Modern Slavery and Human Trafficking Statement
This is a voluntary statement by Apex Grove Distribution Ltd ("Apex Grove"), structured around the headings in section 54 of the UK Modern Slavery Act 2015 and reflecting our obligations under Kenyan law, including the Counter-Trafficking in Persons Act 2010 and the Employment Act 2007. Apex Grove is part of the Earthe group.
Our Structure, Business and Supply Chains
Apex Grove is a Kenyan private limited company. We provide borehole drilling and maintenance and construction and infrastructure works (such as footbridges and roads) for county governments and government agencies, and operate an international trade arm dealing in bulk commodities such as sugar, fuels such as LPG and gasoil, and bitumen.
Our supply chains include drilling equipment and consumables, construction materials, plant hire, labour and subcontractors, transport and logistics providers, and commodity and fuel producers, refiners, traders, shipping and storage providers.
Our Policies
We do not tolerate forced, bonded, compulsory or child labour, or human trafficking, anywhere in our business or supply chains. Our Anti-Bribery and Corruption, Sanctions and Trade Compliance, Health and Safety and Whistleblowing policies support this statement. In line with the Employment Act 2007 we provide written terms, pay at least the applicable minimum wage, respect lawful working hours, and do not retain workers' identity documents or charge recruitment fees.
Due Diligence
- Know-your-counterparty checks on commodity, fuel and bitumen suppliers, including ownership, origin of product and trading history.
- Sanctions screening of counterparties, vessels and beneficial owners against UN, UK, EU and US lists.
- Exclusion of product of sanctioned origin, including Iranian-origin product, and of counterparties subject to applicable sanctions.
- Checks on subcontractors and labour providers covering age verification, pay and documentation.
Risk Assessment and Management
We consider the highest-risk areas to be casual and subcontracted labour on construction and drilling sites, labour agencies, and upstream production and shipping of internationally traded commodities, particularly agricultural commodities such as sugar. We prioritise due diligence on these areas and may require remediation or end relationships where concerns are not addressed.
Effectiveness
We will track the completion of supplier checks, issues raised through our whistleblowing channel, and actions taken in response, and review this statement annually.
Training
Managers, site supervisors and staff involved in procurement and trading receive guidance on recognising indicators of modern slavery and trafficking, and on how to report concerns.
Reporting Concerns
Anyone can report a concern confidentially to connect@apexgrove.ke. Where appropriate, we will refer matters to the relevant Kenyan authorities.
Approval
This statement has been approved by the director of Apex Grove Distribution Ltd, Peter Mulati, and senior leadership.
Last reviewed: November 2026
Signed:
Gruffald Salter, CEO
Apex Grove Distribution Ltd