Our approach to transparency

Our Group Tax Policy covers our approach to tax strategy, management and control of our tax affairs. We actively seek to identify, manage and mitigate our tax risks. Identified tax risks are actively managed within an appropriate tax risk framework and control procedures. Significant risks are routinely reported to the Board and Audit Committee. 

In our annual Sustainability Report, we provide detailed disclosure on our tax and royalty payments to governments, as well as the socio-economic contributions we make in the countries in which we operate.

Since 2015, we have published an annual Payments to Governments report that addresses our UK regulatory obligations under DTR 4.3A of the Financial Conduct Authority’s Disclosure Guidance and Transparency Rules, which were introduced to implement the payments to governments requirements provided for in the EU Transparency and Accounting Directives. The report includes our contributions to the national, regional and local economies in which we operate, including taxes, royalties and other related information. In response to external stakeholders’ feedback, we expanded our disclosures on certain countries, our contributions and activities in the countries where our payments to government are $100 million or higher, our large custom and excise payments to government entities as well as details on material advances and loans payable. The report also describes our approach to tax transparency and includes our commodity trading payments made to state-owned enterprises (SOEs) in Extractive Industries Transparency Initiative (EITI) implementing countries for the purchase of oil and gas and minerals and metals originating in those countries.

We lodge this report with the Swiss Tax Authorities and, in line with the OECD requirements, it is made available to other tax authorities under the protocols for the automatic exchange of tax information in the jurisdictions where Glencore has a taxable presence. This enables these authorities to monitor the amount of tax that Glencore pays. 

Glencore has been an active supporter of the EITI since 2011 and engages with the EITI at both local and international levels. We are supportive of the EITI and the objective of the EITI Association to make the EITI Principles and the EITI Standard the internationally accepted standard for transparency in the oil, gas, and mining sectors.

Where we operate in EITI member countries, we provide local EITI disclosures, participate in local multi-stakeholder groups and engage in policy consultation processes as appropriate. 

We promote commodity-trading transparency by disclosing the payments we make to state-owned enterprises in EITI member countries for the purchases of crude oil, minerals and metals. We include these EITI commodity-trading disclosures in our annual Payments to Government report.

We welcome the EITI Standard’s approach for contract transparency for EITI-compliant countries. Similarly, as a member of the International Council of Mining and Metals (ICMM), we support their Transparency of Mineral Revenues Position Statement , which includes a commitment to contract transparency.

In line with the ICMM’s position on contract transparency, we disclose our mineral development contracts with host governments, granted, entered into or amended post 1 January 2021, where such disclosure is not prohibited by law, regulation or express confidentiality provisions prohibiting the disclosure of the contract and in respect of which we are not able to obtain consent to disclose. We exclude generic licenses and contracts for operations not majority-owned or controlled by Glencore from our disclosure. We encourage the joint venture companies that are majority owned by ICMM members (either singly or jointly) and in which we hold an interest to also implement ICMM’s commitment on contract transparency. 

We have reviewed our mineral development contracts and we have identified the following contracts meeting the ICMM’s disclosure requirements: 

^{*We engaged with the relevant government to obtain consent to disclosure of the contract.}

Our Third Party Due Diligence and Management Procedure sets out the steps we take in respect of the management of third parties including onboarding and due diligence, contract terms/scope of services, training, monitoring and payment reviews/controls, renewal, and termination.

As of January 2023, Glencore has three active marketing sales/purchase agents. These agents perform substantive tasks such as submitting documents, arranging logistics and engaging current and potential customers on queries regarding new business and performance of existing business. Their contracts are renewed annually following full refreshed due diligence and audit by an independent auditor.