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Board and management oversight and governance

Ethics and Compliance
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Our Board of Directors plays a critical role in overseeing and assessing our culture of ethics and compliance, and ensuring policies, practices and behaviours are consistent with our Values. Our Board has established a separate Ethics, Compliance and Culture (ECC) Committee, which is responsible for overseeing our Ethics and Compliance Programme and approving key ethics, compliance and culture-related matters within the Group. The ECC Committee receives quarterly updates on our Ethics and Compliance Programme's implementation, including compliance risks and how they are managed, and on compliance resources. The Board separately receives quarterly updates on whistleblowing and investigation processes, and material internal and external investigations. 

The following management committees also support the implementation of our Ethics and Compliance Programme and report to the Board:

  • The Environment, Social and Governance (ESG) Committee, comprises Glencore’s CEO, CFO, Head of Industrial Assets, General Counsel, Head of Compliance, Head of Human Resources, Head of HSEC&HR, Head of Corporate Affairs, and Head of Sustainability. It also includes senior members of management representing marketing and industrial assets across different commodities. The ESG Committee reviews and considers the various ESG issues, programmes and projects implemented across the Group. It also reviews and approves policies, standards, procedures, systems and controls relevant to the corporate functions.

  • The Business Approval Committee (BAC), a sub-committee of the ESG, comprises Glencore’s CEO, CFO, General Counsel, Head of Corporate Affairs, Head of Sustainability and, where applicable, heads of departments and corporate functions. It determines, sets guidance and criteria, and reviews business relationships, transactions or counterparties that give rise to ethical or reputational concerns.

  • The Raising Concerns Investigations Committee (RCIC), comprises Glencore’s CEO, CFO, General Counsel, Head of Industrial Assets, Head of Human Resources and the Head of Compliance. The RCIC oversees the operation of our Raising Concerns Programme and the conduct of investigations, and is tasked with ensuring recommendations and sanctions are applied consistently across the Group.

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