Our approach

Sustainability at Glencore is overseen at the highest level, by our Board health, safety, environment and community and human rights (HSEC) committee.

Board oversight

The Board’s Health, Safety, Environment and Communities (HSEC) Committee sets the strategic direction for our sustainability activities and oversees the development and implementation of our health, safety, environment and social performance and human rights (HSEC&HR) programmes. It meets at least four times a year and receives regular updates on how our business is performing across our internally defined, sustainability-related material risk areas.

The Board is also responsible for overseeing the Group’s climate strategy and progress against Glencore’s climate commitments. Implementation of our climate strategy is led by the management team via our Climate Change Taskforce (CCT). Progress on this topic is a standing item on the Board agenda and is discussed in Board meetings at least twice yearly. In the event of a fatality or a major or catastrophic incident, the HSEC Committee reviews the incident investigation, its findings and next steps, working with the management of the mine and Group senior management. The information they receive covers the nature of the incident, details of subsequent investigations and the actions taken.

Implementing our sustainability activities

Responsibility for implementing and monitoring our sustainability activities across the Group rests with our senior management, including the Chief Executive Officer, Head of Industrial Assets and heads of our corporate functions and industrial commodity departments.

Our Group Policies support the delivery of our Values and Code of Conduct, which together detail the behaviour and performance expectations for all our offices and industrial assets where we have operational control. Our industrial assets tailor the implementation of Group Policies to reflect local cultures and regional challenges.

Through our HSEC Standards, Procedures, and Guidelines, we aim to establish ethical and consistent business practices and standards for our industrial assets. These support our commitment to be a responsible and ethical operator.

Our Group HSEC&HR Strategy outlines our goals, priorities and objectives for our industrial assets over the next five years. It aligns to our Purpose and our Values and considers our external stakeholder expectations. Each year, we review our strategy for material updates to consider whether it continues to fulfil the needs of our business and our stakeholders.

Our Strategy has evolved to reflect what we want our HSEC&HR performance to achieve. The Strategy defines our level of ambition and risk appetite through goals, priorities and objectives of where we want to take our industrial assets from 2024 to 2028. Through internal and external key performance indicators (KPIs) and targets, it allows us to measure and demonstrate performance. It aligns with our Purpose and Values and considers our stakeholders’ expectations.

The Strategy acknowledges that our industrial assets are at various stages of maturity, and that their priorities need to reflect their risk profiles. Each of our industrial commodity departments is required to develop and document its own HSEC&HR strategies and associated annual plans in line with the requirements and expectations set out in the Strategy.

In developing the Strategy, we took a long-term view that attempted to anticipate the changes that may occur over the next five years. Going forward, our annual reviews of the Strategy will consider changes to the external and internal context due to various factors such as geopolitical events and changes in trends, perceptions, and expectations.

KPIs and executive remuneration

In 2021, we updated our remuneration policy to better align executive director compensation with the interests of our shareholders. This provides that executive directors may not sell any after-tax vested shares under our restricted share plan until two years after retirement, a first among major UK-listed companies.

As part of this policy, 30% of our chief executive officer, Gary Nagle’s, annual bonus will include KPIs relating to HSEC matters - 15% for safety performance and 15% for progress towards our medium-term absolute emission target. In addition, Mr Nagle’s long-term incentive includes a comprehensive underpin focused on a holistic review of the overall business and ESG performance.

To emphasise the importance of sustainability within Glencore, sustainability-related KPIs are applied to our asset-level management as our assets have the greatest opportunity within our business to introduce and drive meaningful improvements in sustainability performance.

Risk management and assurance

The management of HSEC&HR-related risks aligns with Glencore’s general approach to the identification, assessment and mitigation of risk. Our industrial assets use our Enterprise Risk Management Framework to identify and assess hazards, including those with potentially major or catastrophic consequences, and to develop plans to address and eliminate, or mitigate, the related risks. For each of the identified catastrophic hazards we have implemented a standardised approach to identifying and understanding their causes and controls, including critical control verifications.

Glencore’s Group Internal Audit & Assurance (GIAA) includes in its annual plan audits of the management of catastrophic hazards and their controls. Experienced internal and external subject matter experts participate in this programme.

Multi-disciplinary assessments allow GIAA to audit complex issues from a range of viewpoints for an objective, independent and robust appraisal. These assessments are used to review diverse operations and activities with different risk exposures, such as underground operations, open pit mines, TSFs and processing plants. The Board HSEC Committee reviews the results of all HSEC&HR audits, together with their key findings, observations, and recommendations for good practice, as well as the corrective actions implemented by the industrial assets to strengthen their management of the identified risks.

Sustainability at independently operated joint ventures (JVs)

Independent management teams operate our non-controlled JVs. Along with our JV partners, we participate in board shareholder committees that take key strategic decisions and we use this participation to influence the independent management teams to adopt appropriate operational and governance standards that reflect those of Glencore and the other JV partners.

External standards

As we rely on the application and assurance of our own HSEC management framework, we do not insist that our assets undergo third party ISO 14001 or OHSAS 18001 certiﬁcation and we do not use external certiﬁcation as an indicator of performance.

Some of our sites undertake third party ISO 14001 and/or OHSAS 18001 certiﬁcation where there is an external requirement, or where it provides additional value to our business, customers or other stakeholders.

External commitments

We seek to uphold the International Labour Organization Declaration on Fundamental Principles and Rights at Work and the UN Universal Declaration of Human Rights.

We work in accordance with a number of specific international frameworks, including the:

In 2014, we signed up to the UNGC, and have sought to align our strategies and operations with the UNGPs, which cover human rights, labour, environment and anti-corruption. The UNGC also encourages participants to support the UN Sustainable Development Goals, with an emphasis on collaboration and innovation.

In the same year, we joined the ICMM and endorsed its sustainable development framework principles.

In March 2015, we became a corporate participant in the Voluntary Principles on Security and Human Rights Initiative.

World Economic Forum’s Partnering Against Corruption Initiative. Maritime Anti-Corruption Network.

We are a member of the World Economic Forum’s Partnering Against Corruption Initiative. Members collaborate on collective action and share leading practice in organisational compliance. The initiative has a commitment of zero tolerance on bribery and the requirement to implement practical and effective anti-corruption programmes. We are also an associate member of the Maritime Anti-Corruption Network.