Board oversight and governance
Our Board of Directors plays a critical role in overseeing and assessing our culture of ethics and compliance, and ensuring policies, practices and behaviour are consistent with our Values. Our Board has established a separate Ethics, Compliance and Culture (ECC) committee, dedicated to overseeing and approving key ethics, compliance and culture-related matters within the Group.
We provide training to the Board, emphasising to Directors their role in ethics and compliance oversight and programme implementation. Furthermore, the ECC committee receives regular updates covering 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, overviews of monitoring visits and key findings. Board members also receive updates on material reports that have come in via our Raising Concerns platform and the progress of 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 and Human Rights, and Head of Sustainability. It also includes senior members of executive management representing marketing and industrial assets across different commodities. The ESG committee 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 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 Sustainable Development and other relevant corporate or business heads as required. 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 and Head of Human Resources. The RCIC oversees the operation of our Raising Concerns Programme and the conduct of investigations, ensuring recommendations and sanctions are applied consistently across the Group.