Approach to key risks

Our Ethics and Compliance Programme is carefully designed to assess and manage various risks, such as bribery and corruption, market conduct, as well as sanctions. See our latest Ethics and Compliance Report at glencore.com/publications for further information.

Our Anti-Corruption and Bribery 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. 

As per our Market Conduct Policy, market conduct rules and regulations are designed to safeguard the trust in, and integrity of, both financial and related physical markets and thus promote efficient and transparent markets. We operate in different jurisdictions and trade on both regulated markets and over the counter, in both commodity derivatives and physical commodities. We are committed to complying with all applicable laws, regulations and rules related to Glencore’s activities and behaviour in the physical and commodity derivative or related financial markets.

Our Sanctions Policy sets out our commitment to complying with all applicable sanctions and restrictive measures and and we generally adhere to United States, European Union, United Nations and Swiss sanctions throughout our business. We do not participate in transactions designed or intended to evade or facilitate a breach of applicable sanctions or restrictive measures.