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Board oversight and governance

Ethics and Compliance

Our Board of Directors plays a critical role in overseeing and assessing Glencore’s culture of ethics and compliance, and ensuring policies and practices are consistent with our values. Our Board has established a separate committee, the Ethics, Culture and Compliance Committee (ECC), dedicated to overseeing and approving key ethics, compliance and culture-related matters within the Group. 

We provide training to the Board of Directors which emphasises their role in monitoring and implementing an effective ethics and compliance programme. Furthermore, the ECC receives regular updates on the programme which cover all topics such as the compliance team structure, status of risk assessments, policies, standards, procedures or guidelines under development or review, updates on training and awareness activities, overview of monitoring visits and key findings.

The Board also receives regular updates on the programme through the various committees. These updates cover all focus areas, including anti-corruption and sanctions, and topics such as the compliance team structure, status of risk assessments, and policies and procedures under development. Updates also cover training and awareness activities, overviews of monitoring visits and key findings, material investigations and reports received via our Raising Concerns programme. 

The following management committees support the implementation of the ethics and compliance programme and report to the Board

Environment, Social and Governance Committee (ESG)

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

Business Approval Committee (BAC)

The Business Approval Committee (BAC), comprises Glencore’s CEO, CFO, General Counsel, Head of Sustainable Development and other relevant corporate or business heads as required. The BAC, a sub committee of the ESG, determines, sets guidance and criteria, and reviews business relationships, transactions or counterparties that give rise to ethical or reputational concerns.  

Raising Concerns Investigations Committee (RCIC)

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