Our commitment to addressing modern slavery Statement Slavery Modern Our approach Addressing risk Additional Information Contact us

Legal Our Our supply Introduction Our business requirements commitment chains

Introduction Our approach Introduction 1 Glencore plc is committed to preventing the occurrence of Legal requirements 2 Our commitment 3 modern slavery and human trafficking in our operations and Our business 3 Our supply chains 5 supply chains. This Statement serves as a voluntary Statement

Addressing risk under the UK Modern Slavery Act 2015 (UK Act) and a joint Business risks 8 Statement under the Australian Modern Slavery Act 2018 (Cth) Supply chain risks 14 1 Operational risks 19 (Australian Act). Effectiveness 23 Consultation 26 For the purposes of this Statement, we have considered We set out our commitment to zero tolerance for modern Next steps 27 the definitions of modern slavery in both the UK and slavery in our workplaces and supply chains in our Code Board approval 28 Australian Acts, which cover various forms of exploitation of Conduct, Supplier Standards and in our Group Human including: Rights Policy: Additional information • slavery, servitude and forced or compulsory labour; • We do not tolerate child labour, any form of forced, Australian entities 30 compulsory or bonded labour, human trafficking or any Important notice 31 • human trafficking; other form of slavery and actively seek to identify and Contact us 32 • sexual exploitation and forced marriage; eliminate them from our supply chains. • child labour; • We promote fair recruitment and employment practices • deceptive recruiting practices; and so that all work is voluntary and fairly compensated. • debt bondage. This annual statement sets out our approach to modern slavery, the steps we have taken and are taking, and our These terms are also defined and recognised under commitment to address risks of modern slavery in our international law. organisation and supply chains. Modern slavery is a global concern with long-lasting impacts on affected individuals and communities. We recognise our responsibility to work collaboratively with our suppliers, customers, workforce and external stakeholders to increase our understanding of modern slavery risks and the role we can play in seeking to address them where they exist.

1 As discussed in the Board Approval section, Glencore plc approves this Statement on behalf of its Australian reporting entities.

Glencore Modern Slavery Statement 2020 1 Our approach Addressing risk Additional Information Contact us

Legal Our Our supply Introduction Our business requirements commitment chains

The table below maps the recommended reporting criteria for UK Modern Slavery Act (2015) statements to the mandatory UK and criteria required by the Australian Modern Slavery Act (2018).

Australian UK Modern Slavery Act Australian Modern Slavery Act mandatory Glencore’s response recommended reporting criteria reporting criteria Modern Slavery Section Act Statement Identify the reporting entities Appendix A The organisation’s structure, its Describe the structure, operations and supply chains of Structure and operations of our business business and its supply chains the reporting entity Our supply chains This is our fifth Statement under the UK Act and our first under the Australian Describe the risks of modern slavery practices in the Identifying and assessing risks of modern slavery in our Act. It describes the activities we have operations and supply chains of the reporting entity, and business undertaken to strengthen our processes any entities that the reporting entity owns or controls and better understand and address The organisation’s policies in relation to Describe the actions taken by the reporting entity and Governance the risks of modern slavery and human slavery and human trafficking any entity that the reporting entity owns or controls, to trafficking in our operations and supply assess and address those risks, including due diligence Supply chain due diligence The organisation’s due diligence and remediation processes chains during both Acts’ reporting processes in relation to slavery and Addressing geographic risk periods (1 April 2020 to 31 March 2021 for human trafficking in its business and Strengthening workforce capacity supply chains the UK Act and 1 January to 31 December The organisation’s training and 2020 for the Australian Act) and sets out capacity building about slavery and the relevant section of this Statement human trafficking available to its staff where the criteria are addressed. The organisation’s effectiveness in Describe how the reporting entity assesses the Effectiveness ensuring that slavery and human effectiveness of such actions trafficking is not taking place 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 that the reporting entity owns or controls; and (ii) in the case of a reporting entity covered by a statement under section 14—the entity giving the statement

Include any other information that the reporting entity, or Next steps the entity giving the statement, considers relevant

Glencore Modern Slavery Statement 2020 2 Our approach Addressing risk Additional Information Contact us

Legal Our Our supply Introduction Our business requirements commitment chains

Our commitment to addressing Structure and operations modern slavery of our business

Acknowledging that modern slavery While our geographic and product Glencore is one of the world’s largest natural resource companies. We is a real and global concern with long- diversity provides challenges in ensuring employ around 135,000 people across over 35 countries, and produce and lasting impacts on affected individuals the absence of modern slavery within our market more than 60 commodities. and communities, we recognise our supply chains, we do not tolerate child responsibility to work collaboratively labour, any form of forced, compulsory with our suppliers, customers, workforce or bonded labour, human trafficking or and external stakeholders to reduce any other form of slavery and actively the risks of modern slavery in our seek to identify and eliminate them from operations and supply chains. Further, our supply chains. In the event that we consumers are increasingly scrutinising identify either a high-risk supplier or the supply chains of the products they the presence of modern slavery in our consume, and so our customers are supply chains, we would first work with increasingly seeking reassurance that the affected suppliers to improve their the materials they buy are produced practices and safeguards. If these actions sustainably and ethically. By taking action do not bring about sufficient change, we to mitigate modern slavery risks, we are will end the relationship. also mitigating the risk of operational We are signatories to the United Key: disruption that our business could face Nations’ Global Compact, a set of Head office from the identification of modern slavery. principles covering human rights, labour, Industrial assets Marketing office/other We produce and market resources that environment and anti-corruption. We play an essential role in modern life. As operate in accordance with local laws a global company, we are conscious of and relevant international frameworks, the leverage we may have to influence including the Core Conventions of the others, and the important role we can International Labour Organization. play in reducing the exploitation of workers through increasing transparency and accountability in our supply chains.

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Structure and operations of As a global producer and marketer of commodities, we are uniquely diversified by geography, our business products and activities. The integration of our marketing and industrial businesses sets us apart continued from most of our competitors in creating an enhanced entrepreneurial focus on value generation.

Inputs and resources on which our busi- ness model depends ASSETS AND NATURAL RESOURCES • Our resources and reserves feature many long-life and high quality assets • We are a disciplined producer, seeking to align supply with demand and value over Our industrial business Our marketing business volume Our industrial business spans the We move commodities • Our established marketing operations metals and energy markets, from where they are plentiful have global reach and deep understand- producing multiple to where they are needed ing of their respective markets commodities from over 65 assets OUR PEOPLE AND PARTNERS • We have established long-term relation- ships with a broad range of suppliers and customers across diverse industries and Exploration, acquisition and development Logistics and delivery geographies • c.135,000 employees and contractors Our focus on brownfield sites and exploration close Our logistics assets and capabilities allow us to handle spread across over 35 countries in both to existing assets lowers our risk profile and lets us large volumes of commodities, both to fulfil our use existing infrastructure, realise synergies and established and emerging regions for obligations and to take advantage of demand and control costs. supply imbalances. These value added services make natural resources us a preferred counterparty for customers without Extraction and production such capabilities. FINANCIAL DISCIPLINE We mine and beneficiate minerals across a range of Blending and optimisation • We seek to deploy capital in a disciplined commodities, mining techniques and countries, for processing or refining at our own facilities, or for sale. manner, seeking to create value for Our ability to blend and optimise allows us to offer all our stakeholders a wide range of product specifications, resulting in an • Our hedging strategies protect us against Processing and refining ability to meet our customer specific requirements price risks and ensure that our marketing and provide a high-quality service. Our expertise and technological advancement in profitability is primarily determined by processing and refining mean we can optimise volume-driven activities and value-added our end products to suit a wider customer base services rather than absolute price and provide security of supply as well as valuable market knowledge. UNIQUE MARKET KNOWLEDGE Our recycling We recycle key Our commodities The products we • As a significantly integrated commodity commodities fuelling produce and market business the circular economy in everyday play an essential role producer and marketer, we are uniquely products in modern life positioned to generate value at every stage of the commodity chain

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Legal Our Our supply Introduction Our business requirements commitment chains

While we mine, process and produce our Industrial assets suppliers by region Our supply own products, we also physically source products from our global supplier base chains – and sell them to customers all over the world. We are one of the world’s leading As a vertically integrated commodity marketers of physical commodities. supplier with a diverse commodity mix, Our network of strategically located our suppliers are critical partners in our assets, including warehouses, ships, commitment to deliver value and to storage, port facilities and commodity operate in a manner that is responsible, processing plants, allows us to efficiently transparent and respects the human and safely transport commodities by rights of all. Our business is supported sea, rail and truck, store and process by varied supply chains which provides them, and deliver to the time, quality and the goods, materials and services we specification that our customers need. need at different stages of our business. Our supply chains include multinational, We mitigate various risks in both our regional, national and local suppliers. industrial and marketing supply chains through our ‘know-your-counterparty’ (KYC) process (a process designed to Glencore’s industrial assets identify corruption, bribery , sanctions, money laundering and reputational engage approximately risks) and supply chain due diligence 34,000 suppliers across the assessments (designed to identify world, with a total spend of various supply chain risks, including Australia, New Caledonia and the Philippines modern slavery risk). There can be a DRC, South Africa, and Zambia around US$13 billion (based correlation between corrupt activity and on 2018 data). Suppliers to human rights abuse/modern slavery and, North America our industrial assets provide as such, our KYC process supports our South America activities to identify modern slavery. a wide range of goods, Europe materials and services including contract workforce, equipment and technology.

2 Viterra publishes a separate Modern Slavery Statement

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Responsible sourcing, or supply Around 80% of our global procurement chains responsibility, is embedded spend is with suppliers and contractors within our supply chain strategy and is local to the countries where we operate. described further on page 14. Glencore is We are committed to purchasing committed to taking into account social, products and services from suppliers that ethical and environmental considerations operate in a manner that is responsible, when managing our relationships with transparent and respects human rights. suppliers and conducting supply chain due diligence to ensure our suppliers Non-controlled joint have approaches in place to address ventures human rights risks in their own supply We have a non-controlling interest in chains. four major mining assets: copper/zinc Our responsible sourcing strategy and coal assets in South America and a considers the production and sourcing coal operation in Australia’s Hunter Valley. 1 of metals and minerals, as well as the In addition, we own 49.9% of Viterra , procurement of goods and services. formerly known as Glencore Agriculture. We work with relevant stakeholders, We have a non-controlling interest in two such as our workforce and suppliers to oil production sharing contracts for Block encourage responsible sourcing. I and Block O in Equatorial Guinea. Both Our Supplier Standards (Standards) set Blocks are operated by Noble Energy, out our expectations for responsible part of the Chevron group. In Cameroon, sourcing and supply due diligence we have a non-controlling interest in an throughout the commodity supply oil production sharing contract for the chains. Our Standards apply to Bolongo field, which is operated individuals, organisations or companies by Perenco. that provide, sell or lease goods, services, When appropriate, we seek to influence or commodities directly to Glencore the independent management teams of companies. More detail on our Standards these joint ventures to adopt equivalent is set out in the Supplier Standards policies and practices on responsible section on pages 14 to 15. sourcing and supply.

1 Viterra publishes a separate Modern Slavery Statement

Glencore Modern Slavery Statement 2020 6 Our approach Addressing risk Additional Information Contact us

Operational Business risks Supply chain risks Effectiveness Consultation Next steps Board approval risks

Addressing risk

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The table below describes key risks we have identified in our operations and supply chains and identifies our mitigation activities at a Identifying and high level. Actions taken to address modern slavery risk are dealt with in additional detail in the next section of the Statement. assessing risks of Potential exposure to Associated modern slavery risk Mitigation activities modern slavery modern slavery Suppliers of goods and In 2018, Glencore developed a global risk assessment framework to assess Supply chain due diligence in our Industrial services to our Industrial human rights risk within its supplier base. The application of this framework assets assets identified our higher-risk countries (the Democratic Republic of Congo (DRC), practices in our Chad, Zimbabwe, the Philippines and Zambia) and higher-risk supply categories See section below (security, transportation, facilities management (unskilled labour), textiles/ business garments/PPE, and construction labour)

Suppliers to our Marketing Artisanal and small-scale mining (ASM) Supply chain due diligence in our Marketing business - purchasing business See section below Our broad portfolio of assets results in Glencore purchases commodities from third parties in countries where ASM is third-party metals, common. ASM represents an important livelihood and income source for many diversity in our geographical locations, minerals and energy poverty-affected populations around the world. As the sector is largely working conditions, organisational cultures products un-mechanised and informal, it often presents significant safety and human and workforces. We recognise we have the Our marketing teams rights risks, including the participation of children and the use of forced labour. potential to impact human rights directly source commodities from Due to the link between child labour and artisanal mining, we conduct assurance through our operations, and indirectly the industrial assets that we to demonstrate to our stakeholders in our value chain that our product does not through our relationships with joint ventures, fully or partly own, as well contain ore sourced from artisanal mining. Our engagement with those involved as from third-party contractors and suppliers. in ASM focuses on how ASM and large-scale mining can sustainably co-exist as suppliers. Our industrial distinct yet complementary sectors of a successful mining industry. assets work with our We strive to maintain a culture of ethical marketing teams, with our Purchasing cobalt behaviour and compliance throughout our traders visiting these sites. Glencore is one of the world’s leading producers and marketer of cobalt, a metal business, which includes our commitment to in rising demand due to its use in batteries for electric vehicles and portable preventing the occurrence of modern slavery electronics. We produce cobalt mainly as a by-product of copper mining in the and human trafficking across our global DRC, as well as from nickel mining in Australia and Canada. In the DRC, ASM is particularly prevalent near our operations where artisanal miners mine cobalt. assets and supply chains. While most of the cobalt we supply to the market is from our own operations, we Risk management is one of the core also source some from a select group of third-party suppliers. Recognising the responsibilities of the Group’s leadership and specific supply chain risks for cobalt, such as ASM, we prioritised rolling-out our enhanced supply chain due diligence process to our cobalt purchasing activities it is central to our decision-making processes. during 2020 and identified no significant adverse human rights impacts. The Group’s leadership fundamental duties as Conflict minerals to risk management are: Conflict minerals are those where their extraction, trading, handling and export • making a robust assessment of emerging takes place in politically unstable areas and are used to finance non-stated and principal risks owned armed groups (including the use of child soldiers), support corruption and money laundering. Conflict minerals are associated with severe human rights • monitoring risk management and internal abuses, including unlawful killing, sexual violence, torture, forced and child controls labour. • promoting a risk aware culture Currently, EU and US legislation identifies tantalum, tin, tungsten and gold, more commonly known as the 3TG, as conflict minerals. In 2020, as in previous years, Glencore did not produce, process or market any conflict minerals originating from the conflict areas.

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Identifying and assessing risks of Potential exposure to Associated modern slavery risk Mitigation activities modern slavery practices in our modern slavery business Geographic location Operations and suppliers in higher-risk jurisdictions Our approach to supplier due diligence seeks continued to achieve a balance between the country We operate over 150 assets To ensure our understanding of the potential risks within the locations of our specific risks and the ability of local suppliers in 35 countries. Some of the assets and supply chains is current, we consider publications by leading to meet our supplier due diligence countries in which we organisations such as the Global Slavery Index (GSI) as guidance. The GSI requirements. Where required, we support operate lack strong prevalence estimate calculates the proportion of people living in modern slavery small/medium-sized suppliers to meet these governance, which may per 1,000 population. requirements. lead to an increased risk of modern slavery in the We use these resources to better understand the risks of modern slavery in the In both the DRC and Chad, we have in place a in-country suppliers used countries where our operations and local suppliers are based. Their assessments ‘know-your-counterparty’ (KYC) procedure for by our assets. show that our operating countries with the highest prevalence of modern slavery service providers and suppliers that seeks to are the DRC and Chad. determine whether they comply with Key operating country GSI prevalence estimate applicable laws. In the DRC, where artisanal mining is Democratic Republic of Congo 13.71 commonplace, we incorporate in our contracts Chad 11.98 stringent clauses for compliance with our Supplier Standards, requiring suppliers to Cameroon 6.87 notify us of any actual or suspected Equatorial Guinea 6.36 non-compliance. Zambia (Glencore exited in March 2020) 5.74 Our Chad asset includes compliance clauses in Kazakhstan 4.21 its contracts with suppliers. We include the South Africa 2.80 expectations set out in Glencore’s Code of Conduct in our manpower agency Columbia 2.73 agreements. Peru 2.56 In Equatorial Guinea and Cameroon, Glencore Italy 2.43 has an interest in, but is not the operator, of oil Spain 2.27 assets. The operators of these assets produce Bolivia 2.13 their own standalone modern slavery statements that detail their approach and United Kingdom 2.08 activities. Germany 2.04 In Kazakhstan, our Kazzinc precious metals Switzerland 1.67 refinery is certified for LBMA Good Delivery Argentina 1.26 Gold bars. Kazzinc complies with Kazak law Chile 0.78 and is externally audited on its adherence to the LBMA Guidance for Responsible Supply Australia 0.65 Chains for Gold. Kazzinc’s Responsible Supply Canada 0.48 Chains Practices Policy for Gold and Silver recognises the risks of mining and processing Further details on the GSI and the methodology it uses to calculate estimates is precious metals from conflict-affected and available at: www.globalslaveryindex.org high-risk areas, as well as potential impacts on human rights such as forced, compulsory and child labour. It undertakes training for its employees and contractors involved in precious metals supply chains, on both the LBMA Guidance and its own Responsible Supply Chains Practices Policy.

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Identifying and assessing risks of Potential exposure to Associated modern slavery risk Mitigation activities modern slavery practices in our modern slavery business Lack of local suppliers and absence of labour regulation In higher-risk operating regions, our continued community and procurement teams work We are committed to local procurement and primarily use local suppliers, to together to identify needs and develop minimise supply chain risk to our operations and support local development, support programmes for local businesses, to whenever commercial, technical and capability considerations are equal to a help them meet our quality standards and our regional or international supplier. Local procurement teams manage a majority expectations with regard to conduct, including of procurement for industrial assets. During 2020, around 80% of our global working practices and procurement procurement spend was with suppliers local to the countries where we operate. procedures. As part of this, we offer targeted However, in some of our operating regions, there is a lack of strong local training on business management skills, businesses that can meet our requirements. In addition, in many countries, underwrite credit applications and guarantee labour regulations may be weak or their enforcement inconsistent, which creates future business within specific limits. We also risk of non-compliance in those local businesses. encourage large international contractors to develop local partnerships to build capacity locally, resulting in employment opportunities and a transfer of skills.

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Identifying and assessing risks of Potential exposure to Associated modern slavery risk Mitigation activities modern slavery practices in our modern slavery business Workforce Poor working conditions and underpayment Workers directly employed by Glencore are, as continued In some countries in which we operate, freedom of association, collective set out in more detail below in the section At the end of 2020, titled ‘Strengthening workforce capacity’, Glencore employed nearly representation, collective bargaining and just compensation may not be enshrined in domestic law or may not be effectively protected by local regulatory protected by our policies and procedures 88,000 employees and over which ensure that they are not subject to 56,000 contractors. bodies. In these countries, employees are more likely to be exposed to unsafe working conditions, lack of job security and underpayment. modern slavery. Due to the transitional nature of contractor agreements, contractors can also The companies providing contractor face higher modern slavery risks. This is particularly the case if they are low-skilled employees to our industrial assets undergo labourers and their work takes them away from home. the same supply chain due diligence processes as our other suppliers. As there are In 2020, contractors in precarious employment faced heightened risks as a result relatively few contractors directly employed in of the COVID-19 pandemic. This limited some workers’ ability to travel home from our marketing offices, we do not consider their workplace, and may have increased pressure on these workers to work in modern slavery to be a material risk in this more demanding conditions. Contractors often enter the extractive industry area. We have addressed modern slavery risks through apparently legitimate routes, yet a lack of transparency can lead to poor in our warehouses and transportation working conditions and pay. activities in the ‘Transportation and distribution’ section. Transportation and distribution Our Access World warehouse business is wholly Our products move through the hands of many service providers, such as owned and operated by Glencore. Here, our warehouses, land freight and shipping lines. Freight, particularly seaborne Group policies are in place. Our ongoing freight, has been identified in a number of governmental and NGO reports as a management of these facilities includes sector with a higher risk of modern slavery as it employs lower-paid workers from frequent visits. developing countries, involves long periods at sea with little regulatory oversight, For non-operated warehouses, we initially and often subjects crew to difficult working conditions. This risk has been undertake inspections and require the provision heightened during the COVID-19 pandemic where some workers on vessels have of information by the warehouse owner/operator. been unable to leave their ships due to various ports not permitting The transportation of our goods tends to be disembarkation. subcontracted to service providers. Our on-boarding process for these companies includes sharing relevant Glencore policies, such as the Supplier Standards and Group Human Rights Policy to support the suppliers’ compliance with our requirements. For our own and joint-venture owned fleet, which is chartered to Glencore, we have a direct relationship with the ship-manager and proactively engage on crew welfare and timely relief. During the last year, due to Covid-19 lockdowns, where needed, vessels diverted to a convenient port to facilitate crew change overs. While we do not employ crew directly on our time-chartered vessels, as a part of our supply chain due diligence, we ensure that the all vessels and ship managers are fully compliant with ILO Maritime Labour Convention, 2006. In addition, we check the crew’s tenure/time on board at the time of the fixture. If an owner of our chartered vessel requests assistance from us, we provide support where practicable and feasible.

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Identifying and assessing risks of Potential exposure to Associated modern slavery risk Mitigation activities modern slavery practices in our modern slavery business Non-controlled joint ventures Independent management teams operate our continued As set out on page 6, Glencore has non-controlling interests in a number oof material non-controlled JVs. Along with our JV material assets. partners, we participate in board shareholder committees that take key strategic decisions. When we do not directly operate an asset, there is a risk of working practices or We use this participation to seek to influence procurement procedures not meeting our expectations. the independent management teams to adopt appropriate operational and governance standards, including those relating to modern slavery, which reflect those of Glencore and the other JV partners. As Glencore provides procurement services to the Hunter Valley Operations (HVO) coal joint venture in Australia under a services agreement, we implement Glencore procurement procedures at that asset. While human rights policies and training for HVO employees are HVO specific, they are consistent with the equivalent policies and training adopted across the Glencore Australian coal assets.

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Addressing risks of modern slavery in our business

The diversity of our geographic locations and production processes, as well as our presence at many stages of the commodity value chain means we take a robust approach to supply chain due diligence as part of our commitment to zero tolerance for modern slavery in our workplaces and supply chains.

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Addressing risks of modern slavery in Corruption Policy, Sanctions Policy and our business Supplier Standards, mandates the use continued of clauses for certain topics in contracts between our marketing offices and their counterparties. These clauses set Code of Conduct (Group) Human Rights Policy (Group) Anti-Corruption Policy (Group) Addressing risks of modern slavery in out our expectations of our suppliers our supply chains to comply with all applicable laws, Given the global span, length and rules and regulations. In addition, our Supplier Standards (Group) complexity of our supply chains, we Supplier Standards are incorporated by Policies/Standards recognise that there is the potential for reference in prospective contracts with modern slavery risks to exist in our supply our minerals and metals suppliers, which chains. To manage and mitigate these is also a requirement of the Organization Supplier Due Diligence risks, we work with relevant stakeholders, of Economic Cooperation and

Procedure/tool Existing New/Revised such as our workforce, suppliers, Development’s Due Diligence Guidance contracting companies and business (OECD DDG) for Responsible Sourcing partners, to encourage responsible of minerals from Conflict and High Risk sourcing. Areas (CAHRAs). The Supplier Standards have been created to detail the Supplier Standards We are at times unable to compel requirements and expecations we place on our suppliers We set out our expectations for ethical suppliers to accept our Supplier business practices, safety and health, Standards. In these instances, we agree • The Standards give effect to our Human Rights and Anti-Corruption Policies to ensure our human rights and environment in our with these suppliers that both parties suppliers resepect internationally acknowledged human rights Supplier Standards, which apply to the will agree to comply with an equivalent • The Supplier Standards are to be embedded into contracts, agreements and existing suppliers of goods and services across Code of Conduct or policies. Glencore procedures/protocols. our global business. reviews the supplier’s Code of Conduct The Supplier Standards form the base and/or policies to ensure they materially of our robust risk-based programme, align with the expectations set out by which reflects the values embedded in Glencore’s Supplier Standards. our Code of Conduct and sets out our expectations of suppliers in relation to ethical, safety, environmental, bribery and corruption and human rights risks in our supply chains. Our Group Contracting Standard Standard for our marketing business, which aligns with the expectations set out in our Code of Conduct, Anti-

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Addressing risks of modern slavery in Our approach to supplier due diligence • Where the self-assessment identifies We insert different contract terms our business seeks to achieve a balance between issues or unacceptable levels of risk, relating to our Supplier Standards continued the country specific risks and the ability agreeing with the affected supplier, into our supply contracts depending of local suppliers to meet our detailed prior to contracting, appropriate on whether the counterparty and/ supplier due diligence requirements. corrective actions and risk mitigation or country of supply are considered In relation to Modern Slavery, our Supplier measures; The Australian industrial assets adopted low, medium or high risk. For high-risk Standards require that our suppliers: a broader approach that requires all • Where required, conducting further counterparties or countries of supply, • Offer fair remuneration to their new suppliers, regardless of the product due diligence, including the use of we require the supplier to demonstrate employees; and/or service category they supply, to third party verification. We expect that they (including their subsidiaries suppliers to cooperate in the additional and subcontractors) have not breached • Respect the rights of their workforce to undertake supply chain due diligence due diligence and assessment of our supplier standards within the two freedom of association and collective as part of its contracting process. This potential or adverse impacts and years prior to contracting with us. We bargaining; broader approach was based on the view that Australian suppliers in general, provide access to relevant information; also require the supplier to (i) report to us • Provide a safe and healthy working had a greater capacity to satisfy the and any non-compliance with our Supplier environment; Standards and (ii) give us the right to supplier due diligence requirements. • Monitoring progress and tracking monitor and audit this compliance. Most • Respect human rights and the UN This approach has also been adopted by implementation of performance KPIs. of our African operations have adopted Guiding Principles, including by our South African ferroalloys business, When appropriate, we support our the highest-risk contract terms as implementing appropriate policies and where all new suppliers undergo supply suppliers in capacity building and standard. processes; chain due diligence as part of any tender improving their adherence to the response, and existing suppliers in the • Abide by the ILO Core Labour expectations of our Supplier Standards. Our South Africa-based ferroalloys five higher risk categories also undergo Standards. business incorporates a supplier standard the supply chain due diligence process. due diligence questionnaire into its Our regional procurement teams We identify the risk associated with our sourcing and tender enquiry templates, Supply chain due diligence for our reference, and require compliance as well as in its standard contracts. Industrial assets suppliers by: to, our Supplier Standards in their This allow it to receive responses from In developing our supplier risk • Conducting a risk assessment during written supply contracts. We expect existing and potential vendors, which are assessment framework, we prioritised pre-qualification, the tendering our suppliers to review and comply considered during the tender evaluation supply chain due diligence in five process, or at the renewal of an existing with these Supplier Standards. Where process and supports the screening of categories that we identified as posing contract term; appropriate, we support our suppliers suppliers’ compliance with Glencore’s a higher risk to human rights: (i) security to comply with the Supplier Standards • Using the results of the risk Supplier Standards. In the event of a services, (ii) transportation, (iii) facilities through communication and training, assessment to determine whether response raising a red flag, a further management, (iv) textile/garments/ particularly around health and safety at a supplier needs to complete a self- investigation and, where appropriate, PPE and (v) construction labour. Initially, the workplace. assessment against the Supplier a vendor audit is conducted prior supplier due diligence was focused on Standards; to contracting. The ferroalloys team these categories. investigated a number of systems for developing a database of responses,

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Addressing risks of modern slavery in Our in-country security team provides Supply chain due diligence in our Marketing supply chain risk. An important part of our business training on the Voluntary Principles business our due diligence process is to identify continued for Security and Human Rights to the The approach to supply chain due whether our third party suppliers of public security forces, who are under diligence for our metals, minerals and metals and minerals are located in, control of local government. energy products suppliers within our sourcing from or transporting minerals documents and required actions. It global business aligns with the OECD through CAHRAs and, if so, have the is in the process of implementing a DDG for Responsible Supply Chains of potential to be associated with these procurement platform, which it will use Our Australian industrial assets generally Minerals from CAHRAs. human rights abuses. Where we identify adopt a medium-risk approach to to manage this process. The OECD DDG applies to tin, tantalum, a potential ‘red-flag’ supplier, they Supplier Standards in contract terms, tungsten and gold, also referred to as undergo further risk assessments. In Chad, our contractors and suppliers are with each potential new supplier asked ‘conflict minerals’. Today it is largely subject to standard terms and conditions to demonstrate the processes and Glencore’s CAHRA list reflects considered as the most authoritative and Glencore’s KYC procedure. The Chad policies they have in place to prevent inputs taken from findings made by guidance document for applying due asset has also put in place the following modern slavery. Here, Glencore’s Code governments, international organisations, diligence for these minerals’ supply measures to mitigate modern slavery of Conduct and relevant Group policies including the United Nations and its chains. risks: are referenced in supplier contracts and Security Council sanctions, think-tanks, NGOs, industry literature relating to • Contractors: local contractors’ pay compliance with their expectations is a Other metals are covered by other mineral extraction, media, as well as is equivalent to the salaries paid to requirement. standards and frameworks, for example, internationally recognised indices on direct employees and there are similar the RMI for cobalt, LBMA for silver and conflict, democracy and rule of law, and benefits, such as medical, transport, gold and the Joint Base Metals Due human rights. We tested the validity housing and phone and meal Diligence Standard for copper, nickel, of our CAHRA determination with allowances. The Labour Direction and zinc, lead. recognised industry consultants and National Employment Office (ONAPE) CAHRAs are typically regions or countries considered the indicative and non- approve all local manpower contracts. with socio-economic and political crises, exhaustive CAHRA list produced by the • Security Services: our in-country institutional weakness and weak rule European Union. security manager works with our of law, widespread violence including private security provider to emphasise armed conflicts. Such countries are the importance of their compliance susceptible to widespread human with the International Code of Conduct rights abuses - torture, cruel, inhuman for Private Security Service Providers. and degrading treatment, child, forced The Code includes a specific reference or compulsory labour and sexual to the “Prohibition of Slavery and violence. These human rights abuses Forced Labour. Signatory companies are encompassed by the term modern will not use slavery, forced or slavery and, together with war crimes or compulsory labour, or be complicit in other serious violations of international any other entity’s use of such labour.” humanitarian law, represent a significant

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Addressing risks of modern slavery in our business continued

By applying the OECD’s five-step due One of our largest challenges is that for a diligence approach to our due diligence company of our size, robust due diligence Implementing the OECD five-step approach to for our minerals and metals supply requires significant resources and time, due diligence chains, we rely on a comprehensive not only for our due diligence team, but and robust methodology to identify, also for our suppliers. While due diligence Due diligence: an on-going, proactive and reactive assess and manage supply chain is a well-established process for ‘conflict risks. In conducting our due diligence minerals’, it is less established for base process to identiy and address actual or potential risks process, we work collaboratively with our metals. If one supply chain participant is in order to prevent or mitigate adverse human rights suppliers. To date, reflecting our risk- less responsive, this has an impact on the impacts in our supply chain based approach, we have implemented overall due diligence efforts, which can our due diligence approach to our supply affect transparency and undermine the chains for cobalt, nickel, zinc and copper, potential to identify and address human Step 1 Establish strong company management sysstems and are in the process of rolling it out to rights issues in the entire supply chain. our remaining commodities. We believe that a key success factor is to establish an agreed due diligence We seek to confirm that our metals and standard by all supply chain participants. Step 2 Identify and assess risk in supply chain minerals suppliers operate in accordance As such, we welcome the London Metal with our Supplier Standards, including Exchange’s (LME) recently introduced that they are not knowingly tolerating, responsible sourcing requirements Step 3 Design and implement a strategy to respond to identified risk contributing to or profiting from any of and see these as a catalyst to drive the OECD DDG ANNEX II risks, which responsible sourcing efforts in the supply includes modern slavery. If a high level chains of the metals that we market as Step 4 Carry out independet audits of risk is identified, we work with the LME listed brands. supplier to determine appropriate corrective action until both parties agree Step 5 Report annually on supply chain due diligence the desired outcome has been achieved.

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Addressing risks of modern slavery in our business continued

Piloting the RMI’s audit assessment at Murrin Murrin, We have published both programme which found that the due Murrin Murrin’s Responsible diligence management Minerals Assurance Process system conforms, in all In 2019 and 2020, we worked (RMAP) due diligence material aspects, to the with the Responsible report and KCC’s RMAP requirements of the RMAP Minerals Initiative (RMI) to due diligence report on our cobalt standard. pilot its Responsible Minerals website. Assurance Process (RMAP) In February 2021, our KCC The successful RMI for cobalt at our Murrin asset in the DRC undertook assessment of Murrin Murrin Murrin asset in Australia. The an assessment, as part of complements our refiners, RMAP uses independent RMI’s pilot audit programme who are on the LBMA Good third-party assessments for crude cobalt refiners. The Delivery List. In 2020, as in of smelter and refinery audit considered the flow of previous years, our refiners management systems material and controls (metals maintained their successful and sourcing practices to accounting); ensuring no LBMA responsible gold and validate conformance with its external material enter KCC’s silver metal accreditations. cobalt standard. The RMAP processes; and security and standards are developed to human rights, including meet the requirements of the KCC’s approach to artisanal OECD DDG, the Regulation and small-scale mining, (EU) 2017/821 of the European labour related human rights Parliament and the US Dodd- (such as modern slavery) and Frank Wall Street Reform and health and safety. KCC was Consumer Protection Act. confirmed as conformant with all the requirements of In 2020, RMI announced the standard in April 2021. the conclusions of the pilot

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Addressing modern slavery risk in our operations - strengthening workforce capacity

We uphold the International Labour Organization Declaration on Fundamental Principles and Rights at Work.

We recognise and uphold the rights of our workforce to a safe workplace, freedom of association, collective representation, collective bargaining, job security and development opportunities. These rights are set out in our Group Human Rights Policy, which applies to all employees, directors and officers, as well as contractors under Glencore’s day-to- day operational direction, working at a Glencore marketing office or industrial asset. To prevent modern slavery in our workplaces we ensure our workers are paid in accordance with legal requirements, have contracts of employment and have the ability to leave their employment at any time, subject to notice periods. We also provide our employees and contractors with regular training and access to a formal complaints process. In addition, we work hard to maintain robust relationships with local union representatives.

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Addressing modern slavery risk in our Employees and relevant contractors The key Group policies relating to human executive summaries generated by operations - strengthening workforce at our office and industrial assets are rights, including modern slavery, are the our assurance of the technical and capacity expected to apply Glencore’s Group following: management standards that support the continued policy framework while also focusing Group policy commitments. • Code of Conduct on local challenges and opportunities Our HSEC assurance processes (which Governance through tailored approaches and • Human Rights Policy include an assessment of modern slavery In 2020, we embarked on a action plans. Integrated management • Anti-Corruption Policy risks) support Glencore’s management’s comprehensive review of our entire is critical for this approach. We track • Equality of Opportunity Policy assessment of risk and provides Group policy framework. This was a our progress on implementing our assurance on key mitigation controls. It collaborative, cross-functional project policy framework through our internal • Diversity and Inclusion Policy has three elements: to develop and implement a more assurance processes. In addition, we • Community and Stakeholder streamlined and consistent approach to consider the complaints raised through Engagement Policy 1. General risk management: policy governance at Glencore. both our Raising Concerns platform (see throughout the Group, we use our • Health and Safety Policy below) and our grievance mechanisms risk management framework to In addition to re-evaluating our policy utilised by stakeholders living close to our • Environmental Policy identify hazards, particularly those framework, we reviewed and refreshed operations. with potentially major or catastrophic all of our Group policies. The aim was • Supplier Standards consequences, and to develop to ensure Glencore’s commitments, Our workforce can access our policy management plans for the related approaches and requirements are framework through various channels, In particular, our Group Human Rights risks. accessible to employees and relevant including the Group and local intranets. Policy sets out our commitment to contractors in a simple, clear and concise Our Group policies are available in 12 2. Self-assessments: our assets complete respect the dignity and human rights of fashion. Employees must be able to easily languages. annual self-assessments against Group our workforce and our business partners, understand the behaviours expected sustainability policies, standards and Our managers and supervisors are the societies in which we live and work, of them. External stakeholders must fatal hazard protocols. We use the responsible for ensuring employees and all others who may be affected by also have access to our policies to stay results to drive performance and to understand and comply with the policies, our activities. We expect our business informed of Glencore’s approaches and identify gaps. As part of our annual standards and procedures. As part of partners to share our commitment and commitments on matters of critical sustainability data audit, our external our group-wide roll out of our new policy we leverage our business relationship to importance to them. auditor checks the work at a number framework, we will conduct targeted advance human rights, as well as utilising of assets for data accuracy and policy The Group policy framework, and training sessions for our managers and our Supplier Standards and supply chain compliance. supporting policies, standards, workforce. due diligence process to encourage their procedures, guidelines and operational alignment with our expectations. 3. HSEC-HR auditing: our HSEC We require each of our assets to processes embed our commitment Assurance Policy specifies HSEC-HR undertake an annual self-assessment on The Glencore Board, through its Health, across our business to respect human auditing activities at both Group and their implementation of our Group HSEC- Safety, Environment and Communities rights and align with the Guiding departmental levels with a focus on HR expectations. These self-assessments (HSEC) Committee oversees our human Principles and with the Sustainable catastrophic hazards. are reviewed by both the corporate rights activities which are embedded Development Framework of the ICMM. HSEC-HR team and the internal audit across the business. It reviews the function.

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Addressing modern slavery risk in our access to a work computer is not engage with unions active at their sites in prevent further misconduct and limit operations - strengthening workforce available, employees and contractors different ways and at different levels. We potential financial, reputational and other capacity receive training in other ways, including do not interfere with the rights of unions impacts. Our Whistleblowing Policy sets continued induction sessions, pre-shift training and and prohibit any form of intimidation out Glencore’s approach to protecting toolbox talks. or retaliation against workers seeking whistle-blowers with the aim of We respect our workforce’s right to to exercise their rights to freedom of encouraging and supporting individuals In addition to online and face-to-face freedom of association and the right association, collective representation to report concerns. It also provides detail training, awareness-raising activities to collective bargaining and we foster and/or collective bargaining. on the process for reporting, escalating, and initiatives are key to reminding transparent and collaborative labour handling and/or investigating and employees of the importance of ethics Our assets ensure that working hours relations. We promote fair recruitment remedying concerns. and compliance. While in-person are not excessive by monitoring rosters, and employment practices so that all activities and initiatives have been heavily shifts and other recording procedures, Glencore is committed to: work is voluntary and fairly compensated impacted by Covid-19, we have continued in compliance with local legislation (as provided in the Group Human Rights • Protecting whistleblowers and other to develop awareness materials in the and agreements with unions or works policy). individuals from retaliation; form of electronic guides, checklists, councils. Training newsletters, videos and intranet • Protecting the identity of Our assets hold regular meetings with We conduct training with our employees communications. whistleblowers and respecting union representatives to provide updates and relevant contractors to ensure they their confidentiality; Participants from our marketing on safety, production and costs and understand the behaviour expected teams receive training to support their discuss upcoming business challenges, • Giving whistleblowers the opportunity of them and provide guidance on understanding of due diligence in opportunities, and risks to longer-term to report anonymously; and the elements of the Group’s policy minerals supply chains, the adverse viability. • Taking protected concerns seriously framework. Our training programmes human rights impact associated and handling and/or investigating mix e-learning with face-to-face Making a complaint with sourcing, handling, processing, protected concerns in a diligent and training. We tailor our training and We have clear, formal processes for our transporting of minerals through efficient manner. awareness materials and make them people to report labour grievances. CAHRAs, the elements of the OECD’s relevant by including hypothetical five-step approach due diligence, as Raising Concerns programme scenarios illustrating how human rights well as their roles and responsibilities Glencore is committed to creating a We encourage whistleblowers to first dilemmas might manifest themselves for implementation for a robust due culture where our workforce and other raise concerns with relevant managers in employees’ daily work. Our annual diligence. stakeholders, such as customers and or supervisors as they are usually best training on the Code of Conduct for suppliers, feel comfortable reporting equipped to resolve concerns quickly employees includes a specific module on Industrial relations concerns without fear of retaliation. and effectively. Reporters also have the human rights applicable to our suppliers We are committed to working honestly We are also committed to ensuring option of reaching out to nominated and contractors. and openly with labour unions at all our concerns are treated seriously and whistleblowing contacts, who are locations and treating employees with New joiners receive compliance training handled and/or investigated in a manner members of senior management at the respect. As unions play different roles at sessions on our Values, Code of Conduct, that protects a whistleblower’s identity. office or industrial asset. our assets depending on geographical Identification of concerns allows us and key compliance risks including If a concern remains unresolved or a region and industrial sector, our assets to take appropriate action that could how to raise concerns. Where regular whistleblower is uncomfortable using

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Addressing modern slavery risk in our Complaints and grievances on human In 2020, we received 1,272 community operations - strengthening workforce rights impacts complaints (2019: 1,149 complaints). The capacity We consider access to remedies to be majority, 34%, related to damage caused continued a core aspect of our management of by flood water runoff from the Badila and human rights. We operate grievance Mangara operations in Chad, which were local channels, concerns can also be mechanisms at all our assets for our addressed by the asset’s stakeholder reported via our Raising Concerns stakeholders that are legitimate, relations team. Other complaints from Programme. This is our corporate accessible, predictable, equitable, around the Group related to odour/fumes whistleblowing programme and is transparent and rights-compatible and and noise, which accounted for 17% and managed centrally at our Head Office in in line with the United Nations’ Guiding 14% of our total complaints, respectively. Switzerland. Principles’ effectiveness criteria. Our Group Human Rights Policy requires We encourage our suppliers to ensure Raising Concerns allows whistleblowers assets that cause or contribute to their workforce and associated to raise concerns anonymously in any an adverse human rights impact to communities have access to grievance of 21 languages, by internet or phone. provide or participate in effective mechanisms to raise concerns Hotlines are available in most of the remediation. Our approach aligns with confidentially without fear of retaliation. countries where we operate, and details our commitment to the UN Guiding We did not receive any modern slavery are published on the platform’s website principles. complaints during the reporting period and on posters at offices and industrial through our operational grievance assets. All concerns are taken seriously These mechanisms provide an accessible mechanisms. and handled promptly and objectively. channel for directly affected stakeholders We investigate all reports made in good to communicate their human rights faith. concerns without fear of reprisals. These platforms enable our assets to identify, During 2020, our Raising Concerns acknowledge and address genuine platform received 413 reports of concerns operational-related grievances and (2019: 500), with the following breakdown: complaints in a timely and effective • Business Integrity – 143 (35%); manner. We commit to investigating all concerns in a manner that respects the • Human rights – 190 (46%); rights of the complainant. We require • HSEC-HR – 57 (14%); and our local management teams to review • Others – 23 (5%). the complaints and grievances received, as well as to consider their trends over time. We encourage our assets to None of the human rights Raising conduct regular community perception Concerns reports were related to modern surveys, which include questions on their slavery. grievance mechanisms.

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Effectiveness

Glencore is committed to continuously assessing its modern slavery risks and improving its framework for addressing them.

We track our progress on supply chain due diligence. During 2020, our industrial assets screened 7,599 new suppliers following a risk-based approach (2019: 10,432), of which 3,993 suppliers were screened on social criteria which incorporates modern slavery considerations (2019: 5,680).

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Effectiveness appropriate policies and procedures to this company due to the proliferation of Implementing our human rights risk continued be in place and the need to notify of any labour supply companies in the market assessment tool breaches of the agreement. place. In 2020, we developed an innovative human rights rating tool to enable In 2019, we implemented our new supply Tracking complaints and grievances consistent assessment of the human chain due diligence approach in Australia Our corporate team reviews the type and Effectiveness of our ‘know-your- rights risk level of each asset across and New Caledonia. Since then, our frequency of complaints made via our counterparty’ (KYC) screening the Group. We developed the tool in procurement teams have completed asset operated grievance mechanisms In 2019, our African copper assets in the consultation with internal and external 3,315 KYC and supply chain due diligence and our corporate-led Raising Concerns DRC and Zambia adopted a new vendor human rights experts who helped assessments, with 85% undertaken in platform. When appropriate, further management procedure which covers identify country and local risk indicators Australia. action is taken to address reoccurring, both the KYC process for industrial for each of the Group’s salient risks high frequency or serious complaints. assets, and the Supplier Standards as well The assessment process approved just (labour rights, safety, health, security, as the Group’s supply chain due diligence over 2,000 applications and rejected In 2020, we undertook a review of the inequality and water). The tool comprises approach. To date, we have completed three suppliers. Of the three suppliers local grievance mechanisms against 20 indicators from credible, international around 470 new KYC and supplier due rejected, we found all to be conducting the United Nations Guiding Principles’ sources and 29 internal indicators from diligence assessments for these assets. poor business practices such as theft. (UNGP) criteria. We identified areas for across our assets. For around 500 applications no further improvement, including the need for We work with our suppliers to improve An asset’s risk rating will determine the assessment was required. The remaining more robust mechanisms to measure their practices where they do not minimum actions required to manage 800 applications require further review to the effectiveness of the process and meet our standards. For example, the human rights risks. We are rolling out the ensure the process is complete. the need to include feedback from Norwegian Government Pension Fund tool out during 2021 and will report on potentially-affected stakeholders. Over Global recommended divesting from a Our pre-tender supplier assessment its findings both internally to the HSEC the next year, our assets will strengthen global company contracted to one of our found an Australian-based labour supply Board Committee and externally in our the design of their complaints and sites in a country we have identified as company that paid workers a wage annual Sustainability Report. grievance processes. having a potentially high risk of modern based on the group rather than individual External engagement slavery, due to “an unacceptable risk productivity, contrary to Australian work We followed this assessment with During the year, we continued to that the company is contributing to place law. The company was subject learning webinars in early 2021 focused engage with our internal and external systematic human rights violations” to an enforceable undertaking from on challenges and good practices in stakeholders to drive the development against workers in Qatar and the UAE. the Australian government’s Fair Work complaints and grievance process of and alignment with practical, We engaged with the company to Australia agency to pay workers based implementation. Participants included performance-driven responsible sourcing understand the actions they had taken on their individual productivity. While representatives from our compliance, initiatives, standards and frameworks. to address the allegations and the our assessment process identified this legal and community teams. The policies and procedures they had put in issue and our subsequent review found webinars were run in our key operating place to mitigate future risks. We also that the company had addressed the regions and held in various languages. amended our contract to strengthen the issue, we ultimately chose not to use clauses relating to our supplier standards expectations, the requirements for

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Effectiveness continued Working with the Fair Cobalt Alliance

Working with the Cobalt Institute During the year, we engaged on our During the year, we reviewed is intended to reflect the responsible We work closely with the Cobalt approach for responsible production our overall approach to ASM in ASM expectations of both global supply Institute, chairing the Sustainability and and sourcing, as well as its challenges recognition of the important and chain actors and DRC stakeholders. The Responsible Sourcing Working Group. and opportunities, at several multi- sustainable role that responsible Framework is progressive, designed We are continuing to work with the stakeholder forums. These included and transparent ASM could have to be accessible to ASM operators and Cobalt Institute on its Cobalt Industry participating in the RMI’s annual in supply chains. We became a to foster improvements over time. Responsible Assessment Framework conference as a panellist to discuss member of the Fair Cobalt Alliance Protecting human rights, ending (CIRAF). This framework strengthens progressive improvements of refiners in (FCA), collaborating with other supply dangerous working conditions and the ability of cobalt producers and cobalt supply chains. chain companies and non-industry raising productivity are key aspects of buyers to assess, mitigate and report on Throughout the year, we continued to stakeholders. The FCA’s mission is the Framework, supported by basic, responsible production and sourcing participate in the ICMM’s Responsible to transform ASM in the DRC in a progressive and advanced criteria. risks in their operations and supply Sourcing Working Group. This is an positive manner through eliminating To this end, the Framework includes chains. The CIRAF also enables a more opportunity to engage with peers and to child and forced labour, supporting measures on child labour, forced coherent and consistent approach to identify opportunities for a coordinated the professionalisation of ASM labour, remuneration, working hours, cobalt due diligence and reporting by the approach in demonstrating responsible through the adoption of responsible discrimination, and access to personal cobalt industry. supply chains. mining practices, and identifying and protection equipment. Engaging with our peers supporting alternative livelihoods to FCA is developing the Framework in We have strong relationships with help increase incomes and reduce collaboration with the Responsible a number of industry organisations, poverty. including the International Copper Cobalt Initiative and the Global Battery One of the FCA’s foundational Association, RMI, LME, Eurometaux, Alliance’s Cobalt Action Partnership projects is the development of a ICMM and various industry associations (CAP). During 2021, the CAP is carrying globally accepted ‘ASM Framework’. of which we are members. Our out a substantial public consultation The Framework, aligns with existing participation in these organisations process in the DRC and with relevant standards in the DRC and allow us to engage with our peers and international stakeholders. downstream users of our products, as well as providing an opportunity to contribute to the development of industry standards.

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Consultation

In preparing this statement, we consulted widely with stakeholders across our procurement, legal, compliance and operations teams in a number of regions.

Our Board Health Safety, Environment and Communities (HSEC) Committee, which includes our Chief Executive Officer and Chairman as members, sets the strategic direction for our global sustainability activities, including our approach towards human rights and modern slavery, and oversees the development and implementation of our strategic health safety, environment and communities and human rights (HSEC-HR) programmes. The HSEC Committee regularly evaluates the effectiveness of our systems for identifying and managing HSEC-HR related risks, and considers overall performance. The HSEC Committee receives regular updates on the performance of our global assets in the area of human rights (which includes modern slavery concerns), including being made aware of complaints. As part of our supply chain due diligence process, our regional teams include modern slavery in their discussions on broader human rights issues through various mechanisms including regular compliance updates.

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Next steps

We will continue to work with both our internal and external stakeholders to address the risks associated with modern slavery within our business. Going forward we will:

• Supply chain due diligence: reflecting our risk-based • Internal awareness and training: we conduct training approach, we have implemented our due diligence with our employees and relevant contractors to approach to our metals and minerals supply chains ensure they understand the behaviour expected of for cobalt, nickel, zinc and copper, as well as in our them and provide guidance on the elements of our coal business. We will roll it out to our remaining policy framework. In 2021, we will look to strengthen commodities over the coming year; understanding of modern slavery through providing • Grievance mechanisms: we are committed to creating training for both our industrial and marketing teams; a culture where everyone feels free to speak about and concerns in a secure and confidential way. In 2021, we • Regulatory developments: we track regulatory will build on the findings of assessment of our local developments, working to harmonise our approach complaints and grievance processes against the UNGP to regulatory compliance and to incorporate modern effectiveness criteria. These included the need for more slavery into our broader responsible sourcing robust mechanisms to measure the effectiveness of the programme. Where these have the potential to affect process, including feedback from potentially affected our business we look for opportunities to engage in stakeholders; consultation processes. Once finalised, we map our existing approach to the new regulation and address any identified gaps. During 2021, a key focus will be implementing the recently published LME responsible sourcing requirements.

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Board approval

This Statement has been approved by the Board of Glencore plc and is signed on its behalf by Tony Hayward, Chairman of the Board, on behalf of all Glencore Group reporting entities under the UK and Australian Acts.

Tony Hayward Chairman 29 June 2021

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Australian entities Important notice

Additional Information

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Australian entities Important notice

Australian Company Commodity Company Commodity Company Commodity entities Noranda Pacific No. 2 Pty Limited Zinc Anotero Pty Limited Coal Saxonvale Coal Pty Limited Coal The Australian entities Noranda Pacific Pty Limited Zinc HVO Coal Sales Pty Ltd Coal Enex Oakbridge Pty Limited Coal covered by this report, as Cadelan Pty Limited Copper HV Coking Coal Pty Limited Coal Glencore Coal (NSW) Pty Limited Coal required under the Australian Acelight Pty Limited Copper Mt Owen Pty Limited Coal Glencore Coal Sales (NSW) Pty Coal Modern Slavery Act Limited

Glideco Pty Limited Copper NC Coal Company Pty Limited Coal Hail Creek Coal Holdings Pty Coal Limited

Isokind Pty Limited Copper Oaky Creek Holdings Pty Limited Coal

Minara Resources Pty Ltd Nickel Nicias Investments Pty Ltd Coal Company Commodity

Glencore Holdings Pty Limited - Glenmurrin Pty Limited Nickel GS Coal Holdings Pty Ltd Coal

Glencore Investment Pty Limited - Glencore Australia Oil Pty Limited Oil GS Coal Pty Ltd Coal

Glencore Queensland Limited - Rolleston Coal Holdings Pty Coal AZSA Holdings Pty Limited Coal Limited

Helios Hawk Pty Ltd - Helios Australia Pty Limited Coal Glencore Coal Holdings Pty Coal Limited

Midas Hawk Pty Ltd - Cumnock Coal Pty Limited Coal Glencore Coal Investments Coal Australia Pty Limited

Glencore Operations Australia Pty - Cumnock No. 1 Colliery Pty Coal Glencore Coal Pty Limited Coal Limited Limited

Copper Refineries Pty Ltd Copper Mangoola Coal Operations Pty Coal Jonsha Pty Limted Coal Limited

Ernest Henry Mining Pty Ltd Copper Enex Foydell Pty Limited Coal Enex Ulan Pty Limited Coal

Mount Isa Mines Limited Copper/ Enex Liddell Pty Limited Coal Oakbridge Pty Limited Coal Zinc

McArthur River Mining Pty Ltd Zinc Gabume Pty Limited Coal The Newcastle Wallsend Coal Co Coal Pty Ltd

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Australian entities Important notice

By their nature, forward-looking cautioned not to place undue reliance are used for ease of reference only and IMPORTANT statements involve known and unknown on these forward-looking statements do not imply any other relationship risks and uncertainties, many of which which only speak as of the date of this between the companies. Likewise, the NOTICE are beyond Glencore’s control. Forward document. words “we”, “us” and “our” are also used looking statements are not guarantees of to refer collectively to members of the Except as required by applicable CONCERNING future performance and may and often Group or to those who work for them. regulations or by law, Glencore is not do differ materially from actual results. These expressions are also used where under any obligation and Glencore THIS REPORT Important factors that could cause no useful purpose is served by identifying and its affiliates expressly disclaim any INCLUDING FORWARD these uncertainties include, but are not the particular company or companies. intention, obligation or undertaking, to limited to, those disclosed in the Risk LOOKING STATEMENTS update or revise any forward looking The companies in which Glencore plc Management section of this report. statements, whether as a result of new directly and indirectly has an interest are This document contains statements For example, our future revenues from information, future events or otherwise. separate and distinct legal entities. In that are, or may be deemed to be, our assets, projects or mines will be This document shall not, under any this document, Glencore, Glencore group “forward looking statements” which are based, in part, on the market price of the circumstances, create any implication and Group are used for convenience only prospective in nature. These forward commodity products produced, which that there has been no change in the where references are made to Glencore looking statements may be identified by may vary significantly from current levels. business or affairs of Glencore since plc and its subsidiaries in general. These the use of forward looking terminology, These may materially affect the timing the date of this document or that the collective expressions are used for ease or the negative thereof such as “outlook”, and feasibility of particular developments. information contained herein is correct as of reference only and do not imply “plans”, “expects” or “does not expect”, Other factors include (without limitation) at any time subsequent to its date. any other relationship between the “is expected”, “continues”, “assumes”, the ability to produce and transport companies. Likewise, the words we, us “is subject to”, “budget”, “scheduled”, No statement in this document is products profitably, demand for our and our are also used to refer collectively “estimates”, “aims”, “forecasts”, “risks”, intended as a profit forecast or a products, changes to the assumptions to members of the Group or to those who “intends”, “positioned”, “predicts”, profit estimate and past performance regarding the recoverable value of our work for them. These expressions are also “anticipates” or “does not anticipate”, or cannot be relied on as a guide to tangible and intangible assets, the effect used where no useful purpose is served “believes”, or variations of such words or future performance. This document of foreign currency exchange rates on by identifying the particular company or comparable terminology and phrases does not constitute or form part of any market prices and operating costs, and companies. or statements that certain actions, offer or invitation to sell or issue, or any actions by governmental authorities, events or results “may”, “could”, “should”, solicitation of any offer to purchase or such as changes in taxation or regulation, “shall”, “would”, “might” or “will” be taken, subscribe for any securities. and political uncertainty. occur or be achieved. Forward-looking The companies in which Glencore plc statements are not based on historical Neither Glencore nor any of its associates directly and indirectly has an interest are facts, but rather on current predictions, or directors, officers or advisers, provides separate and distinct legal entities. In this expectations, beliefs, opinions, plans, any representation, assurance or document, “Glencore”, “Glencore group” objectives, goals, intentions and guarantee that the occurrence of the and “Group” are used for convenience projections about future events, results of events expressed or implied in any only where references are made to operations, prospects, financial condition forward-looking statements in this Glencore plc and its subsidiaries in and discussions of strategy. document will actually occur. You are general. These collective expressions

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Contact us In addition to this our annual Modern Slavery Statement, our annual corporate reporting suite reflects our commitment to transparent Glencore plc disclosure across a broad range of topics: Baarermattstrasse 3 • Annual Report 2020 CH-6340 Baar • Sustainability Report 2020 Switzerland • Sustainability Highlights 2020 Tel: +41 41 709 2000 • Payments to Governments Report 2020 Fax: +41 41 709 3000 E-mail: [email protected] Disclaimer glencore.com The companies in which Glencore plc directly and indirectly has an interest are separate and distinct legal entities. In this Our Purpose document, “Glencore”, “Glencore group” and “Group” are used for convenience only Responsibly sourcing the commodities that advance everyday life where references are made to Glencore Our strategic objective plc and its subsidiaries in general. These To be a leader in enabling decarbonisation of energy usage and help meet continued demand for the metals needed in everyday life while responsibly meeting the collective expressions are used for ease of energy needs of today reference only and do not imply any other Our values relationship between the companies. Our Values reflect our purpose, our priorities and the beliefs by which we seek to conduct ourselves and carry out our business activities. They define what it means to work at Glencore, regardless of location or role. Likewise, the words “we”, “us” and “our” are also used to refer collectively to members of the Group or to those who Safety Integrity Responsibility work for them. These expressions are also We never compromise on safety. We We have the courage to do what’s We take responsibility for our actions. used where no useful purpose is served look out for one another and stop work right, even when it’s hard. We do what We talk and listen to others to if it’s not safe. we say and treat each other fairly and understand what they expect from us. by identifying the particular company or with respect. companies. www.glencore.com/sustainability/ stakeholder-engagement Openness Simplicity Entrepreneurialism We’re honest and straightforward when we communicate. We push ourselves to We work efficiently and focus on what’s We encourage new ideas and quickly Find us on: improve by sharing information and important. We avoid unnecessary adapt to change. We’re always looking encouraging dialogue and feedback. complexity and look for simple, for new opportunities to create value pragmatic solutions. and find better and safer ways of working.

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