Modern slavery act transparency statement

Fastmarkets Modern Slavery Act

What is the Modern Slavery Act 2015?

The UK Modern Slavery Act 2015 (the “Act”) seeks to address the role of businesses in preventing modern slavery occurring in their organisations and supply chains. It applies to businesses of a certain size, which are required to publish a statement setting out the steps they have taken to ensure that modern slavery and human trafficking are not taking place in their business or supply chains. 

This statement sets out the steps that we have and will continue to take as part of our ongoing commitment to keep slavery and human trafficking out of our business and our supply chains. 

Introduction 

This statement sets out the steps the Fastmarkets Group has taken to comply with the Act. In this statement, Lithium Hangar Holdco Limited and its subsidiary companies are referred to as the “Fastmarkets Group”. Fastmarkets is one of the most trusted cross commodity price-reporting agency (PRA) in the agriculture, forest products, metals and mining and new generation energy markets. 

We provide price data, news and analysis from more than 200 reporters and analysts globally for markets including agriculture, energy, and metals and mining. Our data is used by customers seeking to understand and predict dynamic, sometimes opaque markets, enabling trading and risk management. Fastmarkets is a global business founded in 1913 with a history dating back to the 1800s and has more than 650 employees spread across the UK, US, China, Singapore, Bulgaria, Brazil, Belgium, and Finland. 

Organisational structure, business and supply chains 

With thousands of suppliers worldwide, the risk of modern slavery among them varies. We considered each of our business operations and their supply chains and determined the following areas as our inherent or perceived supply chain risk: 

  • events operation services in non-EU / non-US countries
  • contracted maintenance staff working in the company’s offices in all locations (e.g. cleaning, catering, security, building services)  
  • outsourced operations located in high-risk countries including data and list researchers.

Due diligence processes 

Our principal business relationships are with procurers, traders, consumers, regulators and financial institutions among others. These stakeholders rely on the commodities prices we provide for their market’s activities. As a PRA business we have assessed the risk of modern slavery among our direct employees to be low. This is based on the externally available research on industries that are prone to modern slavery risks. In addition, most of our employees have low-risk roles, such as office-based positions and include roles that require specialist qualifications such as HR, accounting, economists, reports etc. We believe the greatest risk lies within our supply chain. Therefore, we aim to assess our modern slavery risks across the business annually though our procurement due diligence process.    

Risk assessment and management 

As a business we recognise the concerns related to modern slavery globally and the need to address the risks within our business and the wider supply chain. The United Nations Office on Drugs and Crime states that the global modern slavery and human trafficking situation worsened during the pandemic and is set in the context of significant growth and changes in market dynamics. Therefore, as a business we will evolve by looking at ways that we can mitigate modern slavery risks and more so how we engage more closely with our supply chain partners.   

In terms of managing risks within our businesses, the controls in place as part of the recruitment and deployment of employees and consultants are key. We will seek to ensure appropriately robust modern slavery compliance obligations are included in our supplier contracts. The support and tools available for our employees and consultants to raise concerns internally or, if preferred, via an independent confidential helpline, operated by Safecall, further helps to manage the risk of any such abuse going undetected or unreported. 

Measuring effectiveness 

Fastmarkets does not employ unskilled labourers, however, measuring the effectiveness of our modern slavery initiatives remains crucial. We conduct thorough worker checks to ensure our staff have the legal right to work.

Policies 

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships to mitigate modern slavery and human trafficking risks within our business and our supply chains. 

More broadly our Code of Business Conduct and Speak Up policies, covering employees, consultants, and external partners, are designed to encourage the raising of genuine concerns of wrongdoing or harm across our businesses as well as raising the awareness of what to look for on issues relating to modern slavery.    

Training 

Training is crucial to ensure our employees properly understand the risks of modern slavery and know how to respond within their working environment. Our Code of Business Conduct launched in December 2023, and all Fastmarkets employees complete an annual Code of Business Conduct training, which includes Modern Slavery training. We specifically included this training as part of the Code of Business Conduct launch to enhance awareness of modern slavery among our employees.  

By delivering this training, we aim to ensure that all our employees are equipped with the knowledge and understanding necessary to prevent and combat modern slavery in all its forms. Additionally, we have introduced a new Speak Up portal to improve our reporting capabilities on any issues that may pose a risk of modern slavery. 

Compliance approach 

To monitor compliance:  

  • We have a departmental risk management process led by the department head with a senior leadership team member sponsor. This process captures and addresses any areas of the business that pose a risk to our operations and people, including the risks of modern slavery within the business.
  • Modern slavery statement is board reviewed and approved annually.

Looking ahead 

Next steps in mitigating modern slavery risks 2024-2025:

  • Support and enable Fastmarkets’ Procurement team to review our onboarding end to end process.
  • Work with the business to review the supplier lifecycle post onboarding from a due diligence perspective.
  • Review how we measure our effectiveness in managing modern slavery risks, including the provisions within our supplier contracts.
  • Review our right to work checks process and where possible automate reminders within our HRIS by the end of 2024.

Review 

We will continue to review and update our compliance approach as our businesses and inherent or perceived supplier risks change over time. 

This statement is made pursuant to section 54(1) of the Act and constitutes the Group’s modern slavery and human trafficking statement for the financial year ending 30 September 2023. 

This statement was reviewed and approved in June 2024 by the Board of Directors of Lithium Hangar Holdco Limited. 

Updated June 2024

Raju Daswani
CEO
Fastmarkets Global Limited