We develop and maintain constructive relationships with the governments of our operating countries. Whenever we engage with political parties – directly or indirectly – on matters that affect Glencore, our people or our communities, we do so openly, transparently and legally.
We only engage in the political process for legitimate business objectives and in compliance with applicable laws. We engage transparently, and we do not seek to influence the political process by improper or corrupt means.
Responsible political engagement is critical for maintaining trust in the political process and ensuring that legitimate points of view are heard by public decision makers in order to support effective policy decisions in the interests of all stakeholders.
Glencore and political contributions
As a business, we do not favour any political party, group or individual. We do not permit any funds or resources to be used to contribute to any political campaign, political party, political candidate or any politically affiliated organisation.
We do not:
- use Glencore funds to attend or otherwise support political fundraisers;
- provide Glencore premises for an organised party political event;
- use Glencore facilities to publish, reproduce or distribute political messages;
- use Glencore working time or other resources for political activity (unless applicable law entitles us to time off for political duties, and Glencore has agreed to pay for this time), or
- even where permitted to do so by local law, set up corporate political action committees to raise and spend money for political purposes.
These prohibitions do not prevent us from using Glencore resources to support state-led initiatives such as business forums.
Our people may make personal political contributions and be involved in political activity in their own time. However, when doing so, they must not give the impression that they are doing so on behalf of Glencore.
Engaging in the political process
We occasionally engage in public policy debates on subjects of legitimate concern to our business, employees, customers, suppliers, end users and the communities in which we operate.
All Glencore lobbyists, both employees and third parties acting on our behalf must:
- disclose, when making representations for Glencore:
- that they are acting on Glencore’s behalf, and
- the purpose of the representations
- not make representations inconsistent with Glencore’s Values and Code of Conduct, and our positions on material issues
- must comply with all relevant Glencore policy and procedural requirements and applicable legislation, including registering and reporting requirements
- not make misleading or inaccurate statements in their representations on behalf of Glencore
- not seek to influence the political process by unfair or corrupt means; and
- conduct themselves transparently, honestly and with integrity
We may from time to time engage in public policy debates on subjects of legitimate concern to our business, employees, customers, suppliers, end users and the communities in which we operate.
We participate in member organisations – such as trade, business and industry associations and groups – which may engage in lobbying or other public policy advocacy including making representations to public officials or government authorities.
We take steps to ensure that these organisations share the principles set out in our Values and Code of Conduct relating to transparent engagement with public officials and government authorities.
We regularly review the positions of our member organisations to understand the positions they adopt, acknowledging that many of them represent a range of members with different views across multiple policy areas, and therefore the representations they make may not always fully reflect Glencore’s position.
If they adopt positions that are not consistent with our position on material issues, we take appropriate action, which may include engaging with the Member Organisation or, if necessary, resigning from that Member Organisation.
Employing public officials
We do not, directly or indirectly, employ public officials to engage in political advocacy or lobbying on Glencore’s behalf.