London Chemicals & Resources Limited (LCR) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chains and requires the same high standards of its suppliers.

As a company, LCR is mindful of the role it plays in eliminating the exploitation of individuals at the hands of others. This statement sets out the steps LCR has taken and is taking, to prevent acts of modern slavery and human trafficking within its organization and supply chains.

LCR is a supplier of inorganic chemicals and recycling services to a global customer base through a network of agencies. LCR employs people and works with an agency network in the UK and overseas.

We operate a specialist business focused on both the provision of inorganic chemicals and the recycling of spent catalysts and other secondary raw materials.

Further information about the company’s activities can be found at: www.lcrl.net

As part of LCR’s trading and manufacturing business, we work with a range of manufacturers, suppliers and consumers. The nature of supply chains across LCR is diverse and reflects the differing nature of the business. Some of the supply chains are higher risk than others and LCR adopts policies and procedures within its business reflecting the levels of risk faced.

As part of our commitment to combatting modern slavery, LCR condemns the use of forced, bonded or indentured labour, involuntary prison labour, slavery, servitude or trafficking of persons against their will. More specifically, LCR has adopted the following principles relevant to the issues addressed in this statement:

• Importance of people: People are a key factor for our business to succeed. We are proud of the average length of service of employees across LCR and intend to retain people for the long term in fairly paid and stable jobs. We ensure that remuneration for employees meets or exceeds applicable legal minimums and, in the UK, refuse the use of “zero hours” contracts. We respect employees’ rights under applicable law in relation to limits on the hours they may be required to work.
• Child labour: LCR condemns the use of child labour and does not employ children in any aspect of its business.
• Equality of opportunity: LCR is committed to a policy of equal opportunity in all aspects of employment and has established policies to assist in putting this commitment into practice. These policies are applied to all aspects of work, including recruitment and selection of pay and benefits, facilities, promotion, opportunities for training and discipline.
• Transparency and accountability: LCR is committed to conducting its business with honesty and integrity and it expects all staff to maintain high moral and ethical standards as representatives of LCR. LCR has adopted “whistleblowing” and investigatory policies to foster a culture of openness and accountability and to ensure that the policies of LCR can be appropriately implemented and enforced.
• Modern slavery and human trafficking as a global issue: LCR recognises that combatting modern slavery and human trafficking is a challenge not just within LCR but across the supply chains of which members of LCR form a part. LCR looks to ensure that no party to its business transactions is involved in practices that contravene LCR policies on modern slavery and human trafficking, as described herein.

These principles have been developed by reference to applicable law and regulation and LCR judgment on appropriate practices for combatting modern slavery and human trafficking in the context of its operations and supply chains. Where appropriate, these principles are reflected in the codes and policies that employees of LCR are required to adhere to whilst working for LCR.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence procedures:

• We conduct “Know Your Supplier” processes on our suppliers to ensure they are compliant with applicable laws and regulations, including in relation to modern slavery and human trafficking.
• In line with the OECD Guidelines for Multinational Enterprises (which recommends companies carry out supply chain due diligence to identify, prevent, mitigate and account for all adverse impacts that they cover, including child labour and forced labour issues) (the “OECD Guidelines”), we adopt a risk-based approach to due diligence on suppliers, including in relation to modern slavery and human trafficking. In areas where the risk is deemed to be high, further detailed due diligence is undertaken together with supply chain certification where necessary. In line with this risk-based approach, LCR’S current due diligence principles are as follows:
  • Supply chain participants based in the UK are expected to have adopted appropriate modern slavery and human trafficking policies.
  • Supply chain participants based in the OECD’s member countries or countries that are known to have adopted the OECD Guidelines are expected to be low risk and, as a minimum, are expected to comply with relevant employment legislation of the country where they are based and any specific modern slavery and human trafficking regulations.
  • Supply chain participants based in countries where compliance with the OECD Guidelines is unknown and there is considered to be a higher risk of modern slavery or human trafficking activities occurring are required to confirm adherence to our policies or a comparable policy addressing the same concerns. Where appropriate written evidence of such a policy is not available, additional due diligence may be undertaken to determine substantive compliance with applicable modern slavery and human trafficking requirements.

The due diligence exercises described above are undertaken by members of LCR involved in the relevant supply chain and taking into account their judgment as to what scope of due diligence is necessary in the relevant circumstances.

These procedures, together with the policies described in Section 4 above, are designed to:

• establish and assess areas of potential risk in our business and supply chains;
• monitor potential risk areas in our business and supply chains;
• reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
• provide adequate protection for whistleblowers.

We regularly evaluate the nature and extent of our exposure to the risk of modern slavery occurring in our supply chain by reviewing the policies outlined above, communicating our expectations and values to participants in our supply chains and reviewing our due diligence checks and working practices.

We do not tolerate slavery and human trafficking within our supply chains. If we find evidence of a failure by a supplier to comply with relevant slavery and human trafficking policies or laws and regulation, we will consider how to most appropriately address this non-compliance. In some instances, we may require suppliers to take immediate action to remediate the issues identified; in others, we may seek to terminate our relationship with the relevant supplier immediately.

LCR does not currently impose any key performance indicators (“KPIs”) on members of LCR and its management is best placed to assess whether these policies are having the desired effect. To the extent that feedback is received from members of the team, this is considered as part of the regular review process for LCR policies.

LCR does, however, acknowledge that KPIs provide a useful comparative tool for assessing compliance across LCR and can assist in determining whether its policies are helping LCR to ensure that slavery and human trafficking are not taking place in any part of our business or supply chains.

We invest in educating our staff who are involved in our supply chain and purchasing management to recognise the risks of modern slavery and human trafficking in our business and supply chains. Employees are encouraged to identify and report potential breaches of our anti-slavery and human trafficking policy and made aware of the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

Employees can report suspicions of slavery or human trafficking directly to Management of LCR or externally to the Modern Slavery Helpline www.modernslaveryhelpline.org

Following reviews of our actions to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to taking additional steps to tackle slavery and human trafficking.

For the purposes of section 54(1) of the Modern Slavery Act 2015 (the “MSA ‘15”), LCR is not required to produce a slavery and human trafficking statement. However, given the importance of these issues to LCR’s business and supply chains, LCR feels it is appropriate for such a statement to be publicised so customers, suppliers and other interested parties are able to understand how we address these issues.

Richard Bartholomew
Managing Director
London Chemicals & Resources Limited