Sustainability
Ethics and human rights
The conduct standards that govern how we deal with governments and counterparties, and the respect we owe to the people affected by our activities.
What this covers
Two subjects sit together on this page because they answer the same question from two directions: what we may do, and what we may not do to others in doing it. Ethics covers bribery and corruption, money laundering, sanctions and trade controls, competition, fraud, conflicts of interest, political engagement and tax. Human rights covers due diligence, engagement with affected communities and with Indigenous peoples, the prevention of forced labour, child labour and human trafficking, non-discrimination, and access to remedy. Responsible sourcing sits across both, because a supply chain is where an integrity failure and a human rights failure most often arrive together.
The Code of Conduct sits above the policies in both areas and states the standards of behaviour to which everyone who represents Xstreco is held.
Key facts
Zero tolerance
Zero tolerance is a decision rule, not a slogan: it is the basis on which consequences follow.
Legal exposure
Our principal integrity exposure is Swiss criminal law and Peruvian corporate criminal liability.
Prevention model
We maintain a documented prevention model across the Group.
Whistleblower protection
Whistleblower protection in Switzerland derives from general employment law rather than from a dedicated statute.
The position stated plainly
We maintain a zero-tolerance position on corruption, fraud, discrimination, harassment and retaliation. That position is not aspirational language: it is the basis on which we assess conduct and on which disciplinary and legal consequences follow. We prohibit forced labour in any form, child labour and human trafficking without qualification, in our own activities and, through our Supplier Code of Conduct, in our supply chain.
Where we have caused or contributed to an adverse human rights impact, we provide for or cooperate in remediation.
The legal foundation
We hold ourselves to the criminal-law standards that apply to companies in Switzerland and in Peru, covering bribery, money laundering, fraud and trafficking, and our prevention arrangements are built to that standard, not to guidance. Money laundering connected with illegal mining is a standing consideration for any producer of precious metals, and our controls treat it as one.
Consequences
A breach of the Code, of one of our Group policies or of applicable law may result in disciplinary action up to and including termination of employment or of contract, and may result in civil liability or criminal prosecution. Failure to report known or suspected misconduct, and retaliation against a person who reports it, are themselves breaches of the Code.
In this section
Raising a concern
Employees may report a suspected breach to their manager, to a supervisor or through the confidential reporting channels. We provide for anonymous reporting under our Whistleblowing and Ethics Reporting Policy. External parties, including suppliers, counterparties, community members and human rights defenders, may report using the web reporting form or through the contact details set out in that policy. We handle reports confidentially and investigate them in accordance with our internal procedures and applicable law. We prohibit retaliation against anyone who makes a report in good faith or cooperates with an investigation, and such retaliation is itself a breach of the Code.
