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A message from our leadership

Dear stakeholders,

We recognise that ethical conduct is crucial to our operations. It protects the integrity of our business, safeguards the interests of our employees and partners, and underpins the value we deliver to our customers, shareholders and the communities where we operate.

Our Ethics and Compliance Programme is designed to deliver this Group-wide commitment and supports responsible and ethical decision-making at every level of the business.

In 2025, we announced that the US Department of Justice (DOJ) ended our two monitorships approximately one year early, following an assessment of the facts and circumstances of our case. This was an important milestone for the Group and is the culmination of extensive efforts over the last number of years to develop and implement the Ethics and Compliance Programme and make cultural, governance and control enhancements.  In 2026, the three-year term of the plea agreement with the DOJ officially concluded.

The Board and senior management are focused on ensuring we uphold responsible business practices and maintain an effective compliance programme. We remain committed to continuous improvement and ensuring that our Ethics and Compliance Programme is fit for purpose, particularly given the complex geopolitical environment in which we are currently operating.

  • Kalidas Madhavpeddi
    Chairman

  • Gary Nagle
    Chief Executive Officer

We are committed to maintaining a robust, risk-based Ethics and Compliance Programme that is tailored to our business.

We are focused on ensuring that our Ethics and Compliance Programme is operating efficiently and consistently and that it is appropriately tailored to our business needs. Our teams actively engage with the Board and senior leadership throughout the organisation regarding our vision for the Ethics and Compliance Programme and post monitorship priorities.

We recognise that our Ethics and Compliance Programme will not remain effective if it is static and that continuous improvement is required to support ongoing risk mitigation. The compliance landscape is also very dynamic, particularly in the current complex geopolitical environment, and an effective compliance programme needs to evolve in response to ongoing developments.

  • Shaun Teichner
    General Counsel

  • Nicola Leigh
    Head of Compliance

2025 performance dashboard

  • 40000+

    Number of Code of Conduct e-learnings completed
    99% completion rate

  • 697

    reports were recorded through the Raising Concerns Programme, the majority of which were HR-related concerns.

  • 798

    reports were closed, 311 of which were protected concerns within the scope of the Raising Concerns Programme and capable of investigation.

  • 1690

    New conflicts of interest declarations received

    for 1,540 of these, a management action plan was created or they were in the process of being reviewed and signed off.
  • 4776

    Know your counterparty approved for marketing counterparties

  • 12096

    Know your counterparty approved for industrial asset counterparties

  • 15

    Know your counterparty rejected for1 marketing counterparties

  • 21

    Know your counterparty rejected for1 industrial asset counterparties

  • 438

    Approved and active third parties that we continue to monitor in our marketing business

  • 1,611

    Approved and active third parties that we continue to monitor in our industrial business

  • 0

    Rejected third parties1 in our marketing business

  • 2

    Rejected third parties1 in our industrial business

  • 17

    JV's reviewed and approved2 under the process set out in our Joint Ventures, Mergers and Acquisitions, and Disposals Procedure

  • 2

    M&A transactions reviewed and approved2 under the process set out in our Joint Ventures, Mergers and Acquisitions, and Disposals Procedure

  • 9

    Disposals reviewed and approved2 under the process set out in our Joint Ventures, Mergers and Acquisitions, and Disposals Procedure

  1. This reflects rejections for compliance reasons following completion of the onboarding process. It does not reflect rejections where, following engagement between Compliance and the business, the onboarding process was not completed.
  2. Further internal approvals may be required following approval by Compliance, figures therefore may not correspond to the number of transactions implemented.

Important notice
This material does not purport to contain all of the information you may wish to consider. For further important information, including in connection with forward-looking statements and other cautionary information, refer to the Important notice section of Glencore's latest Annual Report, which is available at glencore.com/publications.