Modern Slavery Policy

1. Our standard

LT Marine Offshore Services, Inc. prohibits slavery, human trafficking, forced or bonded labour and unlawful child labour. This applies to staff, persons acting for LT Marine and the recruitment and services we arrange. We expect principals, suppliers and recruitment partners to meet the same standard in work connected with us.

A worker must be free to make an informed employment choice. Consent obtained through threats, deception, withheld wages or abuse of vulnerability does not justify exploitation.

2. Fair recruitment and documents

Staff must explain the role, employer, vessel assignment and material contract terms accurately, give the seafarer time to review them and provide the employment agreement required for the assignment. Do not substitute terms through pressure after acceptance or conceal deductions.

LT Marine must not charge seafarer recruitment or placement fees, directly or through a third party. Under the Maritime Labour Convention, limited personal-document costs may be borne by the seafarer: a national statutory medical certificate, national seafarer’s book, and passport or similar personal travel document. Visa costs belong to the shipowner. Apply any Philippine, contractual or other applicable rule that gives the seafarer greater protection.

Never hold identity documents as security for a debt or continued service. Where originals are needed for lawful processing or requested safekeeping, record the purpose, obtain appropriate authority, provide a receipt and keep them accessible for prompt return. Do not demand a recruitment deposit or a loan tied to accepting work.

3. Age and freedom at work

Verify age and eligibility before deployment. Follow the applicable Philippine, flag-state and assignment requirements, including any higher minimum age. The MLC minimum is 16, with additional protection for those under 18, including restrictions on night work and work likely to harm health or safety. A lawful training arrangement must satisfy its specific conditions.

Workers must be able to raise welfare concerns, communicate with their representatives and leave employment through lawful contract procedures. Threats against families, confinement, punitive document retention and blacklisting for reporting abuse are prohibited.

4. Recognising risk and checking partners

Before using a recruitment intermediary or a higher-risk supplier, the responsible manager must consider licensing where required, ownership, recruitment methods and credible reports of abuse. Record concerns and obtain management direction before proceeding.

Warning signs include unexplained cash demands, someone controlling another person’s answers or documents, wages diverted without a clear lawful reason, and workers afraid to discuss their conditions. Do not dismiss a concern because a contract or supplier assurance appears satisfactory.

5. Reporting and protecting people

Report suspected exploitation promptly through dpo@lt-marine.com under our Speak Up & Whistleblower Policy. Explain any immediate safety risk and a safe way to contact you. Email can identify its sender; this is not an anonymous reporting system.

For immediate danger, follow vessel emergency procedures or contact the relevant emergency services. Do not confront a suspected trafficker or put a worker at greater risk. Management must arrange a proportionate review, protect affected people, preserve relevant records and consider specialist assistance, remedy and referral to authorities. No one must suffer retaliation for honestly raising a concern.

6. Accountability and review

Management is responsible for communicating these requirements, assigning relevant guidance and recording corrective action. A supplier problem requires a response based on worker safety and the facts; ending a relationship alone may leave the affected person exposed. Breaches may lead to appropriate employment or contractual action, subject to fair procedures and applicable law. Management must review this policy periodically and when material risks change.