Modern Slavery Statement

Who we are

“Portland” provides goods and services in fuel and related products. This statement covers Portland Fuel Ltd, The Fuel Trading Company Ltd, Portland Analytics Ltd and Portland CSO Trading Ltd and any references to “we”, “us” or “Portland” can be taken to mean any of the four individual companies. We supply physical fuel by means of bulk, bunker or fuel cards to companies across the UK, we also provide diesel risk management, fuel consultancy work and the trading of CSO (Compulsory Stock Obligation) tickets. Further information on our operations is available at

We are based in York and carry out most of our work in the United Kingdom however we do have international operations, including an office in Gladbeck, Germany as well as trades carried out with customers on the North American continent. We have trading counterparties who are based throughout the world, although all our trading passes through London in accordance with FCA regulations.

Our commitment

Portland is opposed to slavery and human trafficking both in our day to day business and in any part of our supply chain.  We are committed to the principles of the s.54 Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. This statement demonstrates the systems and controls in place to safeguard against any form of modern slavery or human trafficking taking place within our business or supply chain.

This is our first such statement, and therefore highlights not only our current processes but areas in which we aim to develop. The purpose of this statement is to show our commitment to eradicating modern slavery, whether in our business or our supply chain, and to show our compliance with anti-slavery legislation.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Our Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees. This helps us to safeguard against human trafficking through ensuring the individuals have entered the country, registered and sought employment through their own free will.
  • Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. This policy follows the procedures set out in our employee handbook, signed by all members of staff, wherein our grievance procedure ensures that there is always a culture of trust between directors and employees in which any concerns can be raised. If the concerns relate to one director, employees know they can always raise them with another director and be treated confidentially.
  • Code of business conduct.  We operate according the principals of respecting one another, and acting in a fair, responsible and honest manner with all persons we interact and do business with. This encompasses taking care to do no harm to people and in doing so helps us avoid either advertently or inadvertently supporting modern slavery. All senior management staff have signed a separate Code of Conduct (COCON) document.

Our Suppliers and supply chain

Portland conducts due diligence on all suppliers before allowing them to become a supplier of goods or services to us.  This due diligence includes an online search to ensure that each individual organisation has not been convicted of offenses relating to modern slavery.  

Further considerations of suppliers are as follows;

  1. Confirmation they have taken steps to eradicate modern slavery within their business, inclusive of child labour.
  2. Confirmation they hold their own suppliers to account over modern slavery.
  3. Confirmation they pay their employees at least meet the national minimum wage or for international suppliers that they pay their employees any prevailing minimum wage applicable within their country of operations.
  4. Notification that we may terminate the contract at any time should any instances of modern slavery come to light.

We understand that the nature of our business could lead to instances of modern slavery/potential exploitation in the supply chain. Although we do not directly deal with the supply chain, we are committed to understanding where our product comes from to avoid any such incidents.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
  • No grievances from within the company have been raised with any of the directors.

Approval for this statement

This statement was approved by the Board of Directors on 08/01/2021.

Approving board member: James Spencer

Job Title: Managing director