Westwinds Offshore Services Limited
(“the Company”)

Modern Slavery and Human Trafficking 

Policy Statement

The Company, a licensed trust and corporate service provider in the Isle of Man, is fully committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. This policy reflects our company’s promise to act ethically and with integrity in all our business relationships. We ensure compliance with the requirements under the Modern Slavery Act 2015 and maintain consistent standards in line with the principles of the Isle of Man Financial Services Authority.

Structure of the Organisation

This policy applies to all persons working for or on behalf of The Company, including employees at all levels, directors, officers, agency workers, contractors, external consultants, third-party representatives, and business partners, as well as any other person or organisation related to our services such as trusts, companies, or partnerships we administer.

Definitions

Modern slavery encompasses:

• Human trafficking
• Forced work, through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
• Being dehumanised, treated as a commodity or bought and sold as property
• Being physically constrained or having restrictions placed on freedom of movement

Commitment

As an entity regulated by the Isle of Man Financial Services Authority, The Company understands its responsibility not only to comply with legislation but to foster transparency and integrity in all its activities. This extends to ensuring that our client structures are not being used to harbour or transfer benefits from illegal labour. Our commitment is to:

• Identify and assess potential risk areas in our supply chains and client structures.
• Mitigate the risk of slavery and human trafficking occurring.
• Monitor potential risk areas in our supply chains and client structures.
• Protect whistleblowers.

Due Diligence Processes

In line with our commitment to act ethically and with integrity in all our business dealings, The Company employs the following due diligence measures:

• Evaluating the nature and extent of our exposure to the risk of modern slavery occurring in our supply chains and client structures.
• Conducting audits of suppliers and reviewing client activities to evaluate compliance with company standards regarding modern slavery.
• Where necessary, we work with our clients to ensure that adequate due diligence is performed on their own supply chains if they are significant in size or complexity.

Key Performance Indicators

To measure the effectiveness of the measures we have implemented, we will monitor:

• Reports received from employees, clients, or law enforcement related to modern slavery or trafficking.
• Actions taken to strengthen supply chain auditing and verification against modern slavery and trafficking.
• Training levels of staff to raise awareness of modern slavery and human trafficking in our supply chains and business.

Training

The Company will provide training to staff involved in supply chain management and the administration of client structures to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and business.

Reporting

We encourage all employees, clients, and supply chain partners to report any concerns related to the direct activities, or the supply chains, of our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for individuals to make disclosures, without fear of retaliation.

Managerial Responsibility

Responsibility for this policy, its implementation, and ensuring it is maintained and updated in accordance with legal and regulatory developments lies with the Head of Compliance. The policy will be reviewed annually and updated as necessary.

This policy has been approved & authorised by the Board of Directors.

The Company takes its legal and ethical responsibilities very seriously, including those relating to combating modern slavery and human trafficking, and is committed to improving our practices to combat such activities within our influence.