Modern Slavery Policy and Human Rights for Dolphin Drilling

Modern Slavery is a crime and violation of fundamental human rights. It can take various forms, such as slavery, servitude, forced labour and human trafficking.

Consistent with section 54 of the UK Modern Slavery Act 2015, and the Norwegian Transparency Act 2022, Dolphin Drilling (hereinafter referred to as the ‘the Company’) have a zero-tolerance approach to modern slavery and other basic human rights violations and is committed to acting ethically and with integrity in its business dealings and relationships.

The Company is committed to implementing and enforcing effective systems and controls to ensure modern slavery basic human rights violations is not taking place anywhere in its business or any of its supply chains. By conducting risk assessment and due diligence assessments on its own operations, its supply chains and business partners, the Company aims to identify and appropriately address adverse human rights impacts of the business.

The Company has a Code of Conduct that prohibits modern slavery. We expect all employees and everyone we do business with to comply with our Code of Conduct. All employees are also required to complete the Anti-Corruption and Business Ethics Course.

The Company encourage everyone to raise concerns about any issue or suspicion of modern slavery or other basic human rights violations in any part of the business or supply chains.

The Company will annually publish more information about measures taken to prevent basic human rights violations, as well as actual negative consequences or substantial risks identified through its due diligence assessments. Such information will be made available on the Company’s website.

For any external information requests on how we address potential and actual impacts on human rights should be sent to compliance@dolphindrilling.com