Glencore International believes that sustainability must be an integral part of everything we do. It is vital to good business conduct, and helps us meet both our own expectations and those of our stakeholders. We believe that operating sustainably also enhances our corporate reputation and forms part of our competitive advantage around the world. For this reason, we have put a corporate sustainability framework in place to balance social, environmental, ethical and commercial interests at every level of our group. This framework is called Glencore Corporate Practice, or GCP. We have designed and implemented GCP to meet internationally recognised, sector-specific, good practice standards. One of GCP’s principles is a commitment to compliance. Our position on the issues of bribery and corruption is clear: offering, paying, authorising, soliciting or accepting bribes is unacceptable to Glencore. Our principles, commitments and management approach are stipulated in our global anticorruption policy. If employees are concerned that any conduct or proposed course of action might be improper or in breach of any applicable laws or regulations, they must refer that concern to a member of our Business Ethics Committee (BEC) or the local compliance coordinator...Glencore is of the view that, in the context of the Glencore group as a whole, there have been no material breaches of any applicable laws or regulations. Our industrial operations must implement their own compliance programmes, designed to address their specific requirements, but consistent with our overall compliance commitment...Companies associated with Mr Gertler are investors in projects in which Glencore is also a shareholder. Auditing of Beneficial Interests Glencore does appropriate due diligence as required to ensure that it acts in line with its principles under Glencore Corporate Practice.