Modern Slavery Statement
Statement under the UK Modern Slavery Act Statement
This statement is published by GEM Resources plc ("GEM" or the "Company", and "we" and "our" shall be construed accordingly) and its relevant subsidiaries in compliance with the UK Modern Slavery Act 2015 (as amended) ("MSA"). This statement sets out the steps we have taken against modern slavery in our business and supply chains.
Introduction
GEM is committed to combating all forms of modern slavery, forced labour, and human trafficking. Given the elevated risk in some of the jurisdictions in which GEM operates, particularly within the mining sector, the Company takes proactive and comprehensive measures to ensure that its operations and supply chains are free from modern slavery and align with international standards.
Modern slavery is against GEM's commitment to respect human rights as set out in the Universal Declaration of Human Rights, the International Labour Organisation's 1998 Declaration of Fundamental Principles of Rights at Work, the Voluntary Principles on Security and Human Rights and the Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains.
Our Business and Supply Chains
GEM is a London Stock Exchange-listed gemstone mining investment company which holds direct and indirect equity positions in mining companies and projects across several jurisdictions including South Africa, Zambia and Western Australia. The Company is exploring additional investment opportunities globally, including in emerging markets.
GEM may operate as a shareholder with board representation on and oversight over investee companies. These companies may have their own management and procurement teams who oversee daily activities and supply chain decisions. The Company recognises the importance of implementing appropriate governance and monitoring measures to ensure that modern slavery risks are addressed and mitigated, particularly when the Company does not directly control daily operations.
The Gravelotte Mine, owned by GEM's subsidiary in South Africa, is currently the only operational project in GEM's portfolio. The company is proud to have partnered with the local community, which holds a direct shareholding in the mine through a 26% Community and Black Economic Empowerment trust structure (BEE). This partnership ensures mutual benefit and supports a "locals first" employment policy, with the mine currently being 100% staffed by local South Africans. It employs 22 full-time staff, in addition to 7 contractors working through contracted services. While GEM considers the Gravelotte Mine to be low-risk from an MSA compliance perspective, it remains an area of focus for the Company, which continues to monitor the project to ensure adherence to the highest standards of compliance and ethical practice.
The other projects within GEM's portfolio are in the exploration phase, with few or no employees, presenting negligible risk in terms of modern slavery. However, GEM will continue to monitor these projects and manage MSA risks as they progress and develop.
GEM's supply chains extend across mining operations, logistics, and procurement of goods and services, many of which come from jurisdictions with varying levels of legal enforcement and regulatory oversight. GEM is committed to addressing modern slavery risks through a combination of stringent due diligence, supplier engagement, and ongoing monitoring.
Our Values and Policies
GEM is guided by the following principles in its commitment to eliminating modern slavery:
- MSA Compliance: Adherence to the MSA is central to our operations, ensuring that we take all necessary steps to prevent modern slavery within our supply chains.
- International Labour Organization ("ILO") Standards: We align our policies with ILO conventions, particularly those addressing forced labour (ILO Convention No. 29) and the worst forms of child labour (ILO Convention No. 182).
- OECD Due Diligence Guidance: We follow the OECD's Due Diligence Guidance for Responsible Supply Chains, ensuring that our operations and those of our suppliers adhere to internationally recognized standards for labour rights and anti-slavery measures.
- Voluntary Principles on Security and Human Rights: We are committed to adhering to the Voluntary Principles on Security and Human Rights in managing security forces in high-risk operating environments, where human rights and labour abuses can often intersect.
- GEM enforces its own Code of Conduct, which outlines clear expectations for suppliers and contractors to maintain ethical practices, particularly in relation to labour rights and human trafficking.
GEM's employees, partners, and suppliers are expected to conduct their activities in a manner that respects human rights as set out in the above standards. This includes (but is not limited to):
- No use of child labour.
- No use of forced, prison, or compulsory labour.
- No payment of recruitment fee by workers.
- Compliance with all applicable laws and regulations on freedom of association and collective bargaining.
- Maintenance of a safe, secure, and healthy workplace and not tolerating discrimination, harassment or retaliation.
- Compliance with all applicable laws and regulations on working hours
- Provision of wages and benefits that meet or exceed national legal standards.
All GEM companies must comply with local legislation and regulations and must conduct their activities in line with our core values of honesty, integrity, and respect for people.
Risk Assessment
Operating in emerging markets requires a comprehensive risk assessment framework to address modern slavery risks effectively, considering both country and industry risk:
- Country-Specific Risk Factors: There may be challenges related to weak enforcement of labour laws, lack of resources for proper oversight, and high levels of informal or artisanal mining, all of which can increase exposure to modern slavery.
- Sector-Specific Risks: The mining sector, particularly in jurisdictions with high levels of informal and artisanal mining, often involves complex supply chains where labour exploitation can be difficult to detect. In these jurisdictions, the presence of subcontractors and informal labour practices adds additional layers of risk.
- Investment-Specific Risks: As part of our due diligence process for new investments, GEM conducts thorough evaluations of human rights and labour standards, particularly focusing on local conditions in jurisdictions with heightened risks. The Company assesses direct operations and the broader supply chain to identify and mitigate any potential risks of modern slavery.
Due Diligence
GEM implements a detailed due diligence process designed to address the specific risks associated with modern slavery:
- Pre-Investment Screening: Each new investment undergoes a comprehensive review, including human rights and modern slavery risks, with a focus on the local legal framework, labour market conditions, and the presence of any subcontracting or informal mining operations.
- Supplier and Contractor Audits: Key suppliers and contractors in high-risk regions are subject to regular audits to ensure compliance with GEM's ethical standards.
- Ongoing Monitoring: Continuous monitoring of Company operations and supply chains helps identify emerging risks. GEM conducts regular site visits to ensure adherence to ethical labour standards and responds promptly to any concerns or allegations.
Effectiveness and Performance Management
To ensure the effectiveness of our anti-slavery initiatives, GEM tracks performance through:
- Incident Reporting: A confidential system is in place for employees, suppliers, and stakeholders to report any instances or concerns regarding modern slavery.
- Corrective Actions: GEM will investigate concerns or allegations regarding a breach of Company policies. If a violation is confirmed, GEM will take appropriate action up to and including contract termination or dismissal, with full protection in line with the Company's whistleblowing policy.
Training and Awareness
GEM invests in training programs to ensure that all employees, contractors, and suppliers are aware of modern slavery risks and the Company's policies:
- Employee Training: All GEM employees receive regular training on recognizing and preventing modern slavery, with additional training for teams involved in procurement and supply chain management.
- Supplier Engagement: Suppliers are required to adhere to GEM's supplier code of conduct, which sets clear expectations for labour practices.
For more information, please visit our website:. https://gemresources.co.uk/.
Dr Bernard Olivier
Chief Executive Officer
For and on behalf of GEM Resources plc
Date: 17/03/2025
This statement has been approved by the Board of GEM Resources plc and each of its relevant subsidiaries in compliance with the MSA. It was approved by the Board of GEM Resources plc on 17 March 2025.
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