Modern Slavery Act

Dear Stakeholders

Concord is a signatory to the UN Global Compact and in its actions and through its written policies, it is committed to achieving a slavery and human trafficking free supply chain, no matter where materials are sourced from or supplied to and no matter where we provide services to or receive services from.

Concord sources and supplies base metals and concentrates from and to more than 30 countries and over 300 counterparties and this is increasing, almost every day.

As a company with a wide sourcing and distribution network, the process of identifying each and every aspect of our direct and indirect supply chain is a complex, time consuming, difficult and constantly evolving one. However, it remains very high on our corporate agenda and is managed at the highest company levels.

Concord is dedicated to maintaining a fair workplace for all employees and its recruitment policy includes eligibility checks, equal opportunity and ensuring proper right to work status.

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.

Our counterparties are screened through a “know your customer”, on-boarding process which specifically asks questions of and involves investigating our counterparties’ policies and behaviours (including through public database searches) to try to ensure that they share the same commitment to a transparent, responsible and legal supply chain.

We train our staff to monitor, investigate and update information regarding our counterparties and both management and our trading team frequently visit our counterparties to assess and report back on the good and not so good that they discover. We are 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 they will:

• comply with all applicable laws and regulations;
• not employ under age employee or contract workmen 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.

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 knows 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 2017.

Yours Sincerely

[Original statement signed by Mark Hansen on 22 June 2018]

Mark Hansen