its heart, the PIC cycle, Identify labour assess labour rights and modern slavery risks and when applied to labour rights and modern slavery rights and modern put in place effective controls in a proportionate risks, enables bp operations and projects to slavery risks and systematic way – for example through understand current performance so that work can pre-contract due diligence, worker induction, then be undertaken to mitigate risks or impacts ongoing monitoring and contractor management. and work with our sites, contractors and suppliers This promotes breadth as well as depth to our to improve performance over time. Management Develop and due diligence. During 2020, we focused on the roll-out and review and resource risk The introduction of these requirements and our implementation of our labour rights and modern refinement management plan labour rights and modern slavery principles into slavery requirements. our OMS at the end of 2019 shifted our approach Labour rights and from a top-down risk-based approach to a more modern slavery business-led and systematic one. The intention is for this to become part of how our businesses requirements driven by operate, building capability within the organization the OMS performance over time to do this well and adapt to changing improvement cycle local and global challenges. Issues and Implement risk shortfalls identified management and remedied measures

Check effectiveness of measures

9 bp modern slavery and human trafficking statement 2020 Providing our workforce with access to remedy If we find that we have caused or directly contributed to adverse impacts on workforce rights, we are committed to provide for, or co-operate in, the remediation of those impacts.

We encourage a ‘speak up’ culture among Working to ensure that workers on bp sites employees and with our contractors and suppliers have easy access to grievance mechanisms that Our human rights policy and in their work for us. At our worksites we help they trust significantly strengthens our ability to make sure people are aware of our confidential respect the rights of our employees and others access to remedy and anonymous global helpline, OpenTalk, which who work for us, by helping to identify and As stated in our human rights policy, we is available to employees, workers employed by address potential risks to the safety and welfare do not impede access to state-based our contractors or suppliers, and to other third- of our workforce. judicial processes or require individuals parties, including communities. Where relevant, to permanently waive their legal right to We continue to take steps to enhance the mainly at project and operations sites, we also bring a claim through a judicial process accessibility and effectiveness of the grievance have local community complaints and workforce as a precondition of raising a grievance mechanisms available, and make our workforce grievance mechanisms. through a bp grievance mechanism. feel able to raise grievances without fear of any Where bp identifies that we have caused form of retaliation. Our code of conduct clearly or contributed to adverse impacts on states that we have zero tolerance for retaliation, the human rights of others, we provide Contact speak-up which includes threats, intimidation, exclusion, for or co-operate in the remediation of Concerns can be raised through OpenTalk, humiliation and raising issues maliciously or in the adverse impacts through legitimate which is available 24 hours a day, seven bad faith. This stance is further reinforced in our processes intended to deliver effective days a week and in 75 languages. human rights policy. remedy while not preventing access to Concerns can be raised anonymously from other forms of remedy if justified. This If we find that we have caused or directly most locations and reports will be kept may include co-operating in good faith in contributed to adverse impacts on workforce confidential to the fullest extent possible, the provision of remedy through state-led rights, we are committed to provide for, or consistent with law and good business mechanisms. Where adverse impacts are cooperate in, the remediation of those impacts practices. Concerns will be taken seriously directly linked to our activities through our and work with our contractors and suppliers to and bp will not tolerate retaliation of any business relationships, we will support our encourage them to do the same, in line with our kind. business partners in the remediation of human rights policy. those impacts through their own grievance Read more about our work with contractors management processes, or support on remedy in the Oman Khazzan & Ghazeer collaboration to provide for non-judicial and Oman Air bp case studies in the remediation through third-parties. attachment on pages 15 and 16 Read more about our human rights policy at bp.com/humanrights

10 bp modern slavery and human trafficking statement 2020 Training and capability building We are continuing to develop and build the required capability to effectively manage risks to our workforce, through training and expert technical guidance.

Our training and capability building activities include:

• Providing training on our code of conduct, • Specific training for our procurement teams, • Improving site and contractor understanding which underpins and reinforces elements of designed to help identify and manage modern of our labour rights and modern slavery our human rights commitments. We train bp slavery risks they may encounter during the principles and of their role in promoting them. employees about how to apply the code of procurement process, including during pre- This includes awareness on ethical recruitment, conduct in their daily work. Training is available contract supplier due diligence and contracting. including the employer pays principle, the need in 15 languages. The majority of our procurement employees to identify any recruitment fees that might have • Delivering targeted facilitator-led online have now completed this training with 250 been paid and to reimburse, as appropriate – training to relevant parts of our businesses and of them taking it in 2020. We continue to as well as not withholding worker passports. functions to raise awareness of and how to recommend this training to new joiners to our We know that early engagement with our manage the risk of labour rights and modern procurement teams. contractors, suppliers and joint ventures, before slavery. In 2020, we focused on strengthening • Bespoke team-specific training on the undertaking labour rights risk assessments, process and capability for human rights due new labour rights and modern slavery is important in building awareness and diligence in procurement and developing requirements in our OMS, accountabilities for capability to support preventative, corrective or internal expertise in risk assessment implementation, as well as accompanying tools remedial actions. Securing reimbursement of and remediation. and guidance to support implementation of risk recruitment fees is an ongoing challenge but • More than 650 employees undertook self- management and businesses’ use of our labour one we continue to tackle through dialogue, directed online awareness-raising training rights and modern slavery principles. setting our expectations pre-contract and on labour rights and modern slavery risk • Human rights and social performance training discussing solutions at industry level. management in 2020. This training is open to and awareness-raising in support of the any bp employee, although it is primarily aimed launch of our revised human rights policy – at people who work on projects, in operational including dedicated sessions led by senior roles and in functions such as, HSE&C, leadership on the importance of the policy and human resources and ethics and compliance. implementing it through conformance with our The training covers: awareness of labour OMS. These sessions included information on rights, modern slavery and labour practices identification, assessment and management associated with increased worker vulnerability; of labour rights and modern slavery risks and how modern slavery risk indicators may occur impacts. In total around 1,300 employees in our industry or supply chains; and how to attended these sessions. identify warning signs. It also provides role- specific information on how employees can help identify and manage the risks of modern slavery, including by implementing effective prevention measures and remedies.

11 bp modern slavery and human trafficking statement 2020 Consultation and collaboration Stakeholder collaboration and learning from our peers remains central to our approach, as we seek to strengthen our ability to assess and address modern slavery risks in our businesses and supply chains.

2020 activity included: to support the industry and our contractors to Standardizing due diligence address labour rights risks, including modern • Participation, at group level, in the UN Global processes slavery, at large operating sites. We will Compact UK Network’s Modern Slavery We continue to work with a number of our continue to support cross-industry learning and Act Working Group and Business for Social peers to find ways of standardizing our human risk management approaches. This includes Responsibility’s Human Rights Working Group. rights due diligence and assessment processes. collaboration through a joint project of IPIECA For example, in 2020 we worked with IPIECA • bp UK retail business joining founding members and the Building Responsibly Initiative – which to develop industry-specific guidance on labour of the Responsible Car Wash Scheme to continued through 2020 – to develop training rights risk identification in supply chains – to support a pilot scheme. for contractors and suppliers focused on the support convergence in companies’ practice potential labour rights and modern slavery Read more about the pilot scheme in the on supplier labour rights risk identification risks associated with the construction of attachment on page 16 and prioritization. • Instructing Business for Social Responsibility, a large projects. This training was finalized in leading membership organisation working with June 2021 and aims to strengthen contractor We have also supported the development companies on social sustainability, to assess capability, to support longer term, collaborative of a platform that enables participating our disclosure against best practice in several efforts to address labour rights issues, energy companies to share contractor industries. We have tried to align with some of particularly in the context of major oil and responses to a standard human rights due the practices identified through that process, in gas projects. Developed in partnership with diligence questionnaire. order to enhance the accessibility and detail of Ergon, a specialist labour rights consultancy, Read more about the due diligence our disclosure. it provides modular training, to deepen understanding and develop capability in platform on page 8 • Engaging with several leading civil society relevant functions and roles – HR, construction, organizations on our group approach to health & safety and procurement – for managing and reporting on modern slavery and addressing core issues, such as working hours, seeking to reflect their recommendations in freedom of association and the availability of this statement as appropriate. effective worker grievance mechanisms. • Continued collaboration with IPIECA, our industry association for environmental and Read more at ipieca.org/our-work/social social issues, to develop guidance and tools and building-responsibly.org

12 bp modern slavery and human trafficking statement 2020 Assessing the effectiveness of our approach We’re taking steps, through the integration of our labour rights and modern slavery principles into our OMS, training, risk reviews and enhanced contractual frameworks to strengthen our ability to prevent or remedy abuses.

Our approach is focused on the higher-risk parts improvements on a rigorously prioritised and of our business and supply chain, by enhancing data-driven basis. The table below describes the KPIs we will measure and summarizes how the data collected is our ability to identify and manage modern slavery intended to support our labour rights and modern slavery programme. In our 2019 statement, we reported that we were risks and address issues where we find them. developing a measurement framework to help Measure Examples of supporting metrics Purpose We also recognize the role of our contractors and us assess, through the use of key performance suppliers, and the importance of working with Systematic approach to – Types of ongoing monitoring Understand trend data on indicators (KPIs), the quality and effectiveness of identification, prevention and activities carried out issues found and proportion of them, to help manage labour rights and modern the actions we are taking to manage labour rights management of labour rights – Types and numbers of issues actively in progress slavery risks in their activities. risks – including modern slavery – and to track the and modern slavery risks issues identified In situations where an onsite assessment completion of corrective or remedial actions. – Presence and status of identifies specific indicators of modern slavery action plans to address In 2020, we completed the process of developing issues identified risk or other labour rights issues, we expect KPIs, having tested them in 2019 with priority our business partners to develop appropriate bp businesses and requested performance data Contractor and workforce Means to engage contractors Understand methods most corrective action plans to address them. engagement on labour rights and workers in labour rights and used by businesses to engage from an initial, targeted cohort of 17 businesses. Our businesses and functions then engage to and modern slavery modern slavery agenda contractors and workforce We intend to use these KPIs – which as of Q4 monitor delivery of those plans. Actions we have 2020 are being phased into a new group-wide Effective Workforce – Presence of – Understand what is in place taken in a number of prioritized bp businesses data collection system – to help us measure, Grievance Management grievance mechanisms and degree to which it is – and actions taken by our business partners, support and manage performance. – No. grievances raised and % used by workforce in agreement with those businesses – have remedied by category – Understand types of issue contributed to improved working conditions and Over time, we hope that collecting and measuring raised and trends reduced the risk of exploitation, particularly in our performance information in this manner will contracted workforce. help us to track more effectively our progress in identifying, managing and remediating labour Read more on action taken in Oman and rights and modern slavery risks. We expect, were identified include wages and deductions, From this pilot we will work with the businesses Malaysia in the attachment on page 15 once the data collection system is sufficiently employment terms, working time and rest. to further improve data collection methodologies We know that, if our approach is to be sustainable mature to support external reporting, to consider These issues were raised with the relevant and identify how to use this data more and effective over the longer term, it will need to how most appropriately to account, through our contractors and corrective actions agreed. proactively to support real time implementation be focussed on those areas where our efforts and annual disclosure statement, for the impact of • The main means to engage contractors on and improvements on the ground. Focus areas those of our contractors and business partners our actions on the rights of our workforce on labour rights and modern slavery was kick-off will include: can and do successfully address the most severe the ground. meetings with contractors (this is the first • Gaining visibility on the number of issues impacts on the rights of our workforce. In order meeting with a contractor post contract award) identified and closed out through onsite From this initial pilot in 2020 of 17 businesses, we and ongoing performance review meetings. to help ensure that is the case, we are working identified the following: monitoring activities. to systematize the collection and tracking of • Whilst most businesses reported having an • Understanding root causes of why workers information about modern slavery issues – • Businesses are using onsite activities mainly effective grievance mechanism, data showed might not actively use grievance mechanisms such as worker grievances, risk indicators and worker interviews, assessments and payroll varying levels of active use by workers. and identify means to encourage a stronger corrective actions – so we can effectively support checks to identify labour rights and modern speak up culture. slavery issues. The main areas where issues

13 bp modern slavery and human trafficking statement 2020 Looking ahead

We remain open to dialogue, collaboration and • Trial and evaluate use of remote labour rights constructive challenge. We expect our approach and modern slavery assessments and worker bp businesses around the world are taking to managing the risk of modern slavery to interview methodologies to enable ongoing measures to assess and address the risk of continue to evolve as we learn from our risk connection with workers and continued modern slavery. The following case studies reviews, refine our practices and continue to build monitoring even where COVID-19 might illustrate bp’s approach in more detail. capability in our organisation. We know that there restrict travel and access. is more work to do and we cannot achieve this • Enhance awareness of labour rights and For more information visit bp.com/ on our own. Where we encounter challenges, modern slavery risks with key suppliers and sustainability and bp.com/ we will do our best to resolve them, working contractors, including the use of grievance modernslavery collaboratively with others. mechanisms and effective remedy. Over the coming year we intend to: • Improve the quality of our labour rights and modern slavery performance data and • Work with industry and contractors to continue KPIs; and extend collection of this data to to improve approaches to ethical recruitment, additional businesses. assessment and remedy, including recruitment fees and reimbursement. • Expand our use of the cross-industry Human Rights Assessment platform for high risk suppliers. • Continue to embed our systematic approach through our OMS and further embed labour rights and modern slavery principles into key processes, decisions, and stage gates. Bernard Looney chief executive officer, 25 June 2021 This statement has been approved by the board of BP p.l.c. and of each of its relevant subsidiaries, in compliance with the UK Modern Slavery Act. It was approved by the board of BP p.l.c. on 14 May 2021.

14 bp modern slavery and human trafficking statement 2020 Case studies Our businesses around the world are taking measures to assess and address the risk of modern slavery. These are some examples:

Port Klang Plant Malaysia – Oman Khazzan & Ghazeer – site. The business recognises the importance Understanding financial resilience addressing the root cause of labour labour rights and modern slavery of responsible demobilisation and continues to Engagement with workers in the Oman Khazzan survey its workforce to make sure any concerns & Ghazeer business highlighted that some were rights and modern slavery issues evolution and strong worker are captured and acted upon. experiencing financial difficulty. As such, we also As outlined in previous Modern Slavery engagement carried out interviews with a small sample of Acting on workforce grievances 33 workers to understand their socio-economic statements, our blending plant at Port Klang bp’s 2019 statement outlines the approach this Via a programme of grievance mechanisms, situation and financial resilience for example Malaysia has continued to work with their business has taken to establish a workforce including site walkovers carried out by the number of people supported by their jobs, ability contractors to improve issues identified during the welfare programme. Many of the controls trialled bp team, the business identified a number of to save and strategies to respond to disruptions to onsite assessment carried out in 2017. A recent here have been adopted into bp’s guidance and workers who had repeatedly been paid late their finances. Findings included 58% of workers verification assessment showed an improvement systematic approach taking lessons learned to the since COVID-19 had started, contributing to reporting they felt if they could not work, they had in the working conditions of contract workers at wider business. The Oman business has worked financial hardship for subcontractor businesses. a financial safety net, yet 55% also report having the plant. with their contractors on a journey of continuous Working with the relevant contractors, we one month or less of a financial buffer. This is improvement for the workforce provided to The initial assessments in 2017 focused on developed a plan to bring all wage payments up very much an initial pilot and we intend to review the business. the recruitment, hiring and employment of to date, resulting in 87 workers being paid in the the methods and findings to help us understand foreign migrant workers, but also identified As a result, a comparison of induction statistics region of $94,400 in overdue wages. more about our workforce and help inform our issues in relation to Malaysian contract workers for the Oman business between 2017–2020 The team followed up with workers to check sustainable livelihoods agenda. engaged on a casual basis with informal working showed significant improvements made across that they had received their monies, but also arrangements. In recognition that this was the key areas of focus. For example, 96% of to understand the impact that the delays in not aligned with our labour rights and modern workers said they had an option to hold their repayment had on them. Workers reported slavery principles, the business incorporated passport compared to 81% in 2019 and 99% hardships in being unable to support their families the expectations of the principles into tendering of workers reported not paying a recruitment and purchase personal items. Coping strategies documents when the existing contracts expired. fee in 2020. To achieve these changes bp has included getting loans from family and friends or Only contractors who would provide more job worked with its contractors over several years, going without items. On receiving payment of security, formal employment contracts and who have had to make a number of updates outstanding wages, workers said this enabled related benefits were considered for the tender. to the way they recruit and employ workers. them to repay loans, send money home, As a result, more than 170 workers benefited Improvements continue, for example this year purchase land and build or refurbish their homes. from guaranteed monthly income, paid annual a key construction contractor decided to enable leave, sick pay and access to social insurance. workers to keep their own passports in a place The business recognised that the associated they felt was safe. This was a fundamental costs could be partly offset by the potential change for the contractor, and it has updated its savings to the business in terms of better hiring polices at corporate level, not just for bp. attendance and attrition rates, improved Activities on site are transitioning from the Project safety, reduced onboarding training and overall (construction) to operations phase, reducing productivity uplift. the number and demographics of workers on

15 bp modern slavery and human trafficking statement 2020 Case studies continued Gelsenkirchen – addressing risks Oman Air bp – access to remedy promotion of the US National Hotline Number for Collaboration in action: during turnaround human trafficking (both labour and sex trafficking) Responsible Car Wash Scheme Air bp selected a contractor to carry out a short- which can be unknowingly facilitated through At our Gelsenkirchen refinery in Germany, the term pipe maintenance project. However, initial convenience stores, which are used for fast in- In late 2020, the bp UK retail business joined labour rights and modern slavery risk assessment labour rights and modern slavery due diligence and-out, anonymous access to bathrooms and founding members of The Responsible Car Wash identified turnarounds as a higher risk activity. identified that the proposed contractor had weak to purchase “treats” for the women and children Scheme (RCWS) to support the RCWS to win the Turnarounds are mandatory shutdowns of the systems, practices and poor understanding involved. bp is encouraging our bp-branded backing of the Government to develop a blueprint refinery to execute inspections and to verify that of bp’s labour rights and modern slavery third-party operators to display signage in stores, for a national licensing scheme for hand car the operator fulfils legal requirements. During this requirements and did not demonstrate an provide informational brochures to customers, washes to tackle endemic non-compliance within time labour rights and modern slavery risk can appetite to change and improve. The business and train workers on how to spot and report the industry. increase due to the expanded and more transient therefore took the decision to re-tender and suspected trafficking. The RCWS was launched in 2018 to improve workforce (as they are only onsite for a few identified a contractor who met more of the “Our code of conduct and human rights policy standards in the hand car wash and valeting months), time pressures and the possibility of requirements and expressed a commitment to reinforce our support for the elimination of industry winning the support of Government additional contractors and subcontractors being improve where needed. all forms of modern slavery. We encourage and regulators. Its work to date has included a used to complete the work. As part of bp’s systematic approach, the business customers and sites across our brands, along number of local trials which have demonstrated The business developed and introduced a carried out worker interviews and identified that with others in our industry, to participate in the the effectiveness of the RCWS Code of worker questionnaire in 13 languages designed 15 workers had not received salaries for the last efforts to address this global challenge.” Practice in identifying non compliances and to identify any potential red flags, for example three months. This was raised with the contractor driving improvement. Richard Harding, SVP mobility & workers being charged for employer provided who explained salary delays were a result of convenience Americas Building on this work, the Government backed accommodation or salaries paid late or in cash. COVID-19 workflow disruption from other pilot will see the RCWS and the Gangmasters This was completed by around 260 members of customers which had caused cash flow issues. 5,000 missing children’s booklets – sponsored by and Labour Abuse Authority (GLAA) work with the turnaround workforce. The business worked with the contractor to repay bp – were distributed throughout Tampa in early Slough Council and regulatory bodies to apply workers outstanding salaries before authorising 2021 around the Super Bowl. Fourteen of the 36 The business also raised labour rights and compliance pressure across all aspects of the payment of the final invoice to the contractor. children in the booklets were recovered within a modern slavery awareness through integration business operation including health and safety, week of the game. During the 10-day operation into worker inductions and through a video However, while this key issue was addressed, environmental, planning and employment more than 150 convenience stores were provided and posters which included contact details of demobilization meant not all concerns identified practices. We hope that by supporting this anti-trafficking information and two of those key bp personnel. Similar awareness training through final worker interviews could be initiative, it will drive improvements and stores reported sightings of missing children was also delivered during the onboarding of bp addressed with our contractor, highlighting the compliance in UK carwashes and provide better within the first hour of outreach. IOB met with employees, contractors and security staff. And a benefit, where feasible, of conducting worker protection for workers. over 400 volunteers and trained over 200 of those third-party was engaged to carry out a remote surveys early in a project and maintaining volunteers about trafficking. Additionally, IOB desktop review of the main contractors and the option to exercise contractual rights to worked with top law enforcement and provided selected higher risk subcontractors. The review allow time and maintain leverage to address them with 80 actionable leads. found that the main contractors did not have concerns identified. systems to screen or monitor subcontractors; one Mobility and convenience Americas “We were honored to partner with bp in anti- subcontractor had policies allowing deductions trafficking efforts surrounding the Tampa Bay from salary. – partnership with ‘IN OUR Super Bowl. We look forward to continued partnership to stop this atrocity surrounding the bp is in the process of responding to the BACKYARD’ Super Bowl and beyond.” findings of this review to develop action plans bp’s convenience network in the US is partnering with contractors and adapt practice for future with a national non-profit called ‘IN OUR Cheryl Csiky, Executive Director of IN turnarounds. These lessons will also be shared BACKYARD’ (IOB) as part of their initiative known OUR BACKYARD. with other bp businesses. as Convenience Stores Against Trafficking. This focuses on education, advocacy and

16 bp modern slavery and human trafficking statement 2020 Case studies continued Actions taken in response to COVID-19

Mexico Spain In Mexico, bp implemented an initiative in At our Castellón refinery in Spain, we reviewed response to COVID-19 to protect vulnerable the terms of the contract with each contractor members of our contracted workforce employed company in order to manage COVID-19 risks through Manpower (an employment agency) at derived from the most severe lockdown in our company owned and operated sites; they Europe; in some cases we agreed similar were placed on paid leave and support was work-life balance measures as were in place for made available. bp also led an initiative to give bp employees. such workers a bonus to compensate for loss of bp conducted joint assessments with our incomes through tips which they were unable to contractors of their financial health and their receive due to the requirement to isolate at home. vulnerability from a business continuity point of At the outset of the pandemic, bp Mexico said view. Specific conditions have been agreed with that Manpower contractors working for bp each contractor for the pandemic, such as mass Mexico would benefit from the same three balancing of man hours. months without dismissals as bp employees We have also paid particular attention to small and has maintained all contracted workers under local suppliers, which are more vulnerable to contract. We also worked with the agency the adverse financial effects of the pandemic; to help ensure the employer provides them to support the local community, we took steps additional medical care options and telephone intended to avoid cash flow restrictions having a access to externally- and internally-provided negative impact on the salaries of those suppliers’ medical support. employees. bp has also undertaken analysis and For those members of the bp Mexico contracted redistributed contractor workload, in order to do workforce who suffered from COVID-19, bp has what we could to help those contractors minimize guaranteed full payment and benefits and given the number of redundancies they needed to them time to fully recover at home after their make in the context of the broad effects of the discharge from care. pandemic on the industrial sector in Spain.

17 bp modern slavery and human trafficking statement 2020