Human Rights Due Diligence Report

Human Rights Due Diligence Report

SEADRILL LIMITED AND ITS GROUP OF COMPANIES (‘SEADRILL”)

This Human Rights Due Diligence Report (“Report”) is made pursuant to cf. section 5 of the “Åpenhetsloven”, the Norwegian Transparency Act 2022 (the “Act”) and to the extent applicable under the Act it sets out the steps that Seadrill has taken during this financial year and continues to take, to ensure that proportionate and risk-based human rights due diligence occur within our business and towards our suppliers and business partners.

INTRODUCTION FROM THE CEO

Seadrill carries out its operations in accordance with internationally recognised human rights standards and supports the UN’s Declaration of Human Rights and its work to end forced labour, discrimination, and child labour. Seadrill is committed to continuing to improve our practices to combat any potential human rights violations, such as modern slavery, human trafficking, as well as decent working conditions.

ORGANISATION’S STRUCTURE

Seadrill is a leading offshore drilling contractor employing highly skilled employees across the globe. We operate through a global structure, enabling us to provide extensive, specialist, coordinated and cohesive service. Our operations are split into four main operating centres in USA, Angola, Brazil and Norway and our corporate management office is located in UK.

OUR BUSINESS

Seadrill is one of the largest offshore drilling contractors in the world and our aim is to unlock oil and gas for the benefit of our customers in the safest most efficient way. Our versatile fleet of drillships, jack-ups, semi-submersibles and tender rigs operate in shallow to ultra-deepwater areas in both harsh and benign environments.

Our fleet is one of the youngest, most modern of all the major offshore drilling contractors. We are recognized for providing the highest quality operations, in some of the most challenging sectors of offshore drilling.

OUR SUPPLY CHAINS

Seadrill’s supply chain includes logistics, equipment and services for our rigs and associated services required to maintain our business. Our supply chain is head quartered in the United States, with representatives where Seadrill operates globally. Seadrill’s supply chain, with the assistance of group Compliance, ensures that each new supplier is put through a risk- based onboarding process to assess their suitability to perform the required services, financial viability and ESG background and experience.

HUMAN RIGHTS RISK ASSESSMENT AND DUE DILIGENCE PROCESS

Human Rights Risk Assessment of High-Risk Suppliers and Business Partners (collectively “Business Partner(s)”)

Seadrill assesses a Business Partner as high risk if that Business Partner operates in a location deemed a “Low Human Development” State or a “Medium Human Development” State pursuant to the UN Human Development Index (“HDI”), and is responsible for:

1. The day to day operational management of Seadrill rig(s) operating for clients, or
2. large construction and/or upgrade and/or scrapping project(s), or
3. large scale sub-contracting/outsourcing of services that would otherwise be performed by Seadrill personnel

The risks pertaining to these High Risk Business Partners derive from an appropriate level of control and oversight by Seadrill.

Human Rights Due Diligence of High-Risk Business Partners

Seadrill approach to human right due diligence is proportionate, and risk based. For business partners assessed as high risk, Seadrill has and will continue to perform bespoke human rights due diligence with a scope approved by the Chief Compliance Officer. This may include, but not be limited to the below measures:

Internal questionnaire to internal relationship owner
Completion of a due diligence questionnaire by the business partner
Independent third- party Human Rights assessment report
In person meetings with the business partner
Annual review
Seadrill Business Partners are required by contract to agree to comply with applicable human right laws and regulations throughout their supply chain and this is associated with applicable audit rights.

Seadrill Integrity Channel
Separately, as part of our initiative to identify and mitigate risk, we operate an integrity reporting channel (the “Seadrill Integrity Channel”), run by an independent third party through which any matters of integrity concern can be raised, including those that relate to human rights, modern slavery, or human trafficking within our business. If preferred, integrity concerns reporting can be submitted to the Seadrill Integrity Channel anonymously. We also welcome integrity concerns reporting being raised internally, whether direct to management, or with our HR, Legal or Compliance functions. Seadrill does not accept retaliation in respect of any integrity concerns reports raised in good faith.

OUR POLICIES ON HUMAN RIGHTS DUE DILIGENCE

We are committed to ensuring there are no human rights violations, including but not limited to modern slavery or human trafficking in our supply chains or in any part of our business. We publicise our commitment to human rights and to ending forced labour in our Sustainability Report, and it is anchored in our Code of Conduct (“Code”) both which can be located on our website and our employees undertake mandatory online Code training.

Seadrill is continuously working towards further strengthening our human rights, slavery, and human trafficking compliance Program.

PARTNER ADHERENCE TO OUR VALUES

We require our Business Partners to adhere to our values. Our Code of Conduct confirms our zero-tolerance attitude towards human rights violations, modern slavery, and human trafficking. We shall only work with Business Partners who commit to operating to the same standards as outlined in our Code.

To reinforce this, we have introduced mandatory anti-slavery clauses into our supply chain contracts and are working on a Supplier Code of Conduct to issue to our suppliers.

TRAINING

To ensure a high level of understanding of the risks of human rights, modern slavery, and human trafficking in our business, targeted awareness training shall be provided to our procurement staff, as well as targeted human rights due diligence reporting training to our Compliance and supply chain staff.

This constitutes Seadrill’s Human Rights Due Diligence Report for the period to 30 June 2023.