Integrity in Business: Developing Ethical Behavior Across Cultures and Jurisdictions
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With Free Saver Delivery. Facebook Twitter Pinterest Share. Description Also available on eBook. To ensure we identify, assess and manage the risks, including many forms of corruption, present in our global network of suppliers, we conduct quarterly anti-corruption audits of suppliers identified as high risk. We participate in the legislative process to have a constructive dialogue with those who are creating or influencing policies that have a significant impact on our business.
We also participate in the electoral process where appropriate and allowed by law, and, at this time, we only make political contributions in the U. Every donation is made in compliance with our Political Contributions Standard, and all applicable federal, state and municipal laws. Contributions are made either directly by the company or by our company-sponsored political action committee called NEWPAC.
A key element of our political engagement strategy is our membership in trade associations that conduct lobbying activities on behalf of the mining industry or the broader business community. Some associations in the U.
We report our political contributions to our Board of Directors on a semi-annual basis and annually on our website. We maintain a broad training program that requires all employees and directors to acknowledge our Code of Conduct.
Employees with regular computer access at work and employees in managerial and leadership roles must complete online courses on specific topics, and in-person training is made available to all employees to address Code-related issues relevant to their region.
His messages are supported by monthly presentations from the ethics and compliance team. We further embedded a culture of integrity into our personnel management practices by including conversations about our company values during performance evaluations and annual goal-setting meetings. We actively encourage employees to speak up and report any incidents where a possible Code of Conduct violation has occurred.
Anyone — including contractors and community members — at any time can anonymously report a concern via the web or by phone using our third-party-run Ethics Solutions Tool available in English, Spanish and Dutch. We also input into the Ethics Solutions Tool cases with a Code-related component that originated through other channels such as human resources or security. Any matters that have a human rights impact are categorized as such. Substantiated compliance issues lead to some form of action, which may include a recommended process improvement, coaching, formal discipline or termination.
Managers are reminded of substantiated outcomes at mid-year and year end so that they can be factored into performance appraisals, thereby potentially affecting remuneration.
During the year, we continued to assess our ethics and compliance program and identify opportunities for improvement. Areas of focus included strengthening our management of corruption risks, implementing stronger controls, engaging and training employees on relevant ethics matters, and conducting prompt, thorough and fair investigations.
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We significantly improved the management of commercial and government corruption risk throughout the lifecycle of our supplier relationships with the launch of our Supplier Risk Management program. During the year, we initiated a program to audit suppliers identified as high risk from a corruption perspective.
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As part of the program, each quarter our ethics and compliance team collaborated with our supply chain organization to identify vendors whose work might pose a corruption risk, and then the ethics and compliance team audited the relationship to determine whether it met our basic contracting requirements for bidding, contracting and vendor lifecycle management, and to evaluate the ethics and compliance practices of the vendor. No significant supplier corruption risks were found; however, the audits did identify opportunities to improve internal processes and also served as an effective, positive engagement tool with suppliers.
The new certification process led to a heightened focus on certain expenditures, and was supported by an expense management optimization effort to improve our cost-related reporting, specifically to enhance tracking of payments and expenses related to government officials and community leaders. Following a third-party assessment in that evaluated the effectiveness of our global ethics program, in , we extended the assessment to our regions and operations.
In , we plan to deploy a new online conflict of interest disclosure platform that reduces the need for paper disclosures and consolidates all disclosures, significantly improving our ability to analyze, track and manage any potential conflict of interest. In all our jurisdictions, we engaged with government stakeholders on key matters including the following:.