We are not satisfied with merely meeting the minimum standards required by law. We are committed to maintaining a culture of ethics and compliance throughout Glencore – not simply performing the minimum required by laws and regulations. Glencore will not knowingly assist any third party in breaking the law, or participate in any criminal, fraudulent or corrupt practice in any country.
Group-wide, Glencore has implemented an ethics and compliance programme that encompasses risk assessments, policies and procedures, training and awareness, monitoring, speaking openly and investigations. All employees, directors and officers (as well as contractors, where applicable) must comply with our relevant policies and procedures, and the law. When we enter into joint ventures where we are not the operator, we encourage our partners to adopt similar policies and procedures to ours.
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All Glencore, employees are encouraged to promptly report concerns with regards to any incidents that appear violate the Glencore Code of Conduct, its underlying policies or legal requirements to the relevant managers or supervisors at their office or industrial asset. . They can also reach out to people nominated at our offices and industrial assets to receive concerns. These people, called Whistleblowing Contacts, are typically members of the senior management team.
If the concern remains unsolved or someone feels uncomfortable using the local channels, a report can also be made to the Raising Concerns Programme, Glencore’s corporate programme managed in Switzerland.
The procedure is simple: to report a concern via Glencore’s secure internet platform, all that is required is to visit and click on the “Report Concern” button. Telephone numbers are also available in most countries. These are listed on the above-mentioned website.
When using this internet platform, no IP data, time stamps or metadata are collected and messages are transmitted and stored in encrypted form. This ensures the anonymity of anyone reporting a concern, except in cases where the person raising a concern voluntarily waives their anonymity or is required to be named under local laws. If a concern is reported in good faith and the whistleblower voluntarily gives their name, thus waiving anonymity, their identity will be kept confidential and protected. Glencore will only disclose the identity of the whistleblower to those employees who need to know it in order to investigate and resolve the concern.
Glencore will not tolerate retaliation against individuals who have reported their concerns in good faith. However, wilful misuse of the reporting procedure is also unacceptable.