Modern Slavery and Human Trafficking Statement

1. Policy Statement

Valen Commodities is committed to preventing acts of modern slavery and human trafficking in our business operations and supply chains. We recognize our responsibility to respect human rights and maintain ethical standards throughout our global trading activities. This statement is made in accordance with the UK Modern Slavery Act 2015 and similar legislation in other jurisdictions.

2. Our Business

Valen Commodities is an international petroleum trading and brokerage company that facilitates institutional-grade transactions in the global commodities market. Our operations include:

• Trading and brokerage of petroleum products, including EN590 10 PPM Diesel
• Supply chain verification and compliance services
• Facilitation of transactions between verified suppliers and buyers
• Commodities market analysis and insights

We operate primarily as a trading intermediary, working with established suppliers, refiners, and buyers in the petroleum industry.

3. Our Supply Chains

Our supply chains involve:

• Petroleum refineries and production facilities
• Storage and terminal operators
• Shipping and logistics providers
• Financial institutions and payment processors
• Legal, compliance, and professional service providers
• Technology and software service providers

We recognize that modern slavery risks may exist at various points in extended supply chains, particularly in industries involving manual labor, transportation, and manufacturing. While our direct operations involve primarily professional services, we are committed to understanding and addressing risks throughout our business relationships.

4. Risk Assessment

4.1 Risk Areas

We have identified the following areas where modern slavery risks may be present:

• Extended Supply Chains: Risks in upstream production, refining, and transportation operations of our trading partners
• Logistics and Shipping: Risks in maritime and land transportation services, particularly in international shipping
• Third-Party Service Providers: Risks in cleaning, maintenance, security, and other support services
• Geographic Risk: Operations in regions with higher prevalence of forced labor or weak labor protections

4.2 Risk Mitigation

We conduct regular risk assessments to identify and evaluate potential modern slavery risks in our operations and supply chains, prioritizing areas of highest risk for enhanced due diligence.

5. Due Diligence Processes

We have implemented due diligence processes to identify and prevent modern slavery:

• Supplier and Partner Screening: We conduct background checks and reputation assessments on potential trading partners and service providers
• Compliance Verification: We verify that partners have appropriate policies and certifications related to human rights and labor standards
• Contractual Requirements: Our agreements include provisions requiring compliance with anti-slavery laws and ethical standards
• Ongoing Monitoring: We monitor our business relationships for changes in risk profile or compliance status
• Third-Party Audits: Where appropriate, we engage independent verification of supply chain practices

6. Policies and Procedures

6.1 Code of Conduct

Our Code of Conduct requires all employees and representatives to:

• Respect human rights and dignity in all business activities
• Report any suspected violations of anti-slavery laws
• Refuse to engage with partners who violate human rights standards
• Support remediation efforts when violations are identified

6.2 Procurement and Vendor Management

Our procurement processes include evaluation of vendors' human rights practices and require compliance with anti-slavery standards as a condition of engagement.

7. Training and Awareness

We provide training to relevant personnel on:

• Recognizing signs of modern slavery and human trafficking
• Understanding legal obligations under anti-slavery legislation
• Conducting due diligence on business partners
• Reporting procedures and whistleblower protections
• Industry-specific risks in commodities trading

Training is provided to all employees upon joining and updated regularly to reflect evolving risks and best practices.

8. Reporting and Remediation

8.1 Reporting Mechanisms

We maintain confidential reporting channels for concerns about modern slavery:

• Direct reporting to management and compliance officers
• Anonymous whistleblower hotline
• External reporting to relevant authorities when appropriate

8.2 Remediation

When modern slavery is identified in our operations or supply chains, we are committed to taking immediate action, including termination of relationships where necessary, supporting victims, and cooperating with law enforcement and relevant authorities.

9. Effectiveness and Measurement

We measure the effectiveness of our anti-slavery efforts through:

• Regular risk assessments and supply chain audits
• Tracking of training completion and awareness levels
• Monitoring of reported incidents and response times
• Review of partner compliance certifications
• Benchmarking against industry best practices

This statement is reviewed annually and updated as necessary to reflect changes in our operations, risks, or legal requirements.

10. Board Approval

This statement has been approved by the board of directors of Valen Commodities and reflects our commitment to preventing modern slavery and human trafficking. The board is responsible for overseeing the implementation of this policy and ensuring its effectiveness.

11. Contact Information

To report concerns about modern slavery or human trafficking, or to seek guidance on this statement: