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Training and awareness

Ethics and Compliance

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 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

    40307

    95.8% completions
    (36,302 in 2021)

    Covers: Glencore’s expectations on how to do business safely, responsibly, ethically and legally.

  • Conflicts of interest

    40334

    95.3% 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

    23469

    99.1% completions
    (22,379 in 2021)

    Covers: facilitation payments, gifts and entertainment, and dealings with public officials.

  • Sanctions

    10299

    98.4% 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

    17211

    99.2% 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

    405

    100% 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

    3815

    in 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

    258

    in 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

    191

    in 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
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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.

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