Gold Star Bullion Security Legal & compliance Modern slavery
Modern slavery
Steps taken to keep forced labour out of our own operations and our supply chain.
Status of this statement
Section 54 of the Modern Slavery Act 2015 requires a statement from commercial organisations with a turnover of £36 million or more. Our turnover is below that threshold, so this statement is made voluntarily. We publish it because gold mining and international freight are both sectors with documented forced-labour risk, and because a firm that declines to say anything is telling you something.
- Financial year covered
- to be supplied
- Board approval date
- to be supplied
- Signed by
- to be supplied
Our business
We hold precious metals in vaults and move consignments internationally by air and sea, from an office in London, trading since 2003.
Where the risk actually sits
Our direct employment is small, UK-based and low risk. The meaningful exposure is upstream and downstream of us:
- Artisanal and small-scale mining
- The highest risk in the chain: forced labour and child labour are documented in parts of the sector. Addressed through sourcing due diligence rather than assurances.
- Refining
- Lower risk where the refiner is subject to LBMA Responsible Gold Guidance audit; higher where it is not.
- Freight and handling
- Labour risk in port handling, warehousing and road haulage, particularly through layered subcontracting.
- Cleaning, security and facilities
- Outsourced low-wage services, a common location for labour exploitation.
What we do about it
- Sourcing due diligence. We require chain of custody for metal and decline what we cannot trace. See sanctions and sourcing.
- Subcontractor terms. Carriers, agents and facilities suppliers are required to comply with the Modern Slavery Act and to flow the requirement down to their own subcontractors.
- Recruitment. Right-to-work checked for every person engaged. We do not use unregulated labour providers, and we do not permit recruitment fees to be charged to workers.
- Pay. Everyone engaged directly is paid at or above the Real Living Wage, on time, into an account in their own name.
- Reporting route. Concerns can be raised to info@goldstarbullionsecurity.com, anonymously if preferred, without retaliation.
What we have not done yet
Being straight about the gaps is more useful than a list of aspirations:
- We have not audited our suppliers on site. Supplier assurance is currently contractual and documentary.
- We do not yet publish measurable KPIs against this statement.
- Formal modern slavery training for all staff is planned but not yet delivered.
Reporting a concern
If you suspect modern slavery in our operations or supply chain, contact us, and contact the Modern Slavery Helpline on 08000 121 700, which operates 24 hours a day. In an emergency, call 999.
Questions about this document go to info@goldstarbullionsecurity.com, or write to Gold Star Bullion Security, 144 Houndsditch, London EC3A 7BX, United Kingdom.