The United Nations Guiding Principles (UNGPs) have three requirements for companies to demonstrate that they are fulfilling their responsibilities. We meet these requirements as follows:
Express a commitment to human rights through a policy statement.
Glencore’s commitment to human rights is stated in our Code of Conduct, which is clearly communicated to all employees and contractors.
Perform human rights due diligence to identify, prevent, mitigate and account for potential human rights breaches.
Our operations conduct risk assessments at key phases of their lifecycles. The assessments may cover issues related to labour and workplace, use of security, our business partners, and interactions with stakeholders and vulnerable people. The risks are logged in the operational risk register; progress in addressing them is reported to senior management and the Board as appropriate.
In dealing with our business partners, we expect that they meet the requirements of our Code of Conduct and Group human rights policy. In particularly sensitive cases, such as in the selection and appointment of security contractors for our assets, we review their backgrounds to ensure they have no history of involvement in human rights breaches.
Provide remediation where business enterprises are identified as having caused or contributed to breaches of human rights.
We expect our people to avoid complicity in human rights breaches and to uphold international standards at our assets, regardless of location or function.
Security and human rights
Our Group human rights policy requires our assets to conduct risk assessments for conflict and security concerns. If these risks are identified, our assets must align their practices with the Voluntary Principles.
In March 2015, we were admitted to the Plenary Group of the Voluntary Principles on Security and Human Rights.
Our Voluntary Principles activities
At these assets, we have worked to:
- Establish a formal agreement with private and public security providers, which states our expectations for the conduct of personnel deployed at our assets and agrees a mechanism for incident investigation and escalation
- Develop a locally-appropriate approach to training for all security personnel, to ensure understanding of international human rights standards and our expectations for their conduct (this may be carried out by our personnel or via third parties with a mandate to engage with local peacekeeping forces, and will typically address issues such as use of force, use of equipment and conduct in situations of public unrest)
- Implement ongoing performance monitoring through supervision by our security staff and regular meetings with host communities to identify and discuss any concerns
- Track the human rights record of any potential partner, including public security forces, paramilitaries, local and national law enforcement, and private security firms; and consult with other companies, government officials and wider civil society to share their experiences with private security firms
We developed guidance for this process in 2014, covering deployment, conduct and performance monitoring for both public and private security providers. We have distributed the guidance to our security, compliance and community relations departments to be used as a master checklist; individual assets may need to include additional measures depending on their local conditions. The guidance specifically requires assets to report any concerns with public security providers to the appropriate local authorities, and to collaborate with any subsequent investigation.
Further to this, in 2015 we reviewed our Group risk framework to reflect the risk of security-related human rights abuses. To ensure responsible security management is embedded in our broader efforts to respect human rights, we have also reviewed our grievance mechanism design across the Group to ensure these mechanisms are fully accessible to local communities.
Working with our business partners
The standards we expect of our suppliers are detailed in our Code of Conduct, global anti-corruption policy and Group human rights policy. These comply with the ICMM principles and international standards including OHSAS 18001, the ILO conventions and the UNGPs
Safeguards for public and private security providers
Our assets consult regularly with their host governments and local communities about the impact of their security arrangements. We also monitor private security providers to ensure they operate in a manner consistent with our standards.
While some of the countries where we work have a higher risk of security-related human rights breaches, we expect our people to avoid complicity and uphold international standards everywhere. If security risks are identified, we screen our security contractors’ human rights performance and their ability to comply with our policy. We also ensure we have contracts that reference the Voluntary Principles, and memoranda of understanding that state our commitment to upholding human rights.
Engagement with vulnerable groups
Some of our stakeholders have faced economic and social discrimination in the past. These may include indigenous people, women, children, disabled and elderly people, and victims of conflict. Wherever we operate, we look for these groups during our stakeholder assessments and determine the most appropriate ways to engage with them. We try to understand and respect their religious, cultural and social concerns, and identify opportunities for their inclusion and advancement.
Engagement with indigenous people
Some of our assets are located on or near the traditional lands of indigenous people. We have formal agreements at a number of these, including indigenous land use agreements (ILUAs) in Australia and impact benefit agreements (IBAs) in Canada. Wherever we work, we engage in open and continuous dialogue with indigenous communities to understand their culture, views and aspirations. This helps us work with them to minimise our impact and maximise the benefit we bring to them. Our policy and approach are aligned with the ICMM Position Statement on Indigenous People and Mining
Managing grievances and complaints
We require our assets to operate grievance mechanisms, to receive and address concerns from external stakeholders. Depending on the location and context of the asset, these mechanisms may range from informal complaints channels to formal dedicated grievance mechanisms. Channels for communication include dedicated phone lines, complaints registers at public places, SMS hotlines and the offices of assets in local towns. Where necessary, complaints are recorded with witnesses present, as are the results of investigations.
Group guidelines for consistency
In 2015 we reviewed our grievance mechanisms to ensure consistency and alignment with the UNGPs. As a result, we created internal guidelines on the general principles and specific considerations that assets must consider when designing or reviewing a grievance and complaints mechanism. The guidance focuses particularly on accessibility, and local stakeholders’ awareness of the mechanism, as well as the reporting and investigation of all complaints.
The sophistication and formality of each grievance mechanisms is determined by a risk assessment that considers dimensions such as existing legal frameworks in the area of operation and existing or future operational impacts on host communities.
We seek to avoid resettlement wherever possible. When it cannot be avoided, we proceed in accordance with the International Finance Corporation (IFC) Performance Standard 5: Land Acquisition and Involuntary Resettlement. Throughout, our priority is to ensure that all affected stakeholders have full participation. Following any resettlement, we seek to ensure the communities involved can maintain productive livelihoods through ongoing monitoring.