...Glencore has historically been one of the largest commodity traders in the Russian market, reportedly winning “Rosneft’s regular crude and products tenders.” After the invasion began, Glencore continued to trade Russian commodities. According to customs documents reviewed by Global Witness, Glencore was identified in a group of traders responsible for lifting 33 tankers carrying roughly 20mn barrels of crude and oil products from Russian ports. Similarly, Glencore has continued to deliver significant amounts of Russian-origin aluminium to the London Metal Exchange, specifically including metal produced by Rusal. According to Glencore’s website, its Russian operations also include marketing offices in St. Petersburg and Moscow. The number of employees or the extent of these officer’s operations are unclear.

These activities risk enabling and financing Russia’s violations of IHL and human rights law during the ongoing invasion and occupation of Ukraine and violating Glencore’s Human Rights Policy. It remains to be seen how directly Glencore will be impacted by the partial mobilisation and the heightened legal, regulatory, operational, and financial risks associated with companies being required to provide direct support to the internationally sanctioned Russian military.

We seek to understand how Glencore has conducted and continues to conduct heightened human rights due diligence, per its stated policy and the UNGPs concerning due diligence in conflict-affected areas, and how the findings of such a process has resulted in these continued business activities and relationships. As noted by the UNGPs: …the more severe the abuse, the more quickly the enterprise will need to see change before it takes a decision on whether it should end the relationship. In any case, for as long as the abuse continues and the enterprise remains in the relationship, it should be able to demonstrate its own ongoing efforts to mitigate the impact and be prepared to accept any consequences – reputational, financial or legal – of the continuing connection.

In consideration of the above points and B4Ukraine’s Declaration, we request an urgent dialogue with Glencore’s relevant senior management and staff to discuss the company’s ongoing activities and relationships in Russia, associated risks to the people of Ukraine and the company, and potential steps to prevent/mitigate these risks...