Approach to key risks

We do not permit any of our funds or resources to be contributed to any political campaign, party, candidate or any affiliated organisations. Although we do not directly participate in party politics, we sometimes engage in policy debate on subjects of legitimate concern to Glencore and our stakeholders. Anyone who lobbies on our behalf must comply with all applicable laws and regulations, including those relating to registration and reporting. 

We can only give and receive appropriate, lawful business gifts and entertainment in connection with our work, provided they satisfy the general principles of our Anti-Corruption Policy and are not given or received with the intent or prospect of influencing decision-making or other conduct. We have requirements for pre-approval of gifts and entertainment based on localised thresholds, and additional requirements regarding public officials.

For our third parties, in addition to our standard “Know Your Counterparty” programme, our Third Party Due Diligence and Management Procedure aims to ensure that any such high-risk engagements are in accordance with our Anti-Corruption Policy, applicable laws and regulations. The procedure sets out a detailed risk-based assessment process to identify, assess and mitigate the corruption risk exposure of high-risk third-party relationships, particularly intermediaries, joint ventures and service providers. It also requires, where necessary, ongoing monitoring and review of the relationships to ensure compliance with our Anti-Corruption Policy. 

We report annually on our total payments to governments , and provide country-by-country and project-by-project information. Where applicable, we have aligned our reporting on such payments with the requirements of Chapter 10 of the EU accounting directive. 

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We are a member of the Partnering Against Corruption Initiative (PACI) whose members collaborate on collective action and share leading practice in organisational compliance. PACI has a commitment of zero tolerance to bribery and requires its members to implement practical and effective anti-corruption programmes.

We are conscious that dealings with public officials increase the risk of bribery and corruption, particularly in high-risk jurisdictions, so we are especially careful in our interactions with them. Employees must report requests for inappropriate or illegal payments, favours, or unusual or suspicious requests by a  public official to Compliance immediately.