Modern Slavery Statement

Modern Slavery and Human Trafficking Statement

Serabi Gold plc (“Serabi” or the “Company” or, together with its subsidiaries, the “Group”) publishes this statement in compliance with section 54 of the Modern Slavery Act 2015. This statement describes the steps Serabi has taken to prevent modern slavery in its business and supply chains. Where the context so requires, references in this statement to the Company include references to the Company and all of its subsidiaries from time to time. The Company is committed to the prevention of the use of forced labour and has a zero tolerance policy for human trafficking and slavery.

The Modern Slavery Act 2015 (Act) requires any commercial organisation in any sector, which supplies goods or services, and carries on a business or part of a business in the United Kingdom, and is above a specified total turnover, to produce and publish an annual slavery and human trafficking statement.


1. Organisational structure
Serabi Gold plc is an established gold production and development company, with its shares listed on the stock exchanges operated by AIM in the United Kingdom and the TSX in Canada. Current gold production of 40,000 ounce per annum is derived from the Company’s Palito Complex mining operations located in the Tapajos region, in the southwest of the state of Para in northern Brazil. The Company is developing the Coringa gold project also located in the Tapajos region and currently anticipates that this will be in production during 2023. The Company directly employs approximately 640 personnel in its operations in Brazil and has a small head office staff based in London, England.


2. Our policies on slavery and human trafficking
2.1 The Company will not use or allow the use of forced, compulsory labour, slavery, servitude or human trafficking in the course of its business. This includes sexual exploitation, securing services by force, threats or deception and securing services from children and vulnerable persons.
2.2 The Company operates the following policies which are relevant to the prevention of slavery and human trafficking in its operations:
2.2.1 Anti-slavery and human trafficking policy – this policy sets out the steps that the Company has taken, and will take, to prevent human trafficking and slavery within its business and its supply chain.
2.2.2 Serabi Social Plans – Serabi is a significant employer in the region and provides a number of initiatives each year to support and improve the conditions of local communities, through inter-alia, supporting education, provision of medical and dental facilities, power and water, and general improvement of roads.
2.2.3 Procurement Policy – Serabi’s operations are supported by a supply chain which predominantly comprises goods and services required for the mining, processing and recovery of gold. Where practical, Serabi sources goods and services necessary to maintain its operations via supply chains. The Company tries to use local suppliers if possible and appropriate in order to enhance its contribution to socioeconomic welfare in the Tapajos region and the state of Para.
The Group currently conducts business with numerous suppliers, with the significant majority of them based in Brazil and cumulatively covering over 90% of the Group’s requirements. The majority of the other suppliers are based in North America and Europe.
The Group maintains open channels of communication with its suppliers and encourages them to raise any issues or concerns that arise in the conduct of their business.
2.2.4 Employment Policy – Employment terms and conditions for the Company’s employees based at its UK office and at its Brazilian mining operations are regulated by and are operated in compliance with all relevant prevailing national and local legislation. Employment terms and conditions provided to staff meet or exceed the national norms. The Group’s mining and processing operations are labour intensive and unionised.
2.2.5 Whistleblowing – The Company encourages all of its employees to report any concerns related to the activities of the firm. The Company will ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue. Additionally, the Company will ensure that no one will be victimised for raising a matter under this procedure.
2.3 In addition, internal policies are reviewed regularly to ensure continued compliance with the Modern Slavery Act 2015. .


3. Due diligence processes for slavery and human trafficking
The Company believes that in order to prevent human trafficking and slavery within its business and its supply chain it is necessary to first understand the areas where the Company is most at risk. Although the work conducted at the Company’s mining operations is labour intensive, the Company feels that the unionised workforce and the Company’s adherence to strict employment policies and regular inspection by the Ministry of Labour negates the risk of modern slavery in this operation. As a consequence, the Company feels its supply chain is the area that presents the most risk. As a result of the due diligence process the Company has conducted, systems have been put in place to:
3.1 continue to identify and assess potential risk areas in the Company’s business and supply chains;
3.2 continue to adhere to, and enforce the Company’s procurement policy and the Company’s employment policies;
3.3 seek to continue the good relationship built with unions and the Ministry of Labour in Brazil; and
3.4 protect whistle-blowers.


4. Supplier adherence to our values and ethics
4.1 To ensure contractors and those in the Company’s supply chain comply with its values and ethics, the Company incorporates into its procurement procedures a requirement for suppliers to positively confirm their own commitments to prevent human trafficking and slavery.
4.2 In addition efforts are made to confirm that the Company’s suppliers are as committed to the prevention of human trafficking and slavery as the Company, and each supplier’s conduct is carefully considered when awarding or renewing business.
4.3 Reviews of the Company’s suppliers and its supply chain profile are conducted annually.


5. Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in its supply chains and business, the Company will provide the necessary training to all relevant employees.


6. Performance indicators
The Company will use the following key performance indicators to measure how effective it is in ensuring that slavery and human trafficking is not taking place in any part of its business or supply chain:

6.1 completion of necessary training of the policy by all relevant staff;  

6.2 communication of the policy to suppliers; and  

6.3 continued progress of the social and labour plan of the Group in Brazil. 



7. Further steps

This statement is reviewed annually by the Company’s Chief Executive Officer Michael Hodgson and approved by Serabi’s Board of Directors.
This statement is made pursuant to section 54(1) of the Act and constitutes the Company’s antislavery and human trafficking statement for the calendar year ended 31 December 2020.