Ethics
Our Code of Conduct provides guidance on ethical behaviour for all employees, contractors and business partners.
The Code details our policies on topics such as:
- gifts and hospitality
- payments to public officials
- specific areas or situations which may present the risk of bribery and fraud occurring
- dealing with specific business issues in a transparent and ethical manner
The Code of Conduct also explains how to approve, record and account for payments, gifts and hospitality, as well as the sanctions and penalties that may apply if the rules are breached. In 2011, we trained all our employees on the Code of Conduct.
Bribery and corruption
We do not tolerate any form of bribery or fraud, and will take consistent and swift action when it is discovered. We do not allow any form of political contributions.
All our operations are required to closely monitor this issue, have systems in place to prevent it, and where this fails, to deal with the situation. Our Internal Audit teams test these systems regularly, and review the risk identification process quarterly. Assessments consider the level of risk in the country or region, the policies and practices of other companies operating in the region and the integrity and transparency of government, suppliers, contractors and other business partners.
Transparency
Our Business Principles confirm our commitment to the maximum transparency that is commercially possible. We publicly report our financial, operational and SD performance regularly and in accordance with all relevant legislation and leading practice standards. We support the Extractive Industries Transparency Initiative (EITI) to increase transparency regarding company payments and government revenues in the extractives sector. We report royalties and taxes paid to governments on a country-by-country basis, more detailed information is available in our Sustainability report.
Free enterprise
We are committed to free enterprise in the mining sector. To support this aim, we train employees on all major anti-trust and competition issues. The training programme uses simulated situations and questions to test employees’ understanding of competition law and appropriate behaviour when dealing with customers, competitors, trade associations, suppliers and distributors. All participants must achieve a score in excess of 70%.
Non-compliance
Our internal audit team investigates possible breaches of our Business Principles, which may result in employment being terminated.
Ethics Line
We provide an independently operated Ethics Line in every country where we operate. The line exists for employees, contractors, suppliers, customers or business partners to report any breaches of our Business Principles, policies or prevailing legislation in confidence. Calls are reported on an anonymous basis to the Global Head Internal Audit and Risk, who reports directly to the Audit Committee.
