Our Ethics and Compliance Programme
The Glencore Ethics and Compliance Programme
Key elements of our programme
Our Ethics and Compliance Programme includes various elements related to risk assessments, policies, standards, procedures and guidelines, training and awareness, advice, monitoring, speaking openly and raising concerns, investigations, and discipline and incentives.
Dedicated compliance IT systems and data analytics as well as various controls embedded in business systems support our Ethics and Compliance Programme.
The key elements of our Ethics and Compliance Programme establish a risk-based approach to ethics and compliance to address the challenges presented by our diverse business operations. Together, the elements create a feedback loop, designed to ensure that compliance risks are identified and addressed across our business on an ongoing basis.
Our Ethics and Compliance Programme has been designed with the support of external counsel and other advisors, having regard to the guidance from relevant authorities such as the US Department of Justice, the UK Ministry of Justice and the State Secretariat for Economic Affairs of Switzerland.
Our Ethics and Compliance Programme in action
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.