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 2023.

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 fall 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 has a zero-tolerance approach to modern slavery and human trafficking and is committed to acting ethically, with integrity in all its business practices and ensuring that its operations and supply chains are free from any form of modern slavery or human trafficking.

Concord undertakes deep due diligence processes in screening its counterparties via a “know your customer” (“KYC”) on-boarding process, prior to commercially engaging with them. The KYC process includes identifying specific fields relating to whether the counterparty has its own supply chain policy, whether it is in line with Concord’s anti-slavery policies and whether the counterparty is audited for compliance with its supply chain policy. All counterparties are also screened through public database searches and categorised using a risk-based approach (which incorporates, amongst other factors, countries of operation as a component). Concord seeks to ensure that all of its supply chain counterparties share an equivalent commitment to a transparent, ethical and responsible supply chain.

Concord is committed to maintaining a fair workplace in all of its business operations for all employees, regardless of gender, age, race or sexual orientation. Discrimination of any kind is strictly prohibited, and Concord advocates advancement based on meritocracy. 

When dealing with suppliers and counterparties which have passed its KYC process, Concord is increasingly signing bilateral "Code of Conduct Compliance" documents with its 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.

All relevant employees are required to be familiar with and comply with Concord’s position on modern slavery and human trafficking. Employees are encouraged to be vigilant and aware in their dealings with counterparts and are periodically trained in relation to these issues. Any reports are thoroughly investigated, and appropriate actions are taken.

Concord maintains whistleblowing processes where employees are able to report (without fear of reprisal) any concerns about modern slavery. Reports are thoroughly investigated, and appropriate actions are and will continue to be taken.

Moving forward:

1. Concord will continue to collaborate with customers, financiers and suppliers through all levels of its operations to improve practices and awareness to the risks of modern slavery.
2. Concord will continue to utilise existing (and where possible, improve) KYC checks and technology to enhance the quality of counterpart screening before onboarding for business dealings.
3. Concord will continue to reinforce messaging to all new and existing employees of its commitment to ethical practices and to remain vigilant and recognise such malpractices in all of its operations, so that instances are reported and appropriately dealt with. 

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 28 February 2024.
lssued for the year ended 31 December 2023