Modern Slavery Statement

1. Our Business and Supply Chains

KGML operates as a global commodity trading house with offices in Dubai, Arua City, Noida, and Houston. Our supply chains extend across Africa, Asia, the Middle East, Europe, and the Americas, involving producers, miners, refiners, logistics providers, and financial intermediaries.

We recognise that the commodity sector — particularly mining and sourcing in emerging markets — carries elevated risk of labour rights violations.

2. Policies and Governance

• Formal Human Rights Policy and Responsible Sourcing Policy
• Supply chain due diligence aligned with OECD Guidance for Responsible Mineral Supply Chains
• Contractual labour standards requirements in all supplier agreements
• Modern slavery risk assessment as part of supplier onboarding
• Dedicated ESG and Sustainability function within the organisation

3. Due Diligence

We conduct risk-based due diligence on our upstream supply chain partners, with particular focus on artisanal and small-scale mining (ASM) sourcing in Africa. Site visits, third-party audits, and chain-of-custody tracing are used to verify labour practices.

4. Training and Capacity Building

All employees involved in sourcing and procurement receive training on identifying indicators of forced labour, human trafficking, and labour exploitation.

5. Reporting and Remediation

We maintain a confidential reporting channel for reporting modern slavery concerns. Where instances are identified, we implement remediation plans focused on supporting victims and improving systemic controls.