Code of Conduct

Health & Safety is our first priority. We take responsibility to ensure that people remain safe.

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We aim to create a workplace free of injuries and fatalities. IGR encourages its people to take responsibility of their own safety and the safety of their colleagues, contractors and the communities in which they operate. They do this by first and foremost following the IGR systems established for the safety of the people.

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IGR has strict compliance towards people being fit for duty – mentally, emotionally and physically. It is mandatory for people to follow our health and safety instructions to create a safe environment.

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IGR promotes and is committed to a health & safety culture. This requires commitment from leader, managers and supervisors involved in our supply chain activities.

People should not put themselves in the line of fire and must use their authority to stop work where they consider it unsafe.

People are fundamental to our business. We treat are people with respect and treat them fairly. We give our people fair opportunities to grow and develop their careers and business prospects.

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When we grow our people, we grow our business. At IGR, we expect every employee to improve at least 5% in productivity annually, we help them reach this goal. So, in some way, every employee needs to find ways where they become more skilful in their jobs, resulting it higher results with the same amount of time and effort.

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Our people are required to understand how IGR operates, and what is required for IGR to be successful and sustainable in the long-term. It is our leader’s responsibility that our employees do not fail. If employees productivity increase by 5%, they are not working hard, but smarter.

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IGR invests into employee development programs, when and where the long-term benefits come back to the organisation.

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We do not tolerate any form of workplace discrimination, harassment or physical assault, or any form of child, forced, or compulsory labour. We seek to reflect the diversity of the communities in which we operate within our workforce. We respect the rights of our employees and contractors, including the freedom of association and collective bargaining.

IGR’s engagement with the community is integrated into all stages of our business transactions.

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In our relationship with local communities we respect and promote human rights within our area of influence. This includes respect for the cultural heritage, customs and rights of those communities, including those of indigenous peoples.

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We work with governments, local authorities, community representatives, inter-governmental and non-governmental organisations and other interested parties to develop and support community development projects. These projects and other donations are developed and decided in accordance with our policies and guidelines. These activities, along with the employment we provide, contribute directly and indirectly to the prosperity and development of our local communities in particular and our host countries. Where possible, we support and promote local employment and local procurement through training and small and medium enterprise development.

Our operations are geographically widespread and diverse in nature, including the prospecting, production, reclamation, processing, storage, transportation and marketing of natural resources and agricultural products. Our potential environmental impacts are specific to different commodity groups or production sites.

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Throughout our operations, environmental impacts are identified, analysed and reflected in our planning, management systems and day-to-day activities. We comply with applicable laws, regulations and other requirements for environmental management. Where these are less stringent than our own standards, we apply our higher standards.

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We conserve and protect environmental resources through a broad range of proactive initiatives, which include the efficient use of energy and water, minimising waste, reducing emissions and protecting biodiversity. Throughout the lifecycle of our activities, we conduct ongoing consultations with local communities and other stakeholders to ensure that we operate in a manner that is appropriate.

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We undertake responsible closure planning with the purpose of achieving final sustainable land use.

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We manage our waste sensibly. We regularly examine the integrity of our facilities to mitigate against the risk of serious incidents. We acknowledge the increasing societal and regulatory pressure to reduce carbon emissions to address climate change. We work proactively to manage our energy and carbon footprint and support the development of low emission technologies. We work with policy makers and others to promote the development of a least cost pathway to reducing global emissions while at the same time meeting the needs for affordable energy in developing nations.

We believe in the importance of maintaining active engagement and dialogue with stakeholders. We are committed to communicating regularly, openly and accurately with our employees, contractors, customers, suppliers, local communities, and investors, as well as appropriate associations, governments and other stakeholders.

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We undertake fact-based, timely and constructive communication with all our stakeholders across a wide range of matters. We share information on matters that affect our operations and activities with relevant stakeholders. Our engagement with all our stakeholders supports our decision-making process. We regularly engage in dialogue with governments on issues that affect our operations and activities. Seeking to maintain open and constructive relationships with governments ensures awareness of the opportunities, constraints and concerns related to our operations and marketing activities on an ongoing basis. Communications with governments must only be undertaken by suitable senior management or authorised personnel and all information shared should be accurate and not misleading.

Conflict of interest: A conflict of interest is a situation in which an individual has a private interest sufficient to potentially influence the objective exercise of his or her professional duties. Everybody working for IGR must avoid actual conflicts of interest and, wherever possible, avoid apparent or potential conflicts as well. We must safeguard IGR’s legitimate interests through properly performing our professional duties.

Any concerns around an actual or potential conflict of interest or an unclear situation should be immediately referred to an appropriate supervisor, manager or compliance contact. Contractors, suppliers and partners are engaged through a fair, formal process that includes, where appropriate, written requirements reflecting our Values and policies.

Bribery: A bribe is any financial or other advantage which is offered, provided, authorised, requested or received as an inducement or reward for the improper performance of a person’s relevant function, or the receipt of which in itself would constitute improper conduct. You must not solicit, accept, offer, provide or authorise any bribe either directly or indirectly or through any third party. Any concerns about potential bribery must be reported to a manager, supervisor or an appropriate compliance contact or, where appropriate, through the ‘Raising Concerns’ programme.

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A public official may offer to enable or speed up a process that is his or her duty to perform, in return for a small payment. Such payments are often called facilitation payments and should not be made. All dealings with public officials must be transparent and we must guard against circumstances where even the appearance is made of inducing a public official to perform his or her work improperly. Further guidance on this matter can be obtained from the global anti-corruption policy or an appropriate compliance contact. Anyone working for IGR who fails to comply with applicable anti-corruption laws and the IGR Anti-Corruption Policy may face disciplinary action that could include dismissal.

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Political contributions and activities: We do not permit any of our funds and resources to be used as a contribution towards a political campaign, political party, political candidate or any affiliated organisations. We will not use charitable donations as a substitute for political payments.

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As a signatory of the Extractive Industries Transparency Initiative, we support increased transparency around payments to governments across the world and how they are redistributed and/or reinvested into the communities in which we operate. The pricing of transactions between IGR companies is based on fair market terms, whereby exchanges of goods, property and services are conducted on an arm’s-length basis. We will continue to review our tax payment reporting and make appropriate improvements in line with any applicable regulatory developments.

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Competition: We are committed to the principles enshrined by competition laws. We expect everybody working for Glencore to be aware of competition laws, to avoid infringement and ensure that suppliers or trade customers are not engaging in anti-competitive activities that could damage our business or reputation. We provide our at-risk employees with specific training and guidance on what actions may breach the law and the practical steps that can be taken to ensure compliance.

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Sanctions: Sanctions are laws, regulations and compulsory measures enacted by governmental authorities in relation to particular states, regimes, entities and individuals. Such laws, regulations and measures may directly or indirectly restrict transactions involving goods, services, payments and capital transfers, or the movement of persons. They may also include other prohibitions, licensing and reporting obligations. You must respect and uphold any applicable sanctions.

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Money laundering: Money laundering is a process whereby the origin of funds generated by illegal actions is concealed source. We will not participate or assist any third party in money laundering or any other illegal practice. We encourage and support everybody working for IGR to report to a supervisor, manager or compliance contact any concerns relating to a current or prospective counterparty being engaged in money laundering.

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Inside information: We have systems and processes in place that help to ensure that inside or confidential information about IGR is secure and protected.

These activities also ensure that all products come with documentation for customers to allow safe transport, handling and use. Our marketing, logistics and product safety functions work closely together with our partners and service providers to ensure that quality and safety requirements are met throughout our supply chains. We ensure that customer enquiries are dealt with in a timely and accurate manner. We engage with all stakeholders involved with any aspect of our products. We attempt to promote the responsible use and management of these products.

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We have detailed management policies and programmes that ensure our products meet regulatory requirements and our own quality standards and our customers’ needs.