Modern Slavery and Human Trafficking Statement for the Financial Year Ending 31 December 2024

1. Introduction

European Tank Terminal BV is committed to preventing modern slavery and human trafficking in all its operations and supply chains. While our UK operations are currently limited, our global activities reflect our commitment to ethical conduct and human rights. 

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and outlines the steps we have taken and plan to take to prevent modern slavery in our operations and supply chain. Certain entities within the European Tank Terminal BV group are subject to the UK Modern Slavery Act 2015. This statement is made by European Tank Terminal BV B.V. as the parent company of the European Tank Terminal BV group and covers all other relevant group entities (“European Tank Terminal BV”) to which it is applicable.

 

2. Our Business and Structure

European Tank Terminal BV is a global energy storage and infrastructure company headquartered in the Netherlands. With over 1,200 employees worldwide, we operate in more than 17 countries. Our services include the storage, blending, and processing of energy products and low carbon fuels.

In the United Kingdom, European Tank Terminal BV has established an office and operational presence, including activities related to renewable natural gas (RNG). 

3. Policies and Governance framework

European Tank Terminal BV has a robust global compliance framework including, among others, Code of Conduct, ESG, Whistleblowing and Anti-Bribery and Corruption policies. While these policies do not yet explicitly reference “modern slavery,” they reflect our zero tolerance for unethical practices and protect human rights across our operations.

In 2025, we will further enhance these frameworks by:

• Including modern slavery and human trafficking risks in our compliance essential training module, 

• Further strengthening due diligence in our Know Your Counterparty (‘’KYC’’) process.

4. Risk Assessment and Due Diligence

Our operations are considered to be low risk for modern slavery, particularly in the UK. However, we recognize that certain tiers of our global supply chain (e.g., construction contractors, equipment providers, outsourced services) may involve higher risks.

We are taking a risk-based approach by: 

• Conducting screening of suppliers in higher-risk jurisdictions,

• Evaluating on a case-by-case basis if major supplier contracts should include human rights and anti-slavery clauses, 

• Reviewing grievance mechanisms to ensure they are accessible and effective.

5. Training and Awareness

To support our compliance culture, all employees receive regular training on ethics, compliance, and whistleblowing. In 2025, we will: 

• Include modern slavery and human trafficking risks in our compliance essential training module,

• Raise awareness through internal communications as part of our broader ESG awareness campaign. 

6. Measuring Effectiveness

Our effectiveness will be assessed through:

• Number of concerns reported via our grievance or whistleblowing channels (including the European Tank Terminal BV Integrity Line), 

• Inclusion of modern slavery questions in KYC procedures (where relevant),

• Employee training completion rates,

• Periodic review of policies and third-party risks.

7. Approval

This statement was approved and signed by European Tank Terminal BV on 30 June 2025.