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Modern Slavery Act Statement

Scandlines Infrastructure ApS and its subsidiaries (“Scandlines”) aim at high compliance standards. Though not being under obligation to do so, we have decided to issue a slavery and human trafficking statement for each financial year. This statement shall cover the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business, or a statement that the organisation has taken no such steps.

The organisation’s structure, its business and its supply chains:

Scandlines operates two short distance ferry routes between Germany and Denmark which operate with high frequency and large capacity.  Scandlines operates eight ferries, providing efficient and reliable transportation services to both passengers and business customers. 

Scandlines’ business consists of the transport of passengers, cars, buses and freight units on the routes Puttgarden-Rødby and Rostock-Gedser. We also offer our customers a variety of on-board catering and retail services as well as land-based retail shops (BorderShops and Easymarked) in Puttgarden and Rostock. Scandlines’ catering and retail activities are an integrated part of the logistic division and provide added value across all customer segments.

The main focus of all operations is to create value for the customers on board our ferries as well as in our land-based retail shops. This requires a diversified business model with both logistic services, catering and retail offerings. 

Scandlines is subject to Danish law. Corporate Governance in Scandlines is based on Danish legislation and regulations, including the Danish Companies Act, the Danish recommendations for good corporate governance and the Company’s articles of association, as well as other relevant rules.

Scandlines’ Corporate Social Responsibility work is designed to help create value for our stakeholders and to make Scandlines their preferred partner. 
Scandlines operates its business based on the guidelines laid down by DVCA (Danish Venture Capital and Private Equity Association). Reference is made to www.dvca.dk for more information about the guidelines.

Scandlines Infrastructure ApS is the parent of Scandferries Holding ApS whose main investors are First State Investments, Hermes and 3i Group and their related funds. The activities of the Scandlines Group are managed by Scandlines Danmark ApS and Scandlines Deutschland GmbH and their subsidiaries.

Risk assessment & steps taken: 

At Scandlines, we aim to work to the highest standards of integrity, honesty and appropriate behavior. Adhering to applicable laws, regulations and company guidelines is important to us. These principles are laid out in Scandlines’ Code of Conduct which is distributed and applicable to all employees across the Scandlines group. Employees at Scandlines are hired under Danish and German labor law. Scandlines complies with all relevant local regulations and works closely with trade unions. 

Scandlines’ suppliers are mainly based in Europe. There are a few exceptions in relation to some products which are produced or procured from countries which are identified as higher risk in the Global Slavery Index (www.globalslaveryindex.org). At Scandlines, we treat our suppliers, including agents and consultants, with respect and are committed to conducting our contracting and procurement practices in a fair and transparent manner. We have a specific Supplier Code of Conduct which sets out very clearly the legal standards and ethical behaviors which we require all Scandlines’ suppliers to adhere to (see below for further details on the Code). Suppliers, including agents and consultants, are required to agree in writing to comply with our Supplier Code of Conduct. 

Our efforts regarding modern slavery and human trafficking form part of Scandlines’ overall integrated approach to corporate & social responsibility.

Policies in relation to slavery and human trafficking:

Scandlines issued a Supplier Code of Conduct in 2014 which is based on the 10 principles of the UN Global Compact. The Supplier Code of Conduct is currently being rolled out across Scandlines’ supplier base and has already been signed by a large number of suppliers. Some have provided their own Codes of Conducts which Scandlines verifies in order to confirm that common principles apply. These efforts will continue.

In particular, our Supplier Code of Conduct includes a specific requirement on Scandlines’ suppliers to prohibit and refrain from employing any form of child labour or forced labour.  Suppliers are also required to communicate the principles laid out in Scandlines’ Supplier Code of Conduct to their own sub-contractors and sub-suppliers and to take into account the principles set out in the Scandlines’ Supplier Code of Conduct when they are selecting their sub-contractors and sub-suppliers. 

Scandlines provides a whistleblower system which allows both Scandlines staff and external parties to report any suspicions of ongoing or potential violations of the law or other serious misconduct. The whistleblower system is independently operated.

Procurement Policy / Preferred Vendor set up: Corporate Social Responsibility is one of the considerations in the selection process of a preferred vendor for Scandlines.

Supplier due diligence processes: 

We designed and implemented a due diligence process relating to the external suppliers of Scandlines’ retail and catering activities. The suppliers have been risk-rated in relation to slavery and human trafficking. For those rated as potentially higher risk, measures have been defined to communicate Scandlines’ principles and verify adherence by the relevant suppliers. These measures include regular, detailed supplier reviews and audits by Scandlines and/or by independent external parties. 

Staff training: 

The employees responsible for purchasing and supplier management receive relevant information and training on slavery and human trafficking. This includes awareness of the subject as part of the relevant third party due diligence process.

The Board of Management

Søren Poulsgaard Jensen                                                            

Per Johannesen Madsen

09 July 2019