Ethics and human rights
Ethics
Eight areas of conduct, each governed by one of our Group policies.
What this covers
Eight policies within the suite set our integrity requirements. Together they cover bribery and corruption, money laundering, sanctions and trade controls, competition, fraud, conflicts of interest, political engagement and tax. Each states the principles that apply, the standards it is structured against, and the functions accountable for it.
Key facts
Facilitation payments
Facilitation payments are prohibited without exception.
Financial intermediary status
We are not a financial intermediary; the due diligence duties that apply to financial institutions do not apply to us.
Reporting thresholds
Country-by-country reporting and minimum-taxation duties apply only above thresholds we do not meet.
Minerals due diligence
Minerals due diligence follows the OECD five-step framework.
The eight areas
Responsible sourcing
We take social, ethical and environmental considerations into account in procurement decisions and in supplier relationships. We require suppliers to meet our standards and to cascade them through their own supply chains, and our Supplier Code of Conduct sets the minimum, covering human rights, labour rights, health and safety, environmental protection and business integrity. Minerals due diligence follows the five-step framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: management systems; risk identification and assessment against the Annex II risks; risk management; independent third-party audit at identified points in the chain; and reporting. Where a supplier uses an unauthorised subcontractor, we investigate and require full disclosure and corrective action. Where remediation fails, we may suspend or terminate the relationship.
The reference standards
Our integrity policies are structured against the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the UN Convention against Corruption and the relevant ISO reference standards, and we use the GRI topic standards as references for how we organise the corresponding information. We hold none of the certifications named.
Raising a concern
Employees, suppliers, communities and any other party may raise a concern through the confidential reporting channels. We provide for anonymous reporting and prohibit retaliation against anyone who raises a concern in good faith.
