Sustainability at Glencore is overseen at the highest level, by our Board health, safety, environment and community and human rights (HSEC) committee.
Our HSEC risk management framework provides a standardised approach to identifying, assessing and managing HSEC risks and opportunities.
Our sustainability framework is the primary vehicle for the collection and reporting of sustainability risks, opportunities and performance to inform our business strategy. Our approach to integrating sustainability throughout our business has clearly deﬁned imperatives, objectives, priority areas and targets. It supports meeting legislative requirements, managing the catastrophic hazards associated with our business, and maintaining our societal licence to operate.
We focus our approach through four pillars: health, safety, environment, and community and human rights.
Our Board Health, Safety, Environment and Communities (HSEC) Committee sets the strategic direction for our sustainability activities and oversees the development and implementation of our strategic health, safety, environment, community and human rights (HSEC&HR) programmes.
Oversight and ultimate responsibility for our Group sustainability strategy and framework as well as its implementation across the Group rests with our senior management team. They take a hands-on approach to the management of sustainability activities across the Group. Our sustainability team provides guidance and thought leadership.
In the event of a fatality or a major or catastrophic incident, the HSEC Committee reviews the incident investigation, its findings and next steps, working with the management of the mine and Group senior management. The information they receive covers the nature of the incident, details of subsequent investigations and the actions taken.
KPIs and executive remuneration
In 2021, we updated our remuneration policy to better align executive director compensation with the interests of our shareholders. This provides that executive directors may not sell any after-tax vested shares under our restricted share plan until two years after retirement, a first among major UK-listed companies.
As part of this policy, 30% of our chief executive officer, Gary Nagle’s, annual bonus will include KPIs relating to HSEC matters - 15% for safety performance and 15% for progress towards our medium-term absolute emission target. In addition, Mr Nagle’s long-term incentive includes a comprehensive underpin focused on a holistic review of the overall business and ESG performance.
To emphasise the importance of sustainability within Glencore, sustainability-related KPIs are applied to our asset-level management as our assets have the greatest opportunity within our business to introduce and drive meaningful improvements in sustainability performance.
At every level of the Group, our approach is one of sustainability risk management. Our sustainability risk management framework is aligned with global standards, and helps identify hazards and ways to eliminate, manage or mitigate them.
We fully integrate risk management into our business planning and decision-making processes. We require assets to provide resources and training on our risk management processes for both employees and contractors. Our Group HSEC and human rights team provides detailed risk management guidance and our HSEC audit team audits catastrophic and fatal hazard management plans. They also sign off on the sustainability aspects of the Group risk management framework.
Our sustainability assurance processes support the management’s assessment of risk and provide assurance on the key mitigation controls.
Our processes have three elements:
1. General risk management: throughout the Group, we use our risk management framework to identify hazards, particularly those with potentially major or catastrophic consequences, and to develop management plans for the related risks.
2. Self-assessments: our assets complete annual self-assessments against Group sustainability policies, standards and fatal hazard protocols. We use the results to drive performance and to identify gaps. As part of our annual sustainability data audit, our external auditor checks the work at a number of assets for data accuracy and policy compliance.
3. HSEC (Health, Safety, Environment and Communities) auditing: our HSEC Assurance Policy specifies HSEC auditing activities at both Group and departmental levels and focuses on catastrophic hazards.
Sustainability audit programme
Our audit programme primarily focuses on assessing our management of catastrophic hazards across our business. Our Group HSEC audit function is separate from our other business functions and delivers auditing of our catastrophic hazard management on an arms-length basis. It includes internal and independent subject matter experts that follow up and verify findings.
The audit team’s programme evaluates the effectiveness of our sustainability risk identification, assessment and management, as well as our dissemination of information on risks, controls and best practice across the Group. Every three years an independent third party reviews the programme.
We also undertake multi-disciplinary assessments. These allow us to audit complex issues from a range of viewpoints and support a more robust appraisal. These assessments are suitable for reviewing different operational conditions and activities with varying risk factors, such as underground operations (which may include strata control, fire and explosion, power), open pit mines and metal processing plants.
The Board HSEC committee reviews the results of all HSEC audits, together with key findings, observations and good practice. The Board receives a quarterly report that monitors the progress of closing out the corrective actions.
Each department implements their own internal and external auditing, covering areas such as catastrophic hazards, fatal hazard protocols, HSEC policies, legal, compliance and HSEC data. Audit activities are planned, risk-based and developed specifically for the needs of each asset or project.
Sustainability at independently operated joint ventures (JVs)
Independent management teams operate our non-controlled JVs. Along with our JV partners, we participate in board shareholder committees that take key strategic decisions and we use this participation to influence the independent management teams to adopt appropriate operational and governance standards that reflect those of Glencore and the other JV partners.
We develop constructive relationships with the national, regional and local governments of our host countries, and maintain regular dialogue with them.
We may do this individually, collectively with other organisations, or as part of an industry association. Regular contact allows us to plan for regulatory changes and better react to them.
We foster public dialogue and contribute to the development of sound laws and regulations in areas that affect our business. In all dealings with governments, we work to the highest ethical standards.
We engage with regulators at all levels of government through regular meetings, audits and site visits. Our operations engage with regulators on topics that included mine expansion permits, site-specific environmental regulations and demonstrating compliance with applicable laws and regulations.
As we rely on the application and assurance of our own HSEC management framework, we do not insist that our assets undergo third party ISO 14001 or OHSAS 18001 certiﬁcation and we do not use external certiﬁcation as an indicator of performance.
Some of our sites undertake third party ISO 14001 and/or OHSAS 18001 certiﬁcation where there is an external requirement, or where it provides additional value to our business, customers or other stakeholders.