Company No: 09142456
Modern Slavery Statement
CGN Global Uranium Limited
Registered office address: First Floor, 50 St Andrew's Street,
Cambridge, Cambridgeshire, CB2 3AH
This is a statement produced by CGN Global Uranium Limited (“we” or “us”) in relation to its compliance with the Modern Slavery Act 2015 for the financial year ending 31 December 2023.
Introduction
Modern slavery is a term used to encapsulate various forms of servitude, forced or compulsory labour and human trafficking. We are opposed to modern slavery in all its forms and we are committed to constantly improving our practices to ensure that our supply chain is free from any form modern slavery.
Organisation's structure
We operate within the global energy sector, in particular, in the trading of uranium products.
We are part of the China General Nuclear Power Group (the “Group”) and our direct parent company is CGN Mining Company Ltd.
We operate one office located in Cambridge, United Kingdom and we currently have six employees.
Our business
We purchase uranium products either from intermediaries on the market or from companies whose affiliates are operating uranium mines themselves and other market players. We will then seek to sell these products to uranium traders, producers of uranium products and utilities companies for application in energy contexts.
Our suppliers and customers are located in many different countries and regions all over the globe.
Our supply chains
All of our suppliers are reputable organisations which are well-established within the uranium mining and trading industry. Our supply chains can either begin at the company operating the uranium mine itself, or we purchase the uranium products from intermediaries (e.g. traders, banks and funds).
Our suppliers are located across the following regions:
(a) Australia;
(b) USA;
(c) Canada;
(d) Namibia;
(e) Switzerland;
(f) Kazakhstan;
(g) United Kingdom；
(h) Cyprus；
(i) Hong Kong；
(j) Singapore；and
(k)The Czech Republic
We have developed long-term relationships with our suppliers who have been subjected to our internal evaluation system for suppliers. The terms which we agree with our suppliers set out the commitment of us and our suppliers to respecting human rights and compliance with local laws.
Our values and 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 implement policies which provide a code of conduct for our employees so that we ensure they behave in a way which promotes equality and respect for human rights.
We have in place systems to protect whistle blowers within our organisation and this forms part of our employees’ handbook. Our whistleblowing policy is a key component to ensuring that where an employee detects evidence of or risks relating to modern slavery, then they have a clear procedure in which they can follow to report such evidence or risks and simultaneously be protected in accordance with the terms of our policy.
We adopted an Anti-slavery Policy to reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate the risk of modern slavery our commercial and sales managers have taken actions to review our suppliers and other contractual counterparties in the market through information published through online searches and via trusted news networks. We do this in order for us to understand our suppliers’ histories and current statuses, and to identify any potential risks of modern slavery. Our searches would focus on spotting any potential risks of human rights abuses, labour practices, and anything else which could 3
point towards modern slavery practices. If our findings on the suppliers contain serious compliance issues, then a report will be produced and kept on file.
We will also conduct our own primary research within the uranium market so that we can collect information about our suppliers from other parties active within the same market. This would also allow us to highlight any risks associated with modern slavery.
Risk management
We also recognise that certain areas of our supply chains may pose higher modern slavery risks due to their locations and the nature of the supplier. Following our assessment in the financial year ending 31 December 2023, we do not consider that any of the regions or the sectors which our suppliers operate in pose particularly high risks of modern slavery.
Examples of how we conducted our risk assessment:
Although one of our key suppliers is based in Kazakhstan, which is considered to be a higher-risk region for modern slavery practices, we noted that the particular supplier is listed on the Main Market of the London Stock Exchange. Based on this, we concluded that because of the disclosure requirements for listed companies, the risk of modern slavery practices was relatively low.
Another of our suppliers is based in Namibia, which is also considered to be a higher-risk region for modern slavery practices, however the main supplier we use in Namibia is Swakop Uranium Pty Ltd. (“Swakop”) which is an affiliated company within our Group. Swakop maintains high standards in its mining activities and adheres to our Group’s safety and compliance culture. Since we are in the same group as Swakop, we have been provided with copies of their internal procedures and we have conducted an on-site visit as well. Based on the information we have been able to gather, we concluded that the risks of modern slavery practices in this region were also low.
Moreover, in the financial year ending 31 December 2023, we did not identify any actual instances of modern slavery within our supply chains.
Supplier adherence to our values
We currently do not have a programme in place which obliges our suppliers to adhere to our values and policies relating to anti-slavery. However, in our suppliers’ terms and conditions, the majority contain provisions which ensure compliance and respect for human rights and have satisfied our standards.
The agreements which we sign with our suppliers will all typically obligate our suppliers to ensure their compliance with local laws. In the event our suppliers breach any local laws, including in relation to modern slavery practices, we would treat this with the utmost seriousness and would reconsider our continuing business relationship with them.
Training
We have provided training to all of our employees during their induction. This training would typically cover the content of our policies, employees’ codes of conduct and our employee 4
handbook, copies of which are provided to all employees upon joining us. We may also provide on-going and periodical training provided where necessary.
Our effectiveness in combating slavery and human trafficking
We understand that the risk of modern slavery is not static, and we will continue our approach to mitigating this risk in the year ahead.
In order to assess the effectiveness of the measures taken by us, we will be reviewing the following key performance indicators and reporting on them in future Modern Slavery Statements:
(a)Implementation of an anti-slavery policy within our employees’ code of conduct;
(b)the actions taken to strengthen our supplier due diligence process; and
(c)our staff training levels on Modern Slavery.
Further steps
Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:
(a)Maintain Anti-Slavery Policy;
(b)Monitor processes in which to conduct effective due diligence over our suppliers and supply chains; and
(c)provide training to all of our employees on modern slavery when needed.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023. It was approved by the sole director on 5th March 2024.