codeofconduct english 2014

8/19/2019 CodeOfConduct English 2014

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Corporate Practice

Code of Conduct


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Introduction 1

Our priorities and Values 2

Our priorities 4

Our Values 5

Putting Our Values into practice 6


Who must follow the Code? 9

Upholding the Code every day 10

Raising concerns 11

Focus areas 12

Health and safety 14

Our people 15

Human rights 16

Communities 17

Environment 18

Communications 19

Compliance 20

Enterprise risk management 24

Quality and product safety 25

Investor relations 26

Protecting and maintaining assets 27

Tax 29

Contacts 30

Contents

1

Introduction

As one of t he world’s largest producers and marketers of bulk commodities, we supply global industry

with the basic ingredients it requires every day.

Combining Xstrata’s extensive industrial mining and processing activities with Glencore’s production

and marketing expertise will allow us to be at the forefront of the supply patterns for natural resources

and their related products.

With our unique business model as a vertically integrated producer and marketer o f commodities, we

can capture value at each stage of the commodities chain. Our reach stretches from extraction and

processing to freight, logistics, technology, storage and marketing.

Amongst our highest priorities has always been the safety and well-being of our workforce. We aim for

continuous improvement in workplace safety, with the ultimate goal of minimising the extent of injuries

and occupational illnesses.

This Code of Conduct has been developed to help those who work for us to embody Our Values. Our

people are essential to Glencore Xstrata continuing to supply the world with the commodities it needs.

Ivan Glasenberg


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2

Our priorities


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4Entrepreneurialism

Our approach fosters the highest level o

professionalism, personal ownership an

entrepreneurial spirit in all our employee

never compromising on the safety and

of our people. This is important to our s

and the superior returns we aim to achie

all our stakeholders.

Simplicity

We aim to achieve our key deliverables a

a path to industry-leading returns, while

maintaining a clear focus on excellence

quality, sustainability and continuous

improvement in everything we do.

Our priorities Our Values

Creating value

Our combination of extensive industrial

production facilities and activities, in

conjunction with global marketing and

distribution capabilities, is focused on

delivering superior growth and value creation

for the benefit of all our stakeholders.

Meeting global demand

We seek to ensure a consistent and

competitive supply of essential commodities

to industry worldwide. Our commodities

play an integral role in the production of

essential day-to-day products for developed

and developing countries.

Sustainability as standard

We believe that our long-term success

requires us to prioritise health and safety and

environmental management as well as the

welfare of all our workers, contribute to the

development and well-being of the communities

in which we work, and engage in open dialogue

with our stakeholders.

High quality as standard

We endeavour to maintain high standards

of service, business conduct and product

quality every day. We understand our

responsibility to our customers, suppliers and

the communities in which we operate; this

requires the highest standards of quality and

safety throughout our operations.


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Putting Our Values into practice

In this section


Who must follow the Code? 9

Upholding the Code every day 10

Raising concerns 11

6


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8

Who must fo

Each of us must also take reasonable st

ensure that other individuals or groups a

on behalf of Glencore Xstrata do likewis

The Code applies to Glencore Xstrata’s

marketing activities and industrial opera

controlled by the Group. It applies to all

permanent and temporary employees,

and offi cers as well as contractors (wher

are under a relevant contractual obligat

In joint ventures where we are not the o

we seek to influence our partners towar

adopting similar policies and procedure

wherever possible.

Everyone working for Glen

or role, must comply with t

the aspirations embodied i

actions and decisions and i

Putting Our Values into practice

Glencore Xstrata’s statement of values (Our

Values) stipulates our purpose, our priorities and

the fundamental values by which we conduct

business. It lies at the top of the hierarchy of

documents that form the Glencore Xstrata

Corporate Practice framework.

Glencore Xstrata Corporate Practice is our

corporate governance framework and

programme. The fundamental requirements that

apply across our Group are laid out in this Code of

Conduct (the Code).

Together, Our Values and the Code (including

the underlying policies supporting them and the

associated operational management procedures

for sustainability) represent our commitment to

upholding good business practices. This includes

meeting or exceeding applicable laws and other

external requirements.

Corporate policies

and standards

Operational policies

and standards

Values

Code of

Conduct

(CoC)


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28

Tax

We are committed to full compliance wi

our statutory obligations, full disclosure

authorities and reporting transparently

tax payments that we make to the gove

of the countries in which we operate.

We will continue to review our tax paym

reporting and make appropriate improv

in line with latest best practice and regu

developments.

We work proactively to maximise shareh

value while operating in accordance with

Transfer pricing between Glencore Xstr

Group companies is based on fair marke

whereby exchanges of goods, property

services between group companies are

conducted on an arm’s-length basis.

Glencore Xstrata’s tax stra

intention to achieve long-t

Inside information:

• Is precise and material in that it would be

likely to aff ect an investor’s decision about

whether to make a share transaction related

to the company

• Has not been made public

• Relates directly or indirectly to Glencore Xstrata

or another company that we are doing business

with or are seeking to acquire securities in

• Could have a significant eff ect on the price of

our securities if made public

You must never use inside information to buy, sell

or deal in securities, nor should you disclose this

information to anyone else.

If you are in possession of inside information

relating to Glencore Xstrata you must not deal

in our securities. This also applies to your

“connected” persons (most commonly your

family members).

Glencore Xstrata maintains general insider lists

of personnel who, due to the nature of their

employment or engagement, have, or may have,

access to inside information. These people must

obtain prior clearance from the Company

Secretary before dealing in Glencore Xstrata

securities during a “close period” (usually the

period between a quarter-end and the release

of our next scheduled results or trading update).

If you are not on such a list, you are entitled to

deal in Glencore Xstrata securities at any time,

provided you are not, at the time, in possession

of inside information.

Confidential information about publicly traded

companies other than Glencore Xstrata may also

constitute inside information. If you obtain such

information about another company during your

work, you will be subject to similar restrictions

concerning the securities of that company.


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Page Title

30


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Contacts

If anybody working for Glencore Xstrata has a

material concern that cannot be resolved by

addressing it to the relevant supervisor or

manager, the concern can be reported to:

[email protected]

External enquiries

For further information on Glencore Xstrata’s

Code of Conduct, please contact:

Sustainability

Michael Fahrbach +31 10 40 44 406

[email protected]

Company Secretary

John Burton +41 41 709 2619

[email protected]

Communications

Charles Watenphul +41 41 709 2462

[email protected]

Investor Relations

Paul Smith +41 41 709 2487

[email protected]

www.glencorexstrata.com


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www.glencorexstrata.com

codeofconduct english 2014

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