Diversified miner Glencore has published its inaugural Ethics and Compliance Report, with key findings including the group’s 5% reduction in total emissions in 2021 and payments to governments totalling $7.6-billion.
The report states the company’s commitment to deliver value for its 135 000 employees and contractors, as well as other stakeholders, by operating transparently under a well-defined set of values, with integrity at the forefront.
The company continues to reduce its carbon footprint across the six continents in which it operates.
Glencore prioritises investment in and responsible sourcing of metals that support the decarbonisation of energy use and meet demand for everyday life, it states.
The report notes that commitment to ethics and compliance starts at the top with the board of directors, who bear responsibility for the implementation of Glencore’s values and oversee the company culture, ensuring that behaviour is consistent with the group values.
The board structure includes an Ethics, Compliance and Culture Committee. Board members attend annual training on their role, key compliance risks and development in ethics and compliance requirements and expectations. This work is complemented by that of the Environmental, Special and Governance Committee, the Business Approval Committee, and the Raising Concerns and Investigations Committee.
Glencore has also appointed engagement directors to garner feedback from employees on the company’s ethics and compliance and culture-related matters.
For example, Glencore in 2020 distributed an employee survey, inviting its 30 000 employees from 35 countries to provide insight on their day-to-day experiences, satisfaction with their roles, and safety and ethical behaviour of the company. Overall, the company scored 83 on its ethical commitments.
The Ethics and Compliance Report contains information about Glencore’s Ethics and Compliance Programme, which includes risk assessments, policies, standards, procedures, guidelines, training and awareness, and monitoring and investigations mechanisms.
Glencore summarises the programme as being a risk-based approach to ethics and compliance, to address challenges presented by the diverse business operations. The programme creates a feedback loop, which ensures that compliance risks are identified and addressed across the company on an ongoing basis.
In 2021, Glencore conducted 41 local risk assessments, which pertain to compliance risks faced by the marketing and industrial asset businesses of Glencore. These often related to corruption, sanctions, money laundering and market conduct-related activities.
Glencore also conducted 11 reviews of compliance documents in the prior year, as part of the police governance review cycle, and developed six new compliance documents.
Each Glencore office and industrial asset is required to develop a local training and awareness plan, reflecting that office or industrial asset’s local risk assessment, lessons learned, local legal or regulatory changes or any other local circumstances.
About 36 302 employees completed compliance e-learnings in 2021 related to code of conduct, which includes Glencore expectations on how to do business safely, responsibly, ethically and legally.
Glencore says in the report that a critical element of an effective ethics and compliance programme is having a culture in which people feel comfortable raising concerns, knowing they will be properly addressed.
The company encourages whistleblowers to raise concerns with their managers or supervisors, and only escalate the matter to nominated whistleblowing contacts if necessary.
Should concerns remain unaddressed through these two channels, Glencore urges employees to report concerns through the Raising Concerns Programme, which is available in the form of a website and phone lines across the group’s operations.
In 2021, the Raising Concerns Programme received 426 reports of concerns, of which 308 had been closed as of January 10 this year, taking an average 30 days to close. There were 51 instances of discipline applied in respect of concerns raised in 2021, including nine terminations, four suspensions and three removals of contractors from site.
Glencore says it has made significant investments into resources for implementing a best-in-class ethics and compliance programme, including compliance personnel, systems and external assurance.
CEO Gary Nagle comments that the importance of ethics and compliance made more visible across the company have substantially reinforced the overall compliance tone, culture and commitments of the company.