Modern Slavery Statement

Introduction

This statement is made in accordance with Section 54 of the UK Modern Slavery Act 2015 by AET Pte Ltd, its wholly owned subsidiaries and affiliated companies (together “AET”). It outlines the procedures and steps undertaken by AET to identify, assess, and manage the risks of modern slavery and human trafficking within its operations and supply chains for the period from 1 January 2025 to 31 December 2025, as well as initiatives planned to further strengthen AET’s approach to human rights. 

About AET 

AET is a leading provider of international energy-related maritime solutions and services. AET owns and operates vessels supported by a workforce of sea and shore professionals from various nationalities. Headquartered in Singapore with regional offices in the US (Houston, Galveston), Brazil (Rio de Janeiro), UK (London), Norway (Stavanger) and Malaysia (Kuala Lumpur), AET is a diversified and global business.

We take pride in our asset and service reliability, commitment to upholding the highest standards of health, safety, security and environment (“HSSE") and sustainability, fostering a culture of excellence amongst our employees, operating responsibly and caring for the environment as well as making a positive difference to the communities in which we operate. 

AET's Commitment to Human Rights

AET remains steadfast in our commitment to upholding human rights and eliminating modern slavery across our operations and supply chains in a transparent and forward‑looking manner. We are committed to ensuring that human rights are respected, protected, and progressively strengthened in alignment with international standards and recognised best practices. In summary, our commitments include: 

1. Provide inclusivity, equal employment and fair remuneration opportunities for all employees regardless of race, nationality, religion and gender;
2. Promote a safe and healthy working environment that is free from sexual harassment and any forms of discrimination;
3. Uphold the right to freedom of association and recognition of the right to collective bargaining in accordance with applicable legislations;
4. Promote the well-being of the communities in which we operate; and
5. Eliminate all forms of modern slavery, forced labour, child labour and human trafficking within all our operations.

AET adopted its Human Rights Policy in September 2024, guided by four key principles that define our commitment and approach to respecting and upholding human rights across our operations and value chain:

1. Respect and acknowledgement of internationally recognised human rights
   We align our practices with the International Bill of Human Rights, the UN Universal Declaration of Human Rights, the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work and uphold strict compliance with the Maritime Labour Convention (“MLC”).
2. Adoption of a risk-based approach to human rights due diligence
   Our approach prioritises the identification and management of salient human rights risks, including labour and working conditions, supply chain practices, responsible security arrangements, and the well-being of local communities.
3. Access to effective grievance mechanisms and remedies
   We ensure that accessible, confidential, and non-retaliatory grievance channels are available for individuals to raise concerns and seek appropriate remedies.
4. Appropriate governance for human rights policy and its processes groupwide
   We strengthen organisation-wise governance, awareness, and competency through the Code of Business Ethics (“CoBE”) and continuous engagement and training.

We also maintain strong oversight of our human rights performance, including risks and mitigation efforts, and report in alignment with internationally recognised frameworks.

Our commitment is underpinned by a strong culture of integrity and ethical conduct across all business dealings and relationships. This is reflected in our Code of Conduct and Business Ethics (“CoBE”), which sets out the standards of behaviour expected of all employees and business partners. The CoBE incorporates requirements to respect human rights and to comply with applicable international laws and regulations.

AET's Approach to Due Diligence

We apply a risk-based due diligence approach to identify, prevent, mitigate and address actual and potential adverse human rights impacts arising from activities performed across the AET organisation, and resulting directly from our operations, products or services. These focus on our areas of identified importance which include labour and working conditions, supply chain, responsible security and communities' well-being.

• Activities performed across the AET organisation
  To identify and mitigate the risk of human rights violations, we have implemented a HRRA where we conduct a systematic and periodic review of potential human rights issues across AET’s business to ensure compliance with the latest human rights standards. This includes evaluating labour practices, working conditions, and the potential risk of human rights issues and modern slavery. The last HRRA was conducted in 2021 for AET shore staff covering labour/working conditions. 
  
  Following the adopted Human Rights Policy, we will be conducting the next HRRA for AET shore staff covering the same scope in 2026. This exercise was originally planned for 2025 but was deferred to 2026 to incorporate the latest human rights risk assessment approaches. For seafarers on-board our vessels managed by the ship management company MISC Marine Services (our sister company), a HRRA is planned to be completed in 2026 as well, encompassing all salient human rights elements relevant to their operations.
  
  
• Activities resulting directly from our operations, products or services
  AET’s commitment to respecting human rights extends beyond our own operations. We recognise that our business activities influence a broader value chain, and this requires close collaboration with third parties to ensure that the same standards of respect, responsibility, and ethical conduct are upheld. To support this in 2026 we plan to review our in-charter contracts, where we utilise vessels and crews from third party shipowners and ship managers, to ensure human rights are explicitly protected.
  
  To further strengthen this commitment, we have adopted a comprehensive framework that ensures our third parties align with the principles outlined in our Human Rights Policy. This approach reinforces ethical business practices, respect for internationally recognised human rights, and alignment with the UN Sustainable Development Goals.
  
  This framework encompasses the following:
  1. Supply Chain ESG Self-Assessment: Incorporates human rights elements in a self-assessment process which measure the maturity level of ESG compliance for critical vendors. The exercise has been implemented since 2021 and covers 10 of AET’s critical Tier-1 vendors, including our third-party ship managers managing seafarers on board our vessels. The last self-assessment was completed in 2024 with a 100% completion rate. 
  2. Code of Business Ethics (CoBE): Includes requirements to comply with human rights elements and applies to both our employees and vendors. AET’s vendors are required to agree to the AET CoBE.
  3. Third Party Compliance Due Diligence Assessment: Conducted before the formalisation of a business relationship to ensure that all pre-qualified third parties do not pose any significant associated compliance risk, which includes human rights-related risks, that could jeopardise the reputation of AET.
  4. Ship Recycling: We continue to comply with our Ship Recycling Statement which we adopted in 2021 to establish transparent principles for ethical and responsible ship recycling practices including human rights; in line with the Hong Kong Convention, which entered into force in 2025.

Access to Remedy and Reporting

In line with Pillar 3 of the UN Guiding Principles on Business and Human Rights, AET is committed to providing effective access to remedy for all stakeholders who may be impacted by our operations. To support this commitment, we have set up organisation-wide whistleblowing channels that offer a safe and secure avenue for internal and external stakeholders—including members of the public—to raise concerns or disclose improper conduct, including human rights–related grievances.

All cases reported through these channels are managed in accordance with established processes, and appropriate action is taken for cases where wrongdoing, including human rights violations, is confirmed. AET discloses the number of complaints received through its whistleblowing channels in its Annual Review. In 2025, one human rights-related complaint has been reported through its whistleblowing channels.

Awareness and Training

Capacity-building initiatives for employees, business partners, and other stakeholders remain essential to strengthening understanding of human rights risks—including modern slavery—across AET’s operations and supply chains. In 2025, we provided dedicated training sessions on human rights to our employees to equip them with the knowledge needed to identify risk indicators, prevent harm, and respond effectively to human rights–related issues.

In April 2025, AET reached an important milestone by joining the United Nations Global Compact (“UNGC”), reinforcing our commitment to the Ten Principles of the UN Global Compact—covering human rights, labour, the environment, and anti-corruption—and by embedding internationally recognised standards into our business practices.