We are not satisfied just with meeting the minimum standards required by law. Rather, we strive to foster a culture of ethical behaviour and compliance throughout the Group. Glencore will not knowingly aid or abet any third party in breaking the law or engage in criminal, fraudulent or corrupt practices.
Throughout the Group, we have implemented a compliance programme that includes a number of guidelines, directives, training and awareness-raising measures, as well as control and investigation mechanisms. All our part-time and full-time employees, officers and directors, as well as (where contractually agreed) our contractors, are required to comply with applicable compliance policies and directives as well as applicable laws and regulations. In the case of joint ventures that we do not control, we strive to persuade our partners to align their policies and procedures with ours.
All Glencore employees are required to promptly report to their supervisor or a local manager any incidents that appear to violate the Glencore Code of Conduct, its underlying Policies or legal requirements. In addition, managers in Human Resources, Legal, Finance, Corporate Affairs, Sustainable Development, the Executive Board and the local Compliance Coordinators are available as contacts for such reports.
If a concern cannot be resolved at the local level, or employees, contractors, suppliers or other stakeholders have concerns about contacting local contacts, concerns can be reported at any time through Glencore’s global Raising Concerns programme.
The procedure is simple: To report a concern via Glencore’s protected internet platform, all that is required is to visit https://glencore.raisingconcerns.org 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. In this way, the anonymity of all persons reporting a concern is guaranteed, except in cases where a presenter of a concern voluntarily waives anonymity or is required to be named under local law. If a concern is reported in good faith and the reporter voluntarily gives his or her name, thus waiving anonymity, his or her identity will be kept confidential and protected. Glencore will only disclose the identity of a whistleblower to those employees who need to know in order to investigate and resolve the concern.
Glencore does not tolerate any retaliation against individuals who have reported their concerns in good faith. However, deliberate misuse of the reporting procedure is also unacceptable.