Modern Slavery Statement (CRL)

This statement is made pursuant to section 54 of the United Kingdom Modern Slavery Act 2015 (the “Act”) and constitutes Concord Resources Limited (“Concord”)’s modern slavery and human trafficking statement, as required by the Act, for the financial year ended 31 December 2022.

Concord is a company incorporated in England and Wales. As a result, 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 is a commodity merchant trader with a focus on non-ferrous metals and associated minerals and raw materials. Concord is the main trading entity of the Concord Group, and it both sources and delivers commodities predominantly in developed markets. The products that Concord trades, finances, moves and stores are relevant to many important global industries ranging from automobiles, aerospace, electronics construction, consumer products and infrastructure.

Concord is a signatory to the UN Global Compact. Concord supports the Act which aims to assist eradicating modern slavery, wherever it may occur, and raise public awareness of the modern slavery problem. Concord has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in its business dealings and relationships throughout the world and to implementing controls to safeguard against modern slavery taking place within its business or supply chains.

Concord is committed to achieving the highest standards of ethical behaviours in the conduct of its business and activities worldwide. Concord’s due diligence process firstly involves screening its counterparties via a “know your customer” (“KYC”) on-boarding process. The KYC process includes identifying 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 an information search for each counterparty to assess and analyse any press regarding the counterparty, including its supply chain issues. All counterparties are then screened through public database searches and categorised using a risk-based approach (which incorporates countries 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 employees are paid at least the minimum wage in the relevant local jurisdiction and in England, employees are paid significantly more than the London Living Wage. In the UK, Concord ensures that all staff have provided their National Insurance Number, and (if applicable) Working Visa, prior to their employment and a Legal Department member performs the necessary checks to determine their eligibility to work in the UK and ensure their salary will be monitored by HMRC. We make reasonable effort to ensure that every employee is trained on, and is aware of, their rights and obligations for equality in the workplace. Concord has a dedicated employee assisted helpline which is a life management and personal telephone service and is available to its employees 24 hours a day.

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

All of Concord’s employees are required to ensure that they are familiar with and comply with Concord’s position on modern slavery and human trafficking, including via Concord’s Code of Conduct and Compliance Policies and Procedures manual. Employees are encouraged to 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 must 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 (without fear of reprisal) any concerns about practices in the supply chain or in the general employment, that may not reflect Concord’s legal and moral standards.

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 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, which often include specific declarations made about actions that Concord (and Concord’s 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. Employees are encouraged to speak up if they identify anything concerning anywhere in the Concord supply chain.

Copies of our Modern Slavery Statements are published on Concord’s global website and on the UK Modern Slavery Statement Register.

Approved by the Board of Directors on 27 March 2023.
Issued for the year ended 31 December 2022