Introduction
Glencore is exposed to a wide range of compliance risks across its operations, including in relation to corruption and bribery, conflicts of interest, fraud, sanctions and trade controls, money laundering, competition law, market conduct and data protection. To address these risks, the Ethics and Compliance Programme includes a set of policies, standards, procedures and guidelines, as well as internal Compliance manuals.
Several other policies, standards and procedures which support our Programme are issued by corporate functions other than Group Compliance.
Our policies are publicly available on our website: https://www.glencore.com/who-we-are/policies.
-
Anti-corruption and bribery
Our Anti-Corruption and Bribery Policy is clear: the offering, providing, authorising, requesting or accepting of bribes is unacceptable, and we do not engage in corruption or bribery, including making facilitation payments. We assess corruption risk within our businesses and work to address these risks through policies, standards, procedures and guidelines on various topics.View more -
Conflicts of interest
Our Conflict of Interest Policy requires that we always act in Glencore's best interests and that we try to avoid actual, potential or perceived conflicts of interest. We take steps to manage conflicts and reduce the risk they present.View more -
Fraud
Our Fraud Policy sets out our approach to prohibiting and preventing fraud, informs employees of the types of activities that are considered fraudulent, and sets out employees' obligations to prevent and report fraud.View more -
Sanctions and trade controls
Our Sanctions Policy sets out our commitment to complying with all applicable sanctions and restrictive measures and we generally adhere to United States, European Union, United Nations and Swiss sanctions throughout our business, whether or not we are legally required to do so.View more -
Anti-money laundering
Our Anti-Money Laundering Policy sets out our approach to ensuring that we comply with all applicable laws and regulations to prevent money laundering and the facilitation of tax evasion, and appropriately manage the related risks.View more -
Competition law
Our Competition Law Policy sets out our approach to competing vigorously, but fairly and legally.View more -
Market conduct
Our market conduct compliance framework is centred on our Market Conduct Policy, which articulates our expectations of our employees with respect to market conduct issues.View more -
Data protection
Our Information Governance Policy forms the foundation of our Information Governance and Data Protection Framework. It defines our approach to managing personal data and other types of information responsibly.View more
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.