Training on and awareness of our compliance policies and procedures, as well as strong leadership, are critical components of our Ethics and Compliance programme. They ensure our employees and contractors understand the behaviour expected of them and provide guidance on how they can identify and practically approach ethics and compliance dilemmas in their daily work.
Our new joiners receive new employee compliance training and we provide mandatory ongoing training for all employees on a range of compliance risks and issues they may be confronted with in their roles. For those employees and contractors who do not have regular access to a work computer, we provide training in other ways, including induction sessions, pre-shift training and toolbox talks. In addition, Compliance facilitates awareness raising campaigns about compliance risks to educate employees on expected behaviours.
How we train our business partners
To manage our bribery and corruption exposure associated with our business partners, we implement a range of controls and processes, including anti-corruption training, using a risk-based approach. All high-risk business partners, such as business developers, lobbyists, consultants or advisers interacting with public officials on our behalf are required to complete an annual e-learning on anti-corruption. In addition, business developers also receive in-person anti-corruption training.
Number of employees completing compliance e-Learnings in 2020*
Code of Conduct
Covers: Glencore’s expectations on how to do business safely, responsibly, ethically and legally
Conflict of interest (new training in 2020)
Covers: the different types of conflicts of interest, how to recognise conflicts, and what to do if they arise
Anti-bribery and corruption
Covers: facilitation payments, gifts and entertainment, and dealings with public officials
Covers: our approach to sanctions, due diligence of counterparties, and screening of vessels
Audience: employees and contractors with regular access to a work computer, and in the case of the specific risk e-Learnings, those employees and contractors who are due to the nature of their roles more exposed to conflict of interests , bribery and corruption or sanctions risks.
* The 2020 e-Learning completion numbers have reduced due to the carve-out of the agriculture business Viterra (formerly Glencore Agriculture), which is now managing its own independent compliance programme with oversight from its shareholders including Glencore.
Number of employees attending in-person training on key compliance risks in 2020
Anti-bribery and corruption (in 277 sessions)
Audience: employees and contractors especially exposed to bribery and corruption risks and whose role may require them to interact with third parties. Sessions tailored to employees in various functions using scenarios relevant to their roles
Anti-bribery and corruption / Sanctions / Money laundering red flags (in 19 sessions)
Audience: senior marketing office employees especially exposed to bribery and corruption, sanctions and money laundering risks. Highly interactive sessions on how to identify red flags. Case studies focused on how these key risks might present themselves in real situations and how to mitigate exposure
We tailor our training and awareness materials and make them relevant by including hypothetical scenarios illustrating how ethics and compliance dilemmas might manifest themselves in daily work activities.
We also train and develop our own compliance personnel to increase their understanding of key compliance risks and important developments.
Ethics and Compliance Days at Glencore’s headquarters in Baar, Switzerland, emphasise how we all - leaders in particular - play a critical role in promoting and ensuring a culture of ethics and compliance. The aim of this event is to shine a light on the importance of ethics and compliance at and for Glencore and to raise awareness in a way that supports not just abiding by specific rules and regulations, but also achieving a corporate culture of ethics and compliance.
Raising awareness - Ethics and Compliance Days
Raising awareness - Ethics and Compliance Days
The Singapore office held an Ethics and Compliance day to raise awareness on key Compliance risks and emphasise how we all play a critical role in promoting and ensuring a culture of ethics and compliance.
To mark the United Nations Anti-Corruption Day, on 10 December 2020, in collaboration with the newly created Congolese Anti-Corruption Agency (l’Agence de Prévention et de Lutte contre la Corruption – APLC), the Mining Chapter of Congolese Federation of Companies (FEC) and La Société Générale des Carrières et des Mines (Gécamines), Glencore sponsored an ethics and compliance conference in Kinshasa, Democratic Republic of the Congo (DRC).
The objective of the event was to bring together key stakeholders from business, government, and non-governmental organisations to discuss their experiences and approach to anti-bribery and corruption in the DRC. We introduced the audience to our Ethics and Compliance programme, our Values, and Code of Conduct, including our approach to anti-bribery and corruption and conflicts of interest. The panel included representatives from Gécamines, the FEC, and Glencore and closing remarks by the newly appointed Head of the APLC.
The Compliance Summit is an event organised by Corporate Compliance, which takes place at Glencore’s headquarters in Baar, Switzerland, over the course of two days . This Summit provides guidance to our Compliance Coordinators and Regional Compliance Officers, as well as training on the key compliance risks. The goal of this event is to help our Group Compliance members understand the importance of their role, in addition, to providing an opportunity to interact with fellow Glencore Compliance colleagues across the globe.