Modern Slavery Act

Transparency in Supply Chains Statement (for the year ending 31 December 2018)

Dear Stakeholders

Concord is a signatory to the UN Global Compact. The company is committed to achieving a slavery and human trafficking free supply chain through its written policies and via their application, in its day-to-day actions.

Concord is a base metals and concentrates merchant trader, sourcing from and supplying to more than 30 countries globally. Concord applies its core principles and policies universally across its wide sourcing and distribution network.

Concord’s due diligence process firstly involves screening its counterparties via a “know your customer” (KYC) on-boarding process. The KYC process follows a defined template. The 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.

When negotiating with counterparties, Concord seeks to ensure that its contract contains provisions that define the production as originating from a specific source(s). After agreeing a supply relationship, Concord trains its staff to monitor, investigate and update information regarding our counterparties on a regular basis. Concord’s management and trading teams frequently visit counterparties to assess and report back on issues that they discover.

Concord is increasingly signing bilateral “Codes of Conduct Compliance” documents with our 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. The basic intent of such documents is for each party to confirm that it will:

• comply with all applicable laws and regulations;
• not employ under age employee or contract workpeople as defined under the applicable local laws;
• not engage or employ people against their own free will, nor will personnel be required to lodge ‘deposits’ or original identity papers upon commencing employment;
• comply with local law regarding working hours and overtime;
• ensure that minimum wages are paid to employees in accordance of the applicable local laws;
• treat their employees equally and fairly and not tolerate any form of harassment or discrimination;
• as far as reasonable, attempt to promote that potential business partners, agents, suppliers and intermediaries adopt equivalent principles; and
• use reasonable endeavours to ensure that there are no instances of human trafficking, sexual exploitation, slavery and bonded / forced labour on employees, particularly in or related to the workplace.

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.

Concord’s Code of Conduct includes a whistleblowing process for staff to report concerns about practices in the supply chain or in general employment that may not reflect Conduct legal and moral standards, without fear of reprisal.

We are committed to getting there, even if the journey never ends and we are never truly satisfied. Concord makes great efforts to ensure that it doesn’t knowingly deal with or support any counterparty that it believes to be involved in slavery, human trafficking or other similar human rights abuses.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Concord Resources Limited’s slavery and human trafficking statement for the financial period ended 31 December 2018. This statement was approved by Concord’s Board on 11 June 2019.

Yours Sincerely

[Original statement was approved by Concord’s Board on 11 June 2019 signed by Mark Hansen on 19 June 2019]

Mark Hansen