Anti-Exploitation Policies

Gulf Energy is committed to ethical business conduct in its operations and supply chains and is opposed to all forms of corruption and unethical business conduct.

Gulf Energy is a strong supporter of the international effort to abolish all forms of modern slavery.

The purpose of this policy is to support international efforts against slavery, child labor and human trafficking in conformance with the Gulf Energy ESG Strategy, the Gulf Energy Code of Business Conduct and Ethics, the United Nations Guiding Principles on Business and Human Rights, the United Nations Declaration on the Rights of Indigenous Peoples, the Queensland Human Rights Commission , and other applicable international laws.

This policy applies worldwide to all Gulf Energy entities, all Employees, and all Gulf Energy Agents.

A Gulf Energy “Employee” or “Employees” or “Team Member” is specifically defined, for purposes of this policy, as: any personnel hired directly by Gulf Energy (regardless of status classification of full-time, part-time, temporary, contract, etc.); interns (even if an intern does not receive payment by Gulf Energy); employees of other companies seconded into Gulf Energy, and any Gulf Energy employee seconded to a non-Gulf Energy company. A Gulf Energy “Agent” is specifically defined as any member of any Gulf Energy entity board, any officer of any Gulf Energy entity, hired personnel, consultants, intermediaries, lobbyists, agents, representatives, independent contractors, subcontractors, and any others who act on Gulf Energy’s behalf. To Gulf Energy “slavery” includes all the definitions provided by the Australian Modern Slavery Act 2018; any coerced or compulsory labor, servitude; indentured servitude; detained servitude; sexual exploitation; removal of organs; or securing labor or services by force, threat, or deception. Gulf Energy “child labor” means hazardous labor or labor provided by a child below a basic minimum age. Further, for the purposes of this definition, Gulf Energy accepts the definitions of “basic minimum age” and “hazardous work” as defined by the International Labour Organization Conventions, including but not limited to Convention Nos. 138 and 182. The following minimum age rules apply, with any conflict in application by Gulf Energy to be resolved by the higher age: minimum age specified in local law, 15 years, and 18 years for hazardous work., Certain exceptions may exist and be permitted by Gulf Energy for supporting the goal of promoting education and work experience as part of a bona fide education program, but only in conformance with local law. To Gulf Energy “human trafficking” is the recruitment, transportation, transfer, harboring or receipt of persons by improper means (including but not limited to by force, abduction, fraud, or coercion) for an illegal or improper purpose, including forced labor or sexual exploitation. Further, the definition of human trafficking includes transportation of humans in violation of applicable international laws and applicable country requirements, and includes human smuggling, regardless of if the person transported gave consent at any point in time.

Modern slavery is a crime and a violation of fundamental human rights. Gulf Energy is committed to the elimination of all forms of slavery and to the international effort to abolish child labor and human trafficking and has a zero-tolerance approach to such activities.

No Employee of Gulf Energy may hire child or forced labor or conduct or support human trafficking on behalf of Gulf Energy.

All Employees should be alert to any evidence of slavery, child labor or human trafficking in operations linked to our businesses. If an Employee suspects slavery, child labor or human trafficking, report your concerns immediately to your manager and to the Managing Director or via the email notification system on this website.

Gulf Energy expects and requires its Agents to follow the same zero-tolerance approach and will take steps to identify sources of slavery, child labor and human trafficking in our supply chain.

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