Modern Slavery Statement

This statement is made pursuant to section 54 of the United Kingdom Modern Slavery Act 2015 (the “Act”) and constitutes Concord Resources Limited’s (“Concord”)’s modern slavery and human trafficking statement, as required by the Act, for its financial year ended 31 December 2020.

Concord Resources Limited is a company incorporated in England and Wales and.  B because of this, and to the extent it carries on business, or part of a business, in the UK, it may be within the scope of the Act.

Concord Resources Limited is a commodity merchant trader with a focus on non-ferrous metals and associated minerals and raw materials.  The products that Concord trades, finances, moves and stores are relevant to any number of important global industries ranging from automobiles, aerospace, electronics construction, consumer products and infrastructure.

Concord Resources Limited is a signatory to the UN Global Compact.  It has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in business dealings and relationships throughout the world and to implementing controls to safeguard against modern slavery taking place anywhere within its own business or its supply chains.

Concord’s due diligence process firstly involves screening its counterparties via a “know your customer” (“KYC”) on-boarding process. The KYC template includes specific fields relating to whether the counterparty has a supply chain policy in place and whether the counterparty is audited for compliance with its supply chain policy. Concord also performs a news search for each counterparty to assess and analyse any press regarding supply chain issues. All counterparties are then screened through public database searches and categorised using a risk-based approach (which incorporates country(ies) of operation as a component), trying to ensure that Concord’s counterparties share the same commitment to a transparent, responsible and legal supply chain.  

Concord is dedicated to maintaining a fair workplace for all employees. Concord’s recruitment policy includes eligibility checks, equal opportunity and ensuring proper right to work status. All Concord’s UK employees’ salaries at least meet the National Living Wage and statutory leave entitlements, and this approach is applied consistently to meet local legislation in all jurisdictions in which Concord operates.  In the UK, Concord is able to utilise its employees’ skills of employees from across the world, and it ensures all our staff have provided their National Insurance Number, (and working visa, if applicable), prior to their employment and perform the necessary checks to determine their eligibility to work in the UK and ensure their salary will be monitored by HMRC.

When dealing with suppliers and counterparties which have passed its KYC process, Concord is increasingly signing bilateral “Codes of Conduct Compliance” documents with our its counterparties, which often include specific declarations made about actions that Concord (and its counterparties) take to help ensure the prevention of slavery in all its guises. Further, after agreeing a supply relationship, Concord trains its staff to monitor, investigate and update information regarding Concord’s counterparties on a regular basis.   Whenever possible, Concord’s management and trading teams frequently visit counterparties to assess and report back on issues that they discover.

All of our employees are required to ensure that they are familiar with and comply with Concord’s position on modern slavery and human trafficking.  Employees should be vigilant and aware in their dealings with suppliers and consumers and if there are any concerns or indications that there is any potential modern slavery, human trafficking or other human rights violations, they should notify a member of the management team immediately and before proceeding or continuing with any business activity.   Additionally, Concord’s Code of Conduct contains whistleblowing procedures that can be followed to report any concerns about practices in the supply chain or in the general employment that may not reflect Conduct legal and moral standards, without fear of reprisal.

Although it is difficult to be absolutely sure, Concord is confident that the following elements minimise the risk that an instance of modern slavery or trafficking exists within in its supply chain:

1. Strong personal relationships with customers and suppliers through all levels of a company are key to Concord’s business and Concord’s management and trading teams frequently speak with (and where possible) visit counterparties to assess and report back on issues that they discover.
2. As detailed above, all new customers and suppliers go through detailed KYC checks before any trading is executed.  
3. As detailed above, Concord is increasingly signing bilateral “Codes of Conduct Compliance” documents with our counterparties (or agree to objective, international standards like the UN Global Compact), which often include specific declarations made about actions that Concord (and its counterparties) take to help ensure the prevention of slavery in all its guises.
4. Concord is a signatory to the UN Global Compact and this, together with the requirement that all employees comply with the Concord Code of Conduct no matter where they are located around the world, means that there is a clear understanding at an employee level that Concord is committed to achieving a slavery and human trafficking free supply chain and employees are encouraged to speak up if they identify anything concerning anywhere in the Concord supply chain. 

Approved by the Board of Directors and signed by Mark Hansen on 16 February 2021. Issued for the year ended 31 December 2020.