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HOW WE OPERATE

Responsible sourcing & supply chain

Our Purpose as a company is to responsibly source the commodities that advance everyday life. Responsible sourcing is our commitment to take into account social, ethical and environmental considerations with regards to our products and supply chains and when managing our relationships with suppliers. 

We expect our suppliers to share our commitment to ethical, safe and responsible business practices. Where feasible, we leverage our business relationships both as a company and via business organisations, and promote dialogue with other stakeholders to advance these commitments and industry best practice.

Our requirements and expectations of suppliers

We expect our suppliers to share our commitment to responsible sourcing. We require our suppliers, when working with us, to act in a manner consistent with Glencore’s Supplier Code of Conduct. Additionally, we encourage our suppliers to set expectations for their own suppliers that align with the Supplier Code of Conduct.

Framework for managing suppliers

We have a comprehensive framework and action plan for identifying and managing the key risks associated with our suppliers, from supplier due diligence, selection, onboarding and monitoring, through to disengagement. We allocate appropriate resources and assign clear roles, responsibilities and accountabilities within Glencore to implement this framework. We assess suppliers based on their risk and direct them to the most appropriate due diligence and management process for their risk level. 

Our due diligence processes address supplier risks associated with legal compliance, abuse of human rights such as equality, non-discrimination and diversity, respect for workers’ rights of freedom of association, modern slavery, child labour, health and safety, and environmental impacts. 

We use a variety of tools to assist us in our due diligence processes, which, for example, may include on-site inspections, third party verification, obtaining information from third party sources including authorities, international organisations and civil society, and consulting experts and technical literature. 

We communicate our requirements and expectations to suppliers. Using a risk based approach we conduct training for certain suppliers. 

Where we find instances of non-compliance with the Supplier Code of Conduct, we investigate these incidents to understand causes and contributing factors, and we take appropriate action accordingly. We collaborate with our suppliers and relevant stakeholders to address the deficiencies identified and mitigate identified actual or potential adverse impacts as appropriate. However, where we find that a supplier cannot or will not take actions to demonstrate compliance within an agreed timeframe, we may review our continuing relationship with that supplier, up to and including termination of engagement. 

In the event that we identify that we have caused or contributed to an adverse impact on human rights in our supply chain, we will provide for, or cooperate in, processes to enable an appropriate remedy. 

We implement assurance processes to monitor compliance with our supplier risk management framework. 

As part of Glencore, KCC publicly communicates on the implementation of supplier due diligence obligations including on modern slavery, child labour and conflict minerals, via Glencore regulatory reporting and annual public disclosures. 

We train our employees and contractors who are involved in procurement, purchasing, sales, trading, contracting, contract management and other relevant functions, on our supplier risk management framework. 

We make available anonymous channels to our suppliers in order that they can raise concerns regarding compliance with the Supplier Code of Conduct and our policies.