Gulf Oil International Limited
Modern Slavery Policy
Purpose
This Modern Slavery and Human Trafficking Statement (“Statement”) is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Act”) and sets out an overview of the business, policies, and procedures Gulf Oil International Limited and its subsidiaries (“Gulf”) have implemented and/or carried out during the financial year ending 31 March 2025, representing the substantial steps Gulf has taken to prevent modern slavery and human trafficking in our business and supply chains.
This statement was approved by the Board of Directors of Gulf Oil International Limited on 26 June 2025.
Governance And Accountability
| Owner | Responsible for |
|---|---|
| Board of Directors | Approves this Statement and oversees its implementation and ongoing monitoring. |
| Ethics and Compliance function | Investigates concerns and monitors adherence to ethical business standards. |
| Legal function | Advises on compliance with the Modern Slavery Act. |
| General Managers | Implement our anti-slavery policies at operational level. |
| All staff members | Complete mandatory compliance training, report concerns and promote ethical practices. |
Our Organisation And Operations
Gulf, a wholly owned entity of the Hinduja Group, is one of the largest privately-owned downstream companies, with a presence in over 100 countries worldwide. Gulf’s core business is manufacturing and marketing an extensive range of performance lubricants and associated products across a diverse range of market segments. Gulf also licenses national fuel retail networks around the globe, and is currently present in over 20 countries with more than 1,200 stations. Gulf has a strong international presence in Europe, South America, the Middle East and the Asia Pacific region, owning blending facilities and several licensed plants worldwide. It is the majority shareholder in Gulf Oil Lubricants India Ltd, listed on the BSE. Gulf’s business also includes Gulf Marine, which supplies lubricants to the global shipping industry across 1,100 ports worldwide.
Our business includes:
- Product Range: Lubricants, greases, gear oils, spray oils, marine oils and specialty fluids.
- Global Reach: Blending plants in India, UAE, China, Brazil, Philippines and Singapore, access to third-party facilities and extensive distribution networks.
- Technical Services: Oil condition monitoring, engineering consultation and shipboard advisory.
- Reviva Coffee: Launched in 2023, with a growing customer base, particularly in UK and Latin America. The Reviva brand is a small-batch roasted speciality coffee sourced from Rainforest Alliance-certified farms in Latin America.
- EV Charging: The design, development, assembly and servicing of domestic smart electric vehicle charging systems for the UK market.
Our Commitment To Ethical Business Practices
We are committed to treating workers fairly and ensuring safe, respectful and lawful working conditions across our business. Gulf’s core values and Code of Conduct promote respect, transparency and ethical behaviour, and apply to all employees, contractors, and partners.
Our ethical framework includes:
- Upholding international human rights standards.
- Prohibiting any form of discrimination, harassment, or exploitation.
- Providing mechanisms to raise concerns confidentially via our Speak Up platform.
- Ensuring compliance with all applicable labour laws, including working hours, wages, and safe working conditions.
Gulf maintains a zero-tolerance stance towards all forms of modern slavery, including forced labour, servitude, bonded labour, and human trafficking. We are committed to conducting business ethically, respecting the human rights of all individuals, and promoting fair treatment of workers across our operations and supply chains. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and have implemented effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains
Risk Assessment And Due Diligence
We continue to strengthen and improve our processes for assessing and mitigating the risk of modern slavery. This includes:
- Counterparty Due Diligence: We conduct risk-based customer and supplier due diligence, using a comprehensive third party screening platform and Counterparty Due Diligence check carried out by our Compliance team. For high-risk suppliers, we apply enhanced checks as part of our mandatory Counterparty Due Diligence procedures.
- Country and Sectoral Risk Assessment: We consider geographic and industry-specific risk factors, especially in operations involving manual labour or third-party facilities.
- Supply Chain Audits: Modern slavery risk assessments are carried out via regular Internal Audit and Technology team audits of our third-party plants and licensees.
Supplier Expectations And Contractual Controls
All suppliers are expected to adhere to our Supplier Code of Conduct, which requires our suppliers to comply with:
- All applicable anti-slavery and human trafficking laws, including the Act.
- Respect for workers’ rights and prohibition of forced labour.
- Prohibition of child labour, discrimination and abusive treatment.
- Freedom of association and compliance with health and safety standards.
Gulf strives to procure products and services from high quality and high integrity suppliers, and works with distributors, service providers and suppliers who hold the same values. We achieve this through appropriate and regular risk assessments of third-party suppliers.
Our standard contractual terms include specific provisions that prohibit the use of forced, bonded, or trafficked labour and require our counterparties to implement appropriate measures to prevent modern slavery in their operations and supply chains. These clauses reflect our commitment to upholding human rights and allow us to take action, including contract termination, in the event of non-compliance. We include modern slavery compliance clauses in third party supplier contracts and reserve the right to terminate relationships with parties found to be non-compliant.
Code Of Conduct
Gulf’s Code of Conduct, which underpins how we do business, helps those who work for us to understand the risks of modern slavery. It is a central part of our commitment to conducting our business to the very highest ethical standards. The Code of Conduct makes it clear that Gulf 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.
In addition, our Code of Conduct provides that Gulf will not accept products or services from suppliers, subcontractors or business partners who do not comply with anti-human trafficking and anti-slavery laws.
Speak Up Policy
The Speak Up Policy also aims to foster a culture where people are empowered to report issues of concern.
Our Speak Up Policy enables employees, suppliers and partners to confidentially report suspected breaches of our Code or policies, including concerns related to modern slavery or human trafficking. All reports will be appropriately and confidentially investigated by the Speak Up Committee, with appropriate remedial actions taken.
Training And Awareness
To ensure employees are equipped to identify and report risks, we provide:
- Annual mandatory Code of Conduct training.
- Mandatory dedicated modern slavery training will be launched as part of our online compliance programme in FY26.
- Targeted training for procurement and operational teams working with high-risk suppliers.
During the submission of this Statement, Gulf is not aware of any current or recent incidents, nor of any reports or accusations of forced/involuntary labour or human trafficking in our operations or those of our business partners.
Related Policies And Procedures
- Code of Conduct
- Speak Up Policy
- Supplier Code of Conduct
- Anti-Bribery and Corruption Policy
- CDD process
