Training and awareness
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. Training is also given to third parties in accordance with Glencore's Third Party Training and Monitoring Plan. Training requirements for third parties, including the frequency of training, vary according to the third party’s risk rating and include digital training as well as in-person anti-corruption and bribery training. Where relevant to their engagement, third parties are also enrolled in market conduct digital training.
Number of employees completing compliance e-Learnings in 2022*
* Audience: employees and contractors with regular access to a work computer, and in the case of the specific risk eLearnings, those employees and contractors who are, due to the nature of their roles, more exposed to conflict of interests, corruption and bribery or sanctions risks.
-
Code of Conduct
4030795.8% completions
(36,302 in 2021)
Covers: Glencore’s expectations on how to do business safely, responsibly, ethically and legally. -
Conflicts of interest
4033495.3% completions
(26,825 in 2021)
Covers: the different types of conflicts of interest, how to recognise conflicts, and what to do if they arise. The increase in training numbers is due to the inclusion of the entire audience in 2022.
-
Anti-corruption and bribery
2346999.1% completions
(22,379 in 2021)
Covers: facilitation payments, gifts and entertainment, and dealings with public officials. -
Sanctions
1029998.4% completions
(15,960 in 2021)
Covers: our approach to sanctions breach avoidance, due diligence of counterparties, and screening of vessels.
The drop in training numbers from last year is due to a more targeted, risk-based training approach.
-
Data protection
1721199.2% completions
Covers definition of personal data, key data processing principles and how we deal with data breaches
Number of employees completing spotting compliance red flags sprint in 2022
-
2562
98.7% completions
Covers: anti-corruption and bribery and sanctions/KYC red flags when dealing with business partners, reviewing contract terms, dealing with invoicing, or receiving or making payments to or from third parties.
Audience: employees especially exposed to anti-corruption and bribery risk, particularly traders and traffic personnel, as well as finance and accounting personnel involved in the review of payments, trade finance, and legal roles involved in the review of contracts
Number of employees completing market conduct sprints in 2022
-
Number of employees completing market conduct sprints in 2022
405100% completions
Covers: fundamental concepts of compliant market conduct and communications to raise awareness of how to spot potential market conduct red flags in trading activity and reinforce the need for clean and professional communications.
Audience: employees especially exposed to market conduct risk, particularly traffic, operations, risk and exchange trade executing personnel.
Number of employees attending in-person training on key compliance risks in 2022
-
Anti-corruption and bribery
3815in 329 sessions
Audience: employees and contractors especially exposed to corruption and bribery risks due to the nature of their role. Sessions tailored to employees in various functions using scenarios relevant to their roles. -
Market conduct
258in 71 sessions
Audience: employees especially exposed to market conduct risk, particularly traders and commodity benchmark contributors and employees communicating and dealing with price reporting agencies. Sessions tailored per commodity and topic in focus.
-
Speaking openly and raising concerns
191in 38 sessions
Audience: There were three key trainings targeted at our Whistleblowing Contacts, Lead Investigators and Case Owners and Local Concerns Administrators.
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
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.