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Approach to key risks

Ethics and Compliance

Our Ethics and Compliance programme is carefully designed to assess and manage various risks, such as bribery and corruption as well as sanctions.

Bribery and corruption

Our Anti-Corruption Policy clearly documents our position on bribery and corruption: offering, providing, authorising, requesting or receiving bribes or facilitation payments is unacceptable. We analyse corruption risks within our businesses and work towards addressing these risks through policies and procedures, training and awareness and monitoring. 

Our approach

Political engagement

We do not permit any of our funds or resources to be contributed to any political campaign, party, candidate or any affiliated organisations. Although we do not directly participate in party politics, we sometimes engage in policy debate on subjects of legitimate concern to Glencore and our stakeholders. Anyone who lobbies on our behalf must comply with all applicable laws and regulations, including those relating to registration and reporting. 

Gifts and entertainment

We can only give and receive appropriate, lawful business gifts and entertainment in connection with our work, provided they satisfy the general principles of our Anti-Corruption Policy and are not given or received with the intent or prospect of influencing decision-making or other conduct. In some offices and assets we also have local approval procedures, which can include value thresholds and specific requirements for public officials. 

Third parties

For our third parties, in addition to our standard “Know Your Counterparty” programme, our Third Party Due Diligence and Management Procedure aims to ensure that any such high-risk engagements are in accordance with our Anti-Corruption Policy, applicable laws and regulations. The procedure sets out a detailed risk-based assessment process to identify, assess and mitigate the corruption risk exposure of high-risk third-party relationships, particularly intermediaries, joint ventures and service providers. It also requires, where necessary, ongoing monitoring and review of the relationships to ensure compliance with our Anti-Corruption Policy. 

Payments to governments

We report annually on our total payments to governments , and provide country-by-country and project-by-project information. Where applicable, we have aligned our reporting on such payments with the requirements of Chapter 10 of the EU accounting directive. 

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Participation in external anti-corruption organisations

We are a member of the Partnering Against Corruption Initiative (PACI). Members collaborate on collective action and share leading practice in organisational compliance. Members of PACI are committed to zero tolerance on bribery and implementation of practical and effective anti-corruption programmes. We are also an associate member of the Maritime Anti-Corruption Network (MACN). We actively participate in PACI and MACN’s annual events and have incorporated guidelines from both organisations into our procedures.

Interacting with Public Officials

In some high-risk jurisdictions where we operate, it is common for Public Officials to request small payments or other assistance in return for, or in connection with, the performance of their duties. 

There are situations where payments or assistance to Public Officials are lawful. However, in many circumstances, agreeing to provide payments or assistance to Public Officials in return for, or in connection with, the performance of their duties constitutes a Facilitation Payment, and is a breach of our policies and applicable laws.

Sanctions

Our Sanctions Policy sets forth Glencore’s approach to ensuring that we fully comply with all sanctions, trade controls and anti-boycott laws applicable to our business activities and that we appropriately manage associated risks. We do not participate in transactions or engage in conduct designed or intended to evade or facilitate a breach of applicable sanctions. Our Sanctions Procedure outlines the specific steps we take to ensure compliance.