Corporate Governance

We are a global processor of E-Waste and Gold Ores, active at multiple stages of the commodity supply chain. Our supply chains comprise multinational, regional, national and local suppliers. These suppliers are critical partners in our commitment to do business in a manner that is responsible, transparent and respects the human rights of all.

 

Our requirements and expectations Drawing on internationally accepted standards, as well as EnviroLeach's Code of Conduct and our Anti-Corruption and Human Rights Policies, these Supplier Standards detail the expectations we have for all of our suppliers.

 

For the purposes of these Supplier Standards, a supplier is any individual, organisation or company that provides, sells or leases materials, products or services directly to EnviroLeach companies, including contractors. EnviroLeach expects these Supplier Standards will be incorporated, by reference, into all supplier contracts. In addition, EnviroLeach expects all suppliers to maintain agreed standards of quality and timeliness of delivery. All suppliers working on an EnviroLeach work site must also comply with site-specific requirements. EnviroLeach adheres to its Code of Conduct and policies which meet the expectations of these Supplier Standards.

 

Furthermore, our industrial and marketing related activities in our metals and minerals businesses adhere to the OECD Due Diligence Guideline for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas.

 

1. Ethical business practices

 

We are committed to operating in accordance with strong ethical principles, as detailed in our Code of Conduct, and expect our suppliers to take responsibility for ensuring their conduct conforms to these principles. We expect our suppliers to: 

Comply with all applicable laws and regulations, including requirements relating to: 

  • Anti-corruption

  • Anti-competitive practices 

  • Sanctions and trade controls 

  • Anti-money laundering  

  • Prevention of criminal tax evasion 

  • Not solicit, accept, offer, provide or authorize bribes of any sort either directly or indirectly 

  • Avoid conflict of interests with their obligations to Glencore and take steps to declare and manage any conflicts, including in respect of their employees 

  • Have appropriate policies and controls to ensure compliance with the above requirements

2. Safety and health We believe all fatalities, injuries and occupational diseases are preventable and expect our suppliers to take the necessary responsibility for maintaining safe and healthy workplaces. We expect our suppliers to: •

 

  • Comply with all applicable laws and regulations to ensure a safe and healthy working environment •

  • Provide a safe and healthy working environment, including appropriate personal protective equipment •

  • Provide regular health and safety training to their workforce •

  • Have appropriate policies and controls protecting the safety and health of their workforce Our Supplier Standards We reserve the right to review and update these Supplier Standards when deemed necessary. The most recent version can be found on our website glencore.com. Our Supplier Standards are set across six areas: 2 Glencore Supplier Standards 3. Human rights We support and respect internationally recognised human rights as set out in the Universal Declaration of Human Rights and in a manner consistent with the United Nations (UN) Guiding Principles on Business and Human Rights. We uphold the dignity, fundamental freedoms and human rights of our workforce and the communities in which we live and work and others affected by our activities. We expect our suppliers to: • Respect human rights and the UN Guiding Principles demonstrated by policies and processes appropriate to their circumstances, including: • A policy commitment to meet their responsibility to respect human rights • A human rights due diligence process to identify, prevent, mitigate and account for how they address their human rights impacts • Processes to enable the remediation of adverse human rights impacts they cause or to which they contribute • Where appropriate, align security management practices with the Voluntary Principles on Security and Human Rights 4. Labour rights We uphold the International Labour Organization (ILO) Declaration on the Fundamental Principles and Rights at Work (Core Labour Standards). We encourage our suppliers to respect the ILO Core Labour Standards to treat their workforce fairly and with respect. We expect our suppliers to: • Respect workforce rights to lawful freedom of association and collective bargaining • Have zero tolerance for any form of modern slavery, including forced, compulsory or child labour • Prohibit all forms of unfair or illegal discrimination based on race, nationality, religion, gender, age, sexual orientation, disability, ancestry, social origin, trade union membership, political belief or any other potential bias • Offer fair remuneration, working hours and working conditions • Have appropriate policies and controls protecting the labour rights of their workforce 5. Environment We are responsible for the environment and seek opportunities to reduce our environmental footprint. We aim to protect and conserve land, air, water, biodiversity and energy resources. We expect our suppliers to: • Comply with all applicable laws and regulations to protect the environment • Maintain all legally required environmental permits, licenses, approvals and other certifications • Improve their efficiency of energy, water and natural resource usage • Responsibly manage their air emissions, water quality and handling of hazardous materials • Have appropriate policies and controls to effectively manage their environmental performance 6. Communities We build respectful relationships and communicate openly with local stakeholders to understand and address any concerns. When present in our host communities, we expect our suppliers to: • Treat members of the community with dignity and respect • Have zero tolerance for activities such as threatening behaviour, violence, coercion, sexual exploitation or abuse 3 Glencore Supplier Standards Due diligence and corrective action We undertake, and communicate on, appropriate due diligence of our current and potential suppliers, using a risk-based approach: • During pre-qualification, the tendering process, or at the renewal of an existing contract term we conduct risk assessments of our suppliers. • On the basis of the risk assessment, suppliers may be required to complete a self-assessment against these Supplier Standards. • In some instances we may conduct further due diligence, including the use of third party verification. • Suppliers are expected to cooperate in the investigation and assessment of potential or adverse impacts and provide Glencore access to relevant information on reasonable request. If an unacceptable level of risk is identified, we will work with the supplier to determine appropriate corrective action. The corrective action will be monitored by Glencore and the affected supplier until both parties agree the desired outcome has been achieved. At all times we reserve the right to suspend, discontinue or terminate relationships with suppliers when we have reason to suspect or can identify that the supplier: • Is in breach of the law, or • Refuses or fails to demonstrate reasonable and timely efforts to implement agreed corrective actions required to operate in accordance with these Supplier Standards. We recognise local circumstances may pose significant challenges for meeting these Supplier Standards. When appropriate, we will seek to support our suppliers in capacity building and improving their adherence to the expectations set out in these Supplier Standards. We encourage our suppliers to share and apply the expectations detailed in these Supplier Standards with their own supply chain and exercise due diligence on the materials, products and services supplied to Glencore companies. We recommend due diligence policies and management systems are aligned with standards, such as the OECD Due Diligence Guidance for Responsible Business Conduct. We encourage our suppliers to ensure their workforce and associated communities have access to grievance mechanisms for the confidential raising of concerns without fear of retaliation. Speaking openly At Glencore, we are committed to creating a culture where everyone feels free to speak about concerns in a secure and confidential way. This includes employees and contractors working in our offices and assets as well as third parties such as suppliers or other stakeholders. We encourage everyone to report concerns regarding conduct that potentially breaches our Code of Conduct and its underlying policies, including these Supplier Standards, with a supervisor or manager, or with a local procurement contact at the relevant office or asset. If a concern remains unresolved or a reporter feels uncomfortable using the local channels, he or she may report using the channels of our Raising Concerns Programme. Information about the Raising Concerns Programme is available at glencore.raisingconcerns.org. We have zero tolerance for retaliation against anyone who raises concerns about conduct they believe doesn’t comply with our Code of Conduct or polices, even if the concern isn’t substantiated. Assistance for Suppliers The following Group policies support these Supplier Standards and are available on the Glencore website glencore.com. • Our Values • Code of Conduct • Human Rights Policy • Anti-Corruption Policy Selected Reference Standards: • International Labour Organization Declaration on Fundamental Principles and Rights at Work • OECD Due Diligence Guidance for Responsible Business Conduct • OECD Due Diligence Guideline for Responsible Supply Chains of Minerals from Conflict-Affected and HighRisk Areas • United Nations Guiding Principles on Business and Human Rights • United Nations Global Compact • Voluntary Principles on Security and Human Rights

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