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The CRU group of companies (CRU) specialises in mining, metal and fertilizer commodities, delivering business intelligence through analysis, prices, consulting and events. At the heart of our culture is a strong set of company values: quality, integrity, team focus, customer focus and growth. These underpin our approach to all our stakeholders and underline our desire not only to do things right, but to do the right things. Accordingly, we believe there is no place for slavery, servitude, forced and compulsory labour or human trafficking in today’s society. This statement is pursuant to section 54 of the Modern Slavery Act 2015 and outlines the steps that CRU have taken to ensure that modern slavery has no place in our business or our supply chains.

Organisation Structure:
CRU is formed of four core areas with eleven international offices. CRU Analysis delivers independent market analysis on a comprehensive range of global commodities. CRU Prices publish high quality price assessment in a wide range of commodities. CRU Consulting provides informed and practical advice to meet the needs of our customers and their stakeholders. CRU Events creates industry leading commercial and technical events for the global commodity markets. Our business is central for the commodity market and we are committed to conducting business with honesty and integrity.

Responsibility:
A dedicated team has taken the lead on responsibility for the development and implementation of our anti-slavery initiatives. This team includes the Business Unit Heads from Human Resources, Events, Multi Commodities, Compliance and the CFO, to ensure that CRU is taking the correct pro-active approach to the subject and assess and manage any potential risk.

Internal policies:
All CRU employees across all our global offices are subject to rigorous employment checks and employed in accordance with local legislation requirements. CRU employees are subject to our global compliance policies which highlight the risk of modern day slavery and these policies are acknowledged by all employees annually. In addition, our whistle blowing policy actively encourages CRU employees to speak up if they know or suspect something is wrong. The Executive Committee and Office Managers, who ultimately are responsible for authorising any contracts, undertake training on modern day slavery to broaden their understanding of the issue.

Supply Chain:
Whilst we consider our risk to modern day slavery to be low, our supply chain is many and varied. We have considered each of our key business areas and determined that there are three key areas where we should focus our modern day slavery initiatives;

  • Venue suppliers for CRU Events. These venue suppliers, such as hotels or conference halls may have seasonal, lower skilled and lower paid employees. The CRU Events team will continue to bolster their good practice and understanding in relation modern day slavery and use venues that are committed to anti-slavery initiatives. The team endeavour to choose hotels and function venues that proactively take an anti-modern slavery stance and where appropriate write modern day slavery clauses into the contracts.
  • Outsourcing arrangements, particularly in developing countries which may be more susceptible to the risks of modern day slavery. We will continue to review outsourced arrangements and take a proportional approach by benchmarking these arrangements against the country risk rating as indicated in the Global Slavery Index. We will also endeavour to include modern day slavery clauses in any new outsourced arrangements.
  • Maintenance staff working in all our CRU Offices. Our Office managers will continue to review and attest to their division’s supply chain and take necessary steps to mitigate any exposure to the risk of modern day slavery.

This statement will be reviewed annually.

Should you require any further information on our Statement on Modern Slavery please contact Claire Ballak, Compliance Lead on compliance@crugroup.com

This statement has been published in accordance with Modern Slavery Act 2015 section 54 (1) and approved by CRU International Ltd Board of Directors for the financial year ending April 2021.

David Trafford, CEO, CRU International Limited.