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Responding department: Sustainability

Stock Exchange Symbol: (GLEN:LN)

Update 2016: Please see the 2015 SD report

Does your company have a publicly available commitment to respect human rights?

Yes (stand-alone human rights policy): [link]

Our Code of Conduct addresses our commitments with regard to suppliers, contractors and host communities.  It also addresses our commitment to uphold human rights.  The Code is currently under review; the current version can be found here: [link]

How are human rights governed in your company?

Respect for human rights is core to Glencore’s business.  We are committed to providing a safe and secure workplace within a framework that ensures respect for human rights and fundamental freedoms.  This approach is enshrined in our Code of Conduct, and upheld across our organisation.

Oversight of human rights issues is conducted by the Board Health, Safety, Environment and Community (HSEC) Committee, which is led by Peter Coates and its other members include our Chairman, Tony Hayward, CEO, Ivan Glasenberg and Patrice Merrin. The Board HSEC Committee has overall responsibility for human rights across the Glencore Group. Operational support and implementation oversight is provided by the Group Sustainability Department through ongoing engagement, guidance and site-based assurance.  Responsibility for day-to-day implementation is core to site and departmental management’s responsibilities.  All operations are required to have grievance mechanisms in place to enable external stakeholders to raise concerns, and to alert the operation to emerging issues.

How are human rights managed within your company?

In accordance with the Glencore Human Rights Policy, all operations conduct a human rights risk assessment to identify most significant potential negative impacts and mitigation measures.  Our Human Rights Policy provides guidance on these measures, and ensures the risk assessments are aligned with relevant international standards.  

The Glencore Human Rights policy requires that all suppliers, contractors and other partners be made aware of Glencore’s commitments in this area, and that appropriate programmes be developed to ensure alignment.  For instance, operations employing security contractors in countries with a high risk of human rights-related security abuses are required to conduct background checks on contractor personnel for any past incidents of human rights violations.

Glencore operations engage with staff and business partners to raise awareness of human rights and ensure alignment with its standards.  This can take the form of direct human rights training to employees and contractors, or partnership with appropriate international organisations where direct training may not be possible, as in the case of the Democratic Republic of Congo, where we partner with UN local entity MONUSCO to raise awareness of human rights issues amongst police officers operating at our concessions.

Our operations are required to have grievance mechanisms in place to enable stakeholders to voice concerns.  These mechanisms allow us to assess the effectiveness of our systems, and to take corrective action where needed.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Glencore’s Community & Stakeholder Engagement policy requires stakeholder mapping, needs analysis and engagement strategies to be developed at all operations.  This is done through ongoing dialogue with both individual and community groups, regarding both the operations’ direct impacts on host communities, and broader concerns.  In areas identified as having a high-risk for human rights, the dialogue process also addresses human rights issues, and security managers attend all community meetings to understand any potential negative impacts on host communities.  

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including workplace health & safety, prevention of pollution)
  • Workplace diversity / non-discrimination
  • Sexual harassment
  • Freedom of association and trade union rights
  • Displacement and community relocation
  • Access to water
  • Freedom of expression and/or right to privacy / digital rights
  • Relations with security forces
  • Transparency in payments to governments / responsible tax practices
  • Women
  • Children (including child labour)
  • Indigenous peoples

Glencore reports publicly on its efforts to uphold human rights, including with regard to the issues listed above.  The 2013 report is available on our website: [link]

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

 Glencore is committed to transparency and constructive, open engagement with civil society.  We report on our progress annually in our Annual Report and the Sustainability Report, both of which can be found on our website: [link] Our sustainability report is translated into French, German and Spanish, the key languages in our operating regions, allowing the majority of our stakeholders to receive information on our approach and performance in their local languages. We also detail our approach to key topics, such as human rights, or significant regions, such as Africa, on our website.  We are active in finding opportunities for engaging with NGOs, governments and other stakeholder groups – we operate an open-door policy for all of our stakeholders.  To this end, we have invited a number of critical stakeholders to visit our assets and to speak to our people operating on the ground. Our responses to significant queries and/or publications regarding our operations are also available publicly.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

As stated previously, the Glencore Human Rights policy requires all operations to have a grievance mechanism in place that is aligned with the criteria articulated in the UN Guiding Principles.  

All employees are encouraged to raise concerns with their senior managers, or those managers in human resources, legal, sustainable development or corporate affairs. In addition, each site has a compliance officer, whose contact details are made available.

Alternatively, there is a number of ‘raising concerns’ channels, which allow individuals to report issues via email, via the internet or through a free-of-charge phone number, which is answered in the local language. All queries raised via these channel are reviewed and assessed promptly. The confidentiality of those raising concerns is respected. An individual’s identity is only shared where absolutely necessary, or is required by the law.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

Glencore believes that multi-stakeholder dialogue is an effective way to share knowledge and learnings and to improve operational practices.  

In May 2014, Glencore was admitted to the membership of the International Council on Mining & Metals, an industry trade body dedicated to sustainable development.  Glencore is also a signatory of the UN Global Compact, and a supporting company of the EITI.  We have applied for membership of the Plenary Group of the Voluntary Principles on Security and Human Rights.  

Our commodity businesses and regional teams participate in a number of industry and commodity organisations as well as playing an active role in local and regional groups.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

Following the acquisition of Xstrata in May 2013, Glencore developed a suite of policies addressing all material aspects of sustainability, including policies on human rights and community engagement.  These policies were developed in consultation with internal experts, and also with reference to international standards.  The human rights policy in particular, was developed in alignment with the UN Guiding Principles including, for instance, the UNGPs’ recommendation that the position on this topic be made publicly available.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

We are committed to making a positive contribution to socio-economic growth and sustainable development in countries where we operate.  This includes the respect for and protection of human rights.  We look forward to the continued cooperation between governments, civil society and business under the auspices of the United National Guiding Principles on Business and Human Rights to promote awareness of human rights and develop solutions to shared challenges.