Modern Slavery and Human Trafficking Statement 2023
We are committed to ensuring that no practices of modern slavery or human trafficking take place within Raznoimport (UK) Limited and its subsidiary, whether directly or within our supply chain, and ensuring that we continue to review our practices actively to ensure that they are robust and up to date.
Slavery, forced labour and human trafficking has no place in a modern society, in our organisation or in our supply chain. We’re committed to zero tolerance, and we are prepared to stop trading with partners and suppliers who won’t work with us to deliver on our policies.
We do not tolerate any form of workplace discrimination, harassment or physical assault, or any form of child, forced, or compulsory labour.
- Our Human Rights Policy recognises and aims to safeguard the human rights of everyone in our business, our partners and our supply chain.
- Our Procurement Policy supports our intention to source goods and services efficiently and fairly. The policy applies to our partners and supply chain, and sets out our health, safety, security, ethical and sustainability standards.
In accordance with our Code of Conduct, we seek to ensure that our suppliers, including contractors, maintain:
- Lawful business practices
- Zero tolerance for human rights violations, in relation to both their people and the communities in which they work.
- Working to support local communities, in areas where they operate and adhering to ethical social responsibility policies.
- Safe, healthy and fair workplaces and surrounding areas.
- Business practices that minimise environmental impact complying with the latest environmental and social responsibility requirements in our industry.
Our Business and supply chains
Our Business trades in non-ferrous metals, minerals, metal concentrates and ores and our customer base includes major stainless steel and metal producers. We serve leading commercial customers from metal producers to miners and shipping companies. Our supply chains include third party suppliers of mining services, operational and loading, shipping, railing and trucking services, telecoms, facilities and warehouse management services including, professional services, such as insurance and assay claims handling, accountancy, legal and HR services.
Our Policies on modern slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have introduced requirements to monitor this within our auditing process of on-boarding third party suppliers. We strive to act in an ethical manner with respect to all of our suppliers and business partners and to endorse the same high standards in their dealings with us.
Combating slavery and human trafficking and identifying any risks
During the year we carried out a modern slavery and trafficking risk assessment across all our activities. We have identified mining and production of ores and metals to be a potential risk area and have discussed the risks of modern slavery in this respect with our suppliers and have been given access to environmental and social responsibility reports that they have had conducted by independent inspectors. Based on our own policies and procedures, we believe the risks of slavery or human trafficking in the recruitment and engagement of our employees is low. We continue to conduct internal assessments to ensure that slavery and human trafficking are not taking place in any part of our business or supply chains.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we carry out ongoing monitoring of the third party suppliers we use.
We have put in place systems to:
(a) Identify and assess potential risk areas in our supply chains.
(b) Mitigate the risk of slavery and human trafficking occurring in our supply chains.
(c) Monitor potential risk areas in our supply chains.
Further steps
Following a review of the effectiveness of the steps we have taken to mitigate the risk of modern slavery or human trafficking in our supply chains we intend to take the following further steps going forward
. sharing this statement with all of our staff members and including it within our joining materials for our new employees
. further examining our supply chains to identify any further potential risk areas
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31st December 2022.
Signed: Mikhail Zheleznikov (CEO) 20th June 2023
Approved by the Board of Raznoimport (UK) Ltd- 20th June 2023.