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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 that there is no place for slavery, servitude, forced and compulsory labor or human trafficking in today’s society. This statement outlines the steps that we have taken to ensure that modern slavery has no place in our business or our supply chains.

CRU structure and locations

CRU is an international organisation and employs over 280 experts and support staff with more than 11 offices around the world, in Europe (63%), the Americas (15%), China (12%), Asia (7%) and Australia (3%). Our business is formed of 4 core areas. 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.

Actions taken

In 2018 we hired a dedicated Compliance Lead to exercise oversight of the global compliance framework and embed the compliance culture as set by the CRU Executive Committee. Our Governance and internal oversight structures, policies and working practices are designed and operated to ensure that our business follows best industry practice. The CRU Executive Committee have been briefed on the subject of modern slavery and created a dedicated team responsible for the issue. This team includes the Business Unit Heads from Human Resources, Events, Consulting, Compliance and the CFO to ensure that CRU is taking the correct pro-active approach to the subject and reviewing any potential risk areas.

We consider our own business risk to modern slavery to be low risk due to our internal human resources policies. All CRU employees across all our global offices are subject to rigorous employment checks and employed in accordance to local legislation requirements. In addition, all CRU employees are subject to our global compliance policies and training. Specifically, our whistle blowing policy actively encourages CRU employees to speak up if they know or suspect something is wrong.

Our focus has been in areas that we consider could be higher risk such as our venue suppliers for CRU Events as hotels may have seasonal, lower skilled and lower paid employees. CRU Event employees are aware of modern slavery and human trafficking issues and are encouraged to highlight any issues to their manager. In addition, CRU Events endeavor 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.

Plan for this year

In the coming year we plan to improve our due diligence processes for all areas of the business to mitigate the risk of modern day slavery in our supply chain. We will review our CRU Group internal policies to ensure that the risks of modern day slavery are explicitly highlighted and understanding confirmed by all employees. The CRU Events business will continue to bolster their good practice and understanding in relation modern slavery and using venues that are committed to modern day slavery initiatives. They will also create an exclusion list of any venues that appear to violate any modern slavery or human trafficking obligations and not use any venue that appears on that list. We will continue to review our modern slavery risk and improve our compliance approach and raise awareness of the issue.

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 2020.

David Trafford, CEO,
CRU International Limited.