1. Introduction

At Lusail Energy and Metal Trading W.L.L. (“Lusail Energy”), we believe that the true measure of any organization lies not only in its commercial success but also in its unwavering commitment to ethical principles and human dignity. As a Qatar-based energy and metal trading and brokerage firm—with offices in Brazil, Switzerland, Qatar, and Singapore—we recognize our profound responsibility to uphold the highest standards of morality, integrity, and social justice across all facets of our global operations.

We stand firmly against all forms of modern slavery and human trafficking. This statement is both a reaffirmation of our stance and a broader intellectual essay outlining our dedication to a just and equitable world—one that rejects human exploitation in every form.

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2. Defining Modern Slavery and Human Trafficking

Modern slavery encompasses various forms of coercive labor, including forced labor, debt bondage, and involuntary servitude, where individuals are compelled to work under threats, intimidation, or deceit. Human trafficking is the recruitment, transportation, transfer, or harboring of persons by means of force, fraud, or coercion for exploitative purposes. These heinous crimes violate fundamental human rights and corrode the moral fibers of our shared global society.

 

Given the global nature of Lusail Energy’s business—encompassing energy procurement (Diesel and A1 Jet Fuel) and brokerage activities (Fertilizers and Lithium)—our dedication to eradicating slavery and trafficking must be robust, clear, and consistently upheld.

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3. Our Ethical and Legal Commitments

1. Compliance with International Standards and Local Laws
   We operate under the legal frameworks of the state of Qatar and any additional jurisdictions where we engage in trading activities. We also align our corporate conduct with leading international guidelines such as the United Nations Global Compact, the Universal Declaration of Human Rights, and International Labour Organization (ILO) conventions.

2. Supply Chain Accountability
   Our supplier and partner network is extensive, spanning multiple continents and sectors. We place particular emphasis on ensuring that every partner, contractor, and subcontractor in our value chain upholds the same zero-tolerance approach to modern slavery and human trafficking. In cases where we detect or suspect non-compliance, we take immediate action—this may include halting collaborations, conducting rigorous investigations, and reporting violations to the relevant authorities.

3. Transparency and Due Diligence
   We believe that diligent oversight is instrumental in preventing potential abuses in the supply chain. As part of our procurement processes, we undertake comprehensive due diligence—vetting third parties through systematic screenings, on-site audits, and continuous monitoring. Such practices enable us to identify and address risks effectively before they endanger vulnerable individuals or communities.

4. Risk Assessment and Mitigation
   We systematically identify regions, sectors, or products that could pose heightened risks for forced labor. In these instances, we implement additional controls: enhanced audits, focused training, deeper background checks, and policy reviews that ensure all relevant stakeholders adhere to our strict guidelines.

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4. Organizational Culture and Employee Awareness

1. Education and Training
   We believe that knowledge is a potent deterrent to exploitation. Therefore, we invest in regular training sessions and awareness campaigns for our employees, management team, and local partners. Topics include recognizing signs of modern slavery, understanding legal obligations, and reporting potential concerns through secure channels.

2. Whistleblowing and Reporting Mechanisms
   We maintain confidential reporting systems that allow employees, partners, and external stakeholders to safely voice concerns regarding potential abuses. These channels are widely publicized and diligently managed to ensure timely response and resolute investigation. Our commitment to anonymity and protection from retaliation encourages transparency and fosters an environment where ethical conduct is everyone’s responsibility.

3. Employee Well-Being
   We consider the well-being and dignity of all employees integral to our success. Through proactive Human Resources policies, regular labor rights audits, and fair remuneration practices, we ensure that exploitation, in all its forms, finds no foothold within our organization.
    

5. Partnerships and Collaborative Action

Modern slavery and human trafficking are global issues transcending borders, industries, and demographics. As such, confronting them requires collective action and shared knowledge. Lusail Energy collaborates with governments, civil society organizations, advocacy groups, and other corporations to champion and refine laws and practices that eradicate exploitation. Our involvement in local community initiatives, international forums, and multistakeholder conferences demonstrates our commitment to being a proactive force for change rather than a passive observer.
 

6. Continuous Improvement

1. Policy Evolution
   Our Anti-Slavery and Anti-Human-Trafficking Policy undergoes periodic review to incorporate new legal requirements, industry best practices, and invaluable insights gleaned from ongoing partnerships and assessments.

2. Performance Metrics and Reporting
   We measure and report our progress through structured key performance indicators (KPIs)—such as the number of supplier audits conducted, completed employee training sessions, and identified areas of risk requiring urgent remediation. These data-driven insights guide continuous improvement and keep us accountable to our own exacting standards.

3. Leadership Engagement
   The Board of Directors and Executive Leadership regularly engage in discussions surrounding ethical performance, risk mapping, and policy enhancements. By keeping these discussions at the highest levels of corporate governance, Lusail Energy ensures that the issue of modern slavery and human trafficking remains central to our strategic priorities.
    

7. Our Call to Action

At Lusail Energy, we recognize that our influence extends far beyond our direct operations. We call upon industry peers, suppliers, local communities, and regulators to share in the commitment to eradicate modern slavery and human trafficking. The repercussions of these crimes—devastated communities, stifled economic development, and the ongoing denial of basic human freedoms—underscore the moral imperative to act decisively.

We pledge to be vigilant, innovative, and compassionate in our approach. By working together—across industries, continents, and cultures—we can transform even the most deeply ingrained systemic issues. True progress begins with a moral conviction that every life, and every moment of freedom, is of incalculable value.
 

8. Conclusion

This statement is more than mere policy or corporate compliance—it is a reflection of our collective consciousness and ethical identity. To combat modern slavery and human trafficking is to safeguard the dignity of individuals everywhere. Lusail Energy stands resolute and united in confronting these injustices, driven by our unwavering belief that our economic achievements must never come at the cost of fundamental human rights.

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Through ongoing vigilance, transparent collaboration, and steadfast ethical leadership, we will continue to forge a global trading environment that values and protects human freedom. On behalf of the Board of Directors and the entire Lusail Energy family, I thank you for supporting our commitment to ending modern slavery and human trafficking. We invite our stakeholders—current and future—to join us in championing this critical cause.
 

Signed,

Filippos G. Dounis
Member of the Board of Directors
Chief Operating Officer

Lusail Energy and Metal Trading W.L.L.