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Modern Slavery and Human Trafficking Statement

2021-2022

The Modern Slavery Act

This statement is made on behalf of GFG Alliance (the Alliance) businesses pursuant to section 54 of the Modern Slavery Act 2015 (the Act) and constitutes our modern slavery and human trafficking statement and is intended to demonstrate how GFG Alliance applies its values in the course of business and highlights the degree to which we view our duty to challenge and confront the use of forced, compulsory, trafficked or child labour within our own organisation and our supply chains.

“Modern Slavery” refers to the offences of human trafficking, slavery, servitude and forced or compulsory labour.

“Human Trafficking” is the movement of people through force, fraud, coercion or deception with the aim of exploit exploiting them.

Our Business

GFG Alliance is a collection of global businesses and investments owned by Sanjeev Gupta and his family. The businesses are united through shared values, purpose and strategy to create a sustainable future for industry and society.

Our Principles

At GFG Alliance, we are committed to doing our part in eradicating modern slavery in all its forms from our global business and supply chains. It is our policy to conduct business fairly and ethically and to comply with all applicable laws.

Our vision is to create a more sustainable and accessible future for industry as a foundation upon which we can build a stronger and more prosperous community.

Our Code of Conduct, Whistleblowing, Health & Safety, Human Rights and Modern-Day Slavery Standards and Supplier Standards reflects our commitment to acting ethically and with integrity in our business and supply chains.

GFG Alliance is aware of the adverse impact immoral and illegal practices have on the lives of vulnerable individuals. We pledge to continuously drive our practices to uphold human rights not only through our businesses, but also in the industries we operate in.

The Alliance has recruited global teams for Compliance, Audit, Health & Safety and Procurement to drive our commitment to tackling modern slavery and human trafficking into every part of our organisation.

We have made commitments and have taken forward appropriate initiatives to ensure that anyone working for, or with, GFG Alliance benefits from a proactive employer who is socially responsible, safe and ethical.

Our policies

GFG Alliance is continually developing global standards and initiatives to ensure we do our part in fighting unethical and illegal practices that do not align with our values towards human rights and human trafficking.

a. Code of Conduct

The Alliance’s Code of Conduct was established to demonstrate our corporate social responsibility towards all of our stakeholders. It is our commitment to comply with all applicable legislative and jurisdictional requirements to the highest degree – we expect the same from our suppliers.

Our code, which is accessible and visible to all our employees, outlines our responsibility as an employer and a service provider by highlighting our determination to embed our values of Family, Change and Sustainability through the entire Alliance.

Through our Code of Conduct, we promote equal opportunities and maintain a workplace where our family can work with dignity and respect and free from bullying or discrimination. We expect our suppliers to treat their employees in the same manner.

We are a responsible employer and take pride in our multi-national and diversified workforce. Whilst challenging, our pledge is to create a workplace where we can celebrate the wide reach of our organisation through a Diversity & Inclusion Network but also to combat the challenges faced by our global workforce as we adapt to an everchanging world. The Alliance launched our ‘Everyday Heroes’ programme to share how important each and every role is in our organisation is but also to provide an opportunity to learn about the challenges each or us might face in our work life.

We want to attract skilled workers from all walks of life and provide them with the resources to carry out their duties to the best of their ability. We plan to build upon this foundation and ensure our employees have ethics and values that are in line with ours, achievable through employee coaching, mentoring and training opportunities.

b. Health & Safety

The work we do is critical to the growth and prosperity of the communities and countries that we operate in; our workplaces vary from mines, mills and plants where strict adherence to rules must be kept to maintain the safety of ourselves and of others.

We value human life above all else and manage risks accordingly through our ‘Be GFG Safe’ strategy which includes safety, mental and physical health as pillars. Our policy is to provide transparency, learn from errors and incorporate social responsibility and environmental excellence into our decision making processes.

We listened to the feedback in our COVID-19 People Check-In and Your Voice surveys to prioritise our workforce’s mental health during the pandemic to launch ‘I Am Here’ through which our employees can access mental health resources while we adjust to a newer way of working. It is one of the initial steps in our long-term goal to foster a culture of care and safety in line with our values.

We are collectively responsible for safety. The Alliance established ‘GFG Life Savers’ through which employees can intervene, report and discuss human errors to learn from while unconsciously developing an interdependent safety culture. There is no one size fits all in our organisation, so we pledge to build upon this foundation and integrate safety in everything we do.

In the spirit of our GREENSTEEL and GREENALUMIUM approaches, we launched a Carbon Neutrality initiative (CN30) which will create an economically and environmentally sustainable future for the global metals industry. We aim to secure materials and resources locally to make world class products that are accessible both nationally and globally. We are investing in breakthrough technologies to remove emission and combine renewable power in making our product. We want to achieve this through fair measures that are respectful of human rights.

c. Human Rights & Modern Day Slavery

GFG Alliance reviewed its Human Rights policy and developed a more inclusive standard through which we demonstrate our commitment to fighting human rights abuses and modern slavery. We incorporate internationally-recognised human rights including International Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, and benchmark how we expect our organisation to operate.

The UN Guiding Principles on Business and Human Rights is an integral part of our business conduct and we will continuously monitor our impact on human rights through our dedicated functions.

GFG Alliance is committed to labour and workplace rights. We provide fair pay and fair working conditions in line with statutory requirements of each state we operate in and expect the same from our suppliers in their workforce.

d. Whistleblowing

The Alliance encourages honesty, openness and transparency. In our businesses we provide avenues to all employees and those working with us to raise concerns, questions or grievances through our Human Rights & Modern-Day Slavery and Whistleblowing Standards.

Employees are required to report any known or suspected violations of applicable laws, regulations, policies or ethics and can do so through various channels including telephone hotlines, in writing or in person.

We take all allegations of any type of unethical, immoral or illegal behaviour, including those found in our supply chains, and concerns related to human rights violations, very seriously and we have dedicated teams who deal with reported concerns sensitively and who will take the appropriate remedial action.

e. Our Supply Chain

Suppliers and Vendors
GFG Alliance’s global business is built upon a supply chain that spans from raw materials to transportation and trading of commodities.

Through our GFG Alliance Supplier Standards, we state what we expect of our suppliers and vendors in line with the GFG values of Family, Change and Sustainability. We trust our suppliers and vendors will work with us in promoting business practices that are ethical, safe and socially responsible. We expect suppliers and vendors to seek the highest degree of standards for:

  • Health & Safety
  • Commercial Excellence & Partnership
  • Worker’s Rights
  • Professional Business Practices
  • Environmental, Social and Governance

Due Diligence
GFG Alliance completes due diligence checks when onboarding new suppliers as well as at regular intervals to check compliance with legal and ethical requirements but also uses the checks to identify and remediate modern slavery practices. We have a dedicated global audit resource team available to support local teams meet our expectations with respect to Modern Slavery.

Our pledge is to further manage our risks by developing our due diligence measures in all areas of our business. We will endeavour to identify suppliers and vendors within our supply chain who are associated with high-risk countries in respect of human rights violation and human trafficking.

Our Pledge

GFG Alliance recognises the complex nature of modern slavery as we carry out more work in developing our systems and controls.

Our pledge is to ensure our global standards and initiatives are in place, understood and functional across the Alliance. We will regularly monitor these measures and drive improvements across the organisation.

Our Executive Committee will assess our progress and drive future priorities to enhance the actions we have taken to improve our approach to modern slavery and human trafficking, and that of our suppliers. Our pledge is to use our influence within the industry to develop a programme that engages suppliers, vendors and communities to measure societal impact, raise awareness and drive positive change.

Training and Communication

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we endeavour to provide training to our employees by taking a top-down approach. This statement will be shared through internal communication channels and made available on our website.

GFG Alliance recognises that the knowledge, responsibility and conduct of our employees play an important role in mitigating the risk of slavery and human trafficking within our organisation. We have invested in e-learning systems for more areas of our business which will make training easily accessible; through which we can monitor the effectiveness of our policies and embed change within our global workplace.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes GFG Alliance’s slavery and human trafficking statement for the financial year ending 2021.