SERVICE PROVIDERS

The standards we expect of our service providers are detailed in our Code of Conduct, Global Anti-Corruption Policy and Human Rights Policy. These comply with International Council on Mining and Metals (ICMM) principles and international standards such as the United Nations Global Compact.

 

Performing Services on Behalf of Glencore

 

An individual or company that acts or performs services on behalf of Glencore must never directly or indirectly solicit, accept, offer, provide or authorise bribes of any kind or anything which may be construed as a bribe.

 

A typical example for such a service provider is a sales agent or representative, but advisers, lawyers, consultants, customs clearance agents, brokers and joint venture partners, for example, may also perform services on behalf of Glencore. The service providers take responsibility for knowing what the law permits regarding any benefits given or received by them. This includes whether a particular person with whom they are dealing is a government official.

 

Service providers acting on behalf of Glencore should always be alert in relation to potential occurrence of corruption, such as:

 

  • use of another service provider such as subcontractor who has a close personal or professional relationship with or, in the case of a company, which is beneficially owned by, a government official
  • use of another service provider such as subcontractor who was recommended by a government official
  • unusual or suspicious requests such as for payments that are in cash, urgent, unusual or unexplained
  • large payments for lavish entertainment or travel expenses for third parties
  • lack of transparency in expenses and accounting records
  • reference checks against another service provider such as subcontractor revealing a flawed background or track record
  • a refusal to agree to non-corruption provisions in agreements
  • requests to prepare or execute false or inaccurate documents; and
  • business operations in a country or region with a history of corruption
  • Facilitation Payments

 

A government official may, in return for a small payment, offer to enable or speed up a process that is his or her duty to perform such as issuing permits, licenses, or other official documents, processing governmental papers, such as visas and work orders, providing police protection, mail pick-up and delivery, providing utility services and handling cargo. Such payments are often called facilitation payments. Service providers acting on behalf of Glencore should not make facilitation payments.

 

Further guidance can be obtained from the Glencore Global Anti-Corruption Policy.

 

© Glencore Agriculture 2017