Ethics & Compliance
Our conduct
Every day, Sierramin Bauxite works hard to deliver the resources that are the building blocks of an ever-changing world. While what we achieve is important, so is how we achieve it.
We know consistent ethical behaviour cultivates a culture of inclusion, care and trust, which ultimately results in improved performance by Sierramin Bauxite. It also strengthens our relationships with the communities where we work and helps protect the social value we deliver.
How we work is guided by 6 key elements and they are :
- Sustainability
- Integrity
- Respect
- Performance
- Simplicity
- Accountability
Our commitment to transparency
We live in a world where public trust in institutions is declining. The absence of trust undermines social cohesion and creates social and economic instability. It is incumbent on socially responsible corporations to contribute to rebuilding trust. A key means of doing this is through transparency and disclosure, including making it clear how an organisation contributes to society, enabling people to have access to accurate information to inform their own views on issues.
Transparency principles of responsibility, openness, fairness and accountability are underpinned in our DNA. We continue to exhibit the highest levels of transparency principles .
Water stewardship in such a case is not only critical to our operated assets but is central to the resilience of the communities where we operate and the environment. Greater transparency around water requirements and usage will help governments, industry and communities work together to safeguard our water supplies for future generations.
Our Ethics and Compliance programme
Our Ethics and Compliance programme encompasses risk assessments, policies and procedures, training and awareness, monitoring, speaking openly and investigations. We work with experts to ensure our programme aligns with international best practice, taking guidance from relevant authorities. 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.
Our leaders are responsible for creating a culture where ethical behaviour is encouraged. Integrity is one of our key elements, meaning that across the business, we have the courage to do what’s right, even when it’s hard.
Governance of our code
Sierramin Bauxite expects all employees to act in accordance with our Values, Code of Conduct and policies, regardless of role or location.
Sierramin Bauxite takes breaches of our Code of Conduct and policies seriously. Anybody working for Sierramin Bauxite who breaches the Code of Conduct, policies, procedures or the law may face disciplinary action, including dismissal.
We regularly monitor and test the implementation of our Ethics and Compliance programme in order to determine its effectiveness, and that it is operationalised and embedded into business operations. The monitoring activities also enable us to identify opportunities for improvement that help develop and evolve the programme and respond to changes in our business, the environments we operate in and applicable laws and regulations.
Our Annual Monitoring Plan comprises on-site and desktop reviews. On-site reviews are visits to our offices and/or industrial assets to assess the implementation of our Ethics and Compliance programme. In light of the Covid-19 outbreak, these reviews have been performed remotely. Desktop reviews focus on the analysis and transaction testing of either compliance processes and controls or other processes, systems and controls that the Monitoring team can access centrally.
Our Ethics and Compliance programme is carefully designed to assess and manage various risks, such as bribery and corruption as well as sanctions.
To manage our bribery and corruption exposure associated with our business partners, we implement a range of controls and processes, including anti-corruption training, using a risk-based approach. All high-risk business partners, such as business developers, lobbyists, consultants or advisers interacting with public officials on our behalf are required to complete an annual e-learning on anti-corruption. In addition, business developers also receive in-person anti-corruption training.
Our Sanctions Policy sets forth Glencore’s approach to ensuring that we fully comply with all sanctions, trade controls and anti-boycott laws applicable to our business activities and that we appropriately manage associated risks. We do not participate in transactions or engage in conduct designed or intended to evade or facilitate a breach of applicable sanctions. Our Sanctions Procedure outlines the specific steps we take to ensure compliance.
Training and awareness of our compliance policies and procedures, as well as strong leadership, are critical components of our Ethics and Compliance programme. They ensure our employees and contractors understand the behaviour expected of them and provide guidance on how they can identify and practically approach ethics and compliance dilemmas in their daily work.
Our new joiners receive new employee compliance training and we provide mandatory ongoing training for all employees on a range of compliance risks and issues they may be confronted with in their roles. For those employees and contractors who do not have regular access to a work computer, we provide training in other ways, including induction sessions, pre-shift training and toolbox talks. In addition, Compliance facilitates awareness raising campaigns about compliance risks to educate employees on expected behaviours.
We are committed to creating a culture where everyone feels free to speak about concerns securely and confidentially. That includes employees, contractors, directors and officers working in our offices and industrial assets, as well as third parties such as customers, suppliers or other stakeholders.
Employees and contractors are encouraged to first report concerns to the relevant managers or supervisors at their office or industrial asset since they are usually best equipped to resolve concerns quickly and effectively.
We do not tolerate retaliation against anyone who speaks openly about conduct they believe is unethical, illegal or not in line with our Code of Conduct and policies, even if the concern doesn’t turn out to be substantiated, and as long as it is not raised knowing it is false.
Bauxite mining is a long-term business. In addition to delivering the metals and minerals that power our global economy, we believe our business can make a lasting, positive impact beyond shareholder value. Our sustainability approach starts with building and maintaining respectful relationships with the communities and governments that host our operations.
Mitigating and managing the inherent risks in our business is critical to our success, more importantly to our stakeholders’ wellbeing. We are committed to the responsible management of resources such as land, air quality, water and biodiversity, as well as putting the health and safety of our people first.
Sierramin’s policies and standards support these efforts and guide our performance. In addition, we voluntarily participate in organizations and initiatives that provide a framework for action, a means for independently measuring our performance and a forum to learn and share best practices.
Our systems also ensure effective health, safety, community relations and environmental protection processes are in place at all Sierramin operations. In previous years, we have assessed our site-based management systems using ISO 14001 (environment) and OHSAS 18001 (health and safety) standards.
