Glencore : 2022 Modern Slavery Statement

Modern Slavery Statement 2022

Energising Advancing

today tomorrow

Following a risk-basedapproach, we assessed over 800 suppliers of metals and minerals using our internal risk criteria, including the risks defined in the OECD Due Diligence Guidance on Responsible Sourcing of Minerals from Conflict Affected and High-RiskAreas, 3rd edition (OECD DDG).

Our approach	Identifying and addressing risks	Additional information

Our commitment to addressing modern slavery

Progress during 2022

• Following a review of our responsible

sourcing programme, we revised and

rebranded our Supplier Standards as the

Supplier Code of Conduct.

• We launched the Supplier Code of

Conduct, which defines our requirements

and expectations for our suppliers and

how they work with us. The Code

strengthens our commitments in relation

to modern slavery and child labour and

• We are meeting emerging customer

expectations and retaining market access

by meeting the London Metal Exchange's

and London Bullion Market Association's

deadlines for re-registration of our brands,

both of which require compliance with the

OECD DDG.

• We conducted an annual review of our

responsible sourcing risk assessment tool,

which identifies relevant conflict-affected

and high-risk areas (CAHRAs) based on

risks relating to human rights, conflict, and

Introduction

Glencore plc is committed to preventing the occurrence of modern slavery and human trafficking in our operations and supply chains. Our 2022 Modern Slavery Statement (Statement) serves as a voluntary Statement under the UK Modern Slavery Act 2015 (UK Act) and a joint Statement under the Australian Modern Slavery Act 2018 (Cth) (Australian Act).

For the purposes of this Statement, we have considered the definitions of modern slavery in both the UK and Australian Acts, which cover various forms of exploitation including:

• slavery, servitude and forced or compulsory labour;
• human trafficking;
• sexual exploitation and forced marriage;
• child labour;
• deceptive recruiting practices; and
• debt bondage.

Board approval

This Statement has been approved by the Board of Glencore plc and is signed on its behalf by Kalidas Madhavpeddi, Chair of the Board, on behalf of all Glencore Group (Group) reporting entities under the Australian Act1 and of all Group entities, which carry on business in the UK for the purposes of the UK Act.

Kalidas Madhavpeddi

Chairman

30 June 2023

1 Glencore's reporting entities under the Australian Act are listed in the 'Additional Information' section below.

This document has not been prepared as financial or investment advice or to provide any guidance in relation to our future performance. Refer to the Important notice concerning this Statement, including in relation to forward looking statements, on page 31.

•	includes a new section on climate change.
We launched a new Responsible Sourcing
	Policy, which sets out our commitments
	to responsible sourcing for goods, services,
	metals, and minerals. Our refreshed
	responsible sourcing programme,
	launched in mid-2022, will support the
•	practical implementation of the Policy.
The Responsible Sourcing Policy is
	implemented through our Responsible
	Sourcing Standard which defines the
	mandatory minimum requirements for
	identification, assessment and
	management of key responsible sourcing
	risks associated with our suppliers of
•	goods, services, metals, and minerals.
We continued to conduct our existing
	supply chain due diligence of our goods
• and services providers.

governance.

Find out more: glencore.com

Our approach

Introduction	2
Board approval	2
Progress during 2022	2
CEO introduction	3
UK and Australian Modern Slavery	4
Act Statement
Our business	5
Our supply chains	8

Identifying and addressing risks

Identifying and assessing risks	10
Addressing risks	18
Measuring our effectiveness	24
Consultation	25
Planned actions for 2023	25

Additional information

Australian reporting entities	26
Glossary	29
Important notice	31
Contact us	32
Glencore Modern Slavery Statement 2022	2

Our approach	Identifying and addressing risks	Additional information

Chief Executive Officer's introduction

Committed to preventing modern slavery

Our Purpose is to responsibly source the commodities that advance everyday life. We are committed to delivering our Purpose in a manner that respects the rights of our workforce, communities, those involved in our supply chains and stakeholders affected by our business.

At Glencore, we recognise the global nature of modern slavery and its long-lasting impacts on affected individuals and communities. We are committed to preventing the occurrence of modern slavery and human trafficking in our operations and supply chains. We do not tolerate child labour, forced, compulsory or bonded labour, human trafficking or any other form of slavery and actively seek to identify and eliminate these practices from our supply chains.

During 2022, in response to an evolving regulatory environment and growing stakeholder expectations, we also launched our new Responsible Sourcing Policy, which is underpinned by our Responsible Sourcing Standard. The Policy and Standard are key elements of our updated responsible sourcing programme, which was launched Group-wide in mid-2022. We are establishing centralised, regional hubs for supply chain due diligence which reflects the elevated risk profile of our responsible sourcing obligations.

We are committed to meeting regulatory requirements for responsible sourcing and supply chain due diligence. In 2022, we met the LME's and LBMA's deadlines for reregistering brands that meet their responsible sourcing requirements.

Gary Nagle

Chief Executive Officer

I am pleased to introduce our 2022 Modern Slavery Statement. We are committed to addressing risks of modern slavery in our organisation and supply chains and our annual Statement sets out our approach, the steps that we have taken and our ongoing efforts in this regard.

We are signatories to the United Nations' Global Compact, a set of principles covering human rights, labour, environment and anti-corruption. We operate in accordance with local laws and relevant international frameworks, including the fundamental Conventions of the International Labour Organization. We set out our position of zero tolerance for modern slavery in our Code of Conduct, Responsible Sourcing Policy and Supplier Code of Conduct.

Our Supplier Code of Conduct sets our requirement for our suppliers to have zero tolerance for any form of modern slavery, forced labour or child labour in their operations or supply chains. Building on our 2019 Supplier Standards, our Supplier Code of Conduct, which was launched in June 2022, sets out our expectation that our suppliers share our commitment to ethical, safe and responsible business practices and support our Values.

We will continue our efforts to responsibly source and supply our products in a manner that identifies and addresses human rights risks, including modern slavery.

Gary Nagle,

Chief Executive Officer

30 June 2023

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Our approach	Identifying and addressing risks	Additional information

UK and Australian Modern Slavery Act Statement

This is our sixth statement under the UK Act and our third under the Australian Act. It describes the activities we have undertaken to strengthen our processes and better understand and address the risks of modern slavery and human trafficking in our operations and supply chains during both Acts' reporting periods (financial year 1 January to 31 December 2022).

The table below maps the recommended reporting criteria for UK Modern Slavery Act (2015) statements to the mandatory criteria required by the Australian Modern Slavery Act 2018 (Cth). A full list of our Australian entities reporting for the purposes of the Australian Act are set out in the 'Additional Information' section of this Statement.

UK Modern Slavery Act recommended reporting criteria	Australian Modern Slavery Act mandatory reporting criteria	Section	Page
	Identify the reporting entities	Additional Information	27
The organisation's structure, its business and its supply	Describe the structure, operations and supply chains of the	Structure and operations of our business	5
chains	reporting entity	Our supply chains
	Describe the risks of modern slavery practices in the	Identifying and assessing risks of modern slavery in our	8
	operations and supply chains of the reporting entity, and	operations and supply chains
	any entities that the reporting entity owns or controls
The organisation's policies in relation to slavery	Describe the actions taken by the reporting entity and any	Addressing risks of modern slavery in our industrial assets	10
and human trafficking.	entity that the reporting entity owns or controls, to assess	and supply chains
The organisation's due diligence processes in	and address those risks, including due diligence and
remediation processes
relation to slavery and human trafficking in its
business and supply chains
The organisation's training and capacity building
about slavery and human trafficking available to
its staff
The organisation's effectiveness in ensuring that	Describe how the reporting entity assesses the effectiveness	Measuring our effectiveness and performance	24
slavery and human trafficking is not taking place	of such actions
in its business or supply chains, measured against
such performance indicators as it considers
appropriate
	Describe the process of consultation with: (i) any entities	Consultation	25
	that the reporting entity owns or controls; and (ii) in the case
	of a reporting entity covered by a statement under section
	14 of the Australian Act - the entity giving the statement
	Include any other information that the reporting entity, or	Next steps	25
	the entity giving the statement, considers relevant

Glencore Modern Slavery Statement 2022

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Our approach	Identifying and addressing risks	Additional information

Our business

Our global operations

Head office

Marketing office/other

Industrial asset

One of the world's largest natural resource companies
6	35	c140k	>40
continents	countries	employees and contractors	offices

We are one of the world's largest global diversified natural resource companies and a major producer and marketer of more than 60 commodities that advance everyday life. Through a network of assets, customers and suppliers that spans the globe, we produce, process, recycle, source, market and distribute commodities that support decarbonisation while meeting the energy needs of today.

At the end of the reporting period, Glencore had around 140,000 employees and contractors and a strong footprint in over 35 countries in both established and emerging regions for natural resources. Our marketing and industrial activities were supported by a global network of more than 40 offices.

Glencore Modern Slavery Statement 2022

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