The Glencore Corporate Practice (GCP) is our governance framework that encompasses our Group values, Code of Conduct and other policies and guidelines, such as those developed by the BEC. The GCP represents our commitment to uphold good business practices and to meet or exceed applicable laws and external requirements. We will not knowingly assist any third party in breaching the law, or participate in any criminal, fraudulent or corrupt practice in any country.


We seek to prevent such misconduct through training programmes and strong leadership, underpinned by internal policies, procedures and controls. The Group compliance policies are made accessible to employees via the local compliance coordinator, the Group intranet or the intranet of the specific operation at which they work. Our managers and supervisors are responsible for ensuring that employees understand and comply with the policies. Relevant employees must confirm their awareness and understanding of our compliance requirements in writing every year.


Certain operations implement their own policies in addition to Group policies. These are designed to address their specific requirements, while being consistent with our Group values, Code of Conduct and policies.


Local compliance coordinators, guided by the Group compliance departments, support our employees in day-to-day business considerations, particularly those seeking advice on ethical, lawful behaviour or policy implementation. Employees may access the telephone, email and postal contact details of our local compliance coordinators via the Group intranet, their local intranet and notice boards.


In accordance with the Code of Conduct, anybody working for Glencore who breaches the law, the Code of Conduct or other policies may face disciplinary action that could include dismissal.


We revised our Group Code of Conduct in 2015, to remove the focus on integration (our Xstrata and Viterra operations now being fully integrated), avoid duplication with the HSEC policies that were revised in 2014, and reflect changes to our programme for reporting potential misconduct, Raising Concerns. We rolled out the revised Code of Conduct to all operations and offices during the year, and distributed bulletins to ensure that our workforce was made aware of the revisions. The Code of Conduct is easily available to all employees; we also use it in many of our business activities, including recruitment, induction, supplier briefings and external engagement activities.


In 2015, 395 employees were dismissed for breaching the Code of Conduct, compared to 378 in 2014. The dismissals were predominantly related to failures to follow safety instructions or policies, or misappropriation of company property.




© Glencore Agriculture 2017