The way we do business is increasingly important to our stakeholders who want assurance that we not only conduct ourselves responsibly and ethically, but also that suppliers and customers across our value chain do so as well. We look for opportunities to improve transparency about our business practices and work to ensure our people understand and fulfil their obligations. We participate in assessment and accreditation programmes to verify our performance and identify opportunities for improvement so our stakeholders can have confidence in the way we work.
We expect our people to uphold the highest standard of integrity and to act ethically.
Sometimes this requires courage, which is one of our values. This expectation extends to our partners, that they behave and operate in a way that aligns with our values and priorities.
Our code of conduct, The Way We Work, lays out clear expectations on how we should conduct our business, and ourselves, no matter where we work or where we are from. We want everyone to have the courage to speak up when something is not right, to show integrity and take decisive action when needed. This is not always easy, but being courageous means doing it anyway.
The Way We Work also makes it clear that we do not offer, pay or accept bribes, no matter where we operate, no matter what the situation, and no matter who is involved.
Our business integrity compliance programme, which is managed by our Ethics & Compliance function independently from our business operations, is designed to identify and actively support in managing our compliance risks and regulatory requirements in the jurisdictions where we conduct our business. We continuously evolve the programme so that it mirrors the risk profile of key assets and business activities and enables timely and targeted intervention to prevent issues from occurring.
Our business integrity standard and Procedure require our employees, core contractors and any third parties acting for, or on behalf of, the company to not commit, authorise or be involved in bribery, corruption, fraud or other economic crimes. We also have clear rules regarding third-party benefits, managing conflicts of interest, facilitation payments, sponsorships, donations and community support, mergers, acquisitions and joint ventures, and engaging third parties. Our Ethics & Compliance team helps our people navigate any grey areas.
Partnering to strengthen business ethics in Mongolia
Supporting the country’s continued growth and development through tackling corruption is a significant priority in Mongolia. As the largest international investor in Mongolia, we are committed to supporting the country’s efforts to promote transparency, business ethics, and corporate governance.
In 2021, we partnered with the Mongolian National Chamber of Commerce and Industry (MNCCI) and Transparency International, to establish a dedicated Business Integrity Centre. The Centre offers professional training, resources, and advisory support to approximately 5,000 Mongolian companies to embed global standards in ethical business practice. By working in partnership, the Centre is helping to build the capacity of Mongolia’s businesses and enhance the country’s position as an attractive location for international investment.
In November 2021, the Centre organised the first compliance and business ethics conference in Mongolia. Approximately 130 business representatives from from Ulaanbaatar and all 21 provinces in Mongolia attended the conference including government organisations, business associations, and major private sector representatives.
The Centre has provided business ethics and compliance training to around 110 private-sector employees from 30 companies across various industries.
Fostering an ethical culture
We know that our reputation to act ethically and with integrity hangs on the actions and decisions we make each day across our business. We empower and equip our people to seek guidance when faced with an ethical or business integrity dilemma – both to prevent incidents from occurring, and to protect them and others from harm. We equip our employees through mandatory annual online training, combined with additional face to face training for employees performing higher risk roles. Through training we aim to enhance employees' awareness of possible issues, like bribery and corruption, and to help promote consistent instincts and decisions across the business.
myVoice – confidential reporting programme
myVoice is our confidential whistleblower programme.
myVoice is available to anyone who has concerns or information relating to misconduct or improper circumstances or behaviours connected to Rio Tinto.
These can include concerns about the business, or behaviours of individuals, including suspicion of violations of our standards, policies and standards, human rights, safety, environment, financial reporting, fraud or business integrity issues in general.
myVoice lets you choose to submit a report confidentially or anonymously. It is important to know that the content discussed and the right to anonymity may be subject to local laws.
Progress in 2022
Business integrity
During 2022, we delivered several compliance programme improvements to ensure we continued to be in line with our current business integrity risks. We are exposed to reputational, financial and non-financial risk through the actions of third parties we engage with. We are updating our Third-Party Risk Management programme so we can optimise risk assessments, processes, systems and tools, and improve integration with other associated business processes. We are also managing our risk exposure to economic sanctions, monitoring new sanctions and continuing our ongoing assessment of our supply chains.
In 2022, we focused on how we monitor key fraud controls. We conducted a fraud risk assessment and reviewed the current measures we have in place to prevent and detect fraud risk. This will help us better understand the root causes of fraud and how we can improve our response.
We also updated our data privacy standard, which sets out the minimum requirements for how to collect and process personal data. Our monitoring now covers requirements of the data privacy programme.
Annual training
We know that our reputation as a business that acts ethically and with integrity depends on the actions and decisions we make every day. We empower our people to seek guidance when faced with an ethical or business integrity dilemma – both to prevent incidents from occurring, and to protect them and others from harm.
To help our workforce navigate grey areas and spot business integrity red flags, we have developed an online training course that challenges them to make ethical decisions through a number of interactive scenarios. In 2022, we trained 24,857 of our people in how to recognise and manage business integrity dilemmas. Our online business integrity induction training provides all new joiners with an introduction to ethics and compliance as well as the tools they need to recognise and understand business integrity risks. In addition to online training, the Ethics and Compliance team provides ongoing targeted face-to-face sessions on key risk areas including bribery and corruption, data privacy and competition.
Code of conduct
In early 2023, we launched our updated code of conduct, The Way We Work. Our code of conduct will work as a central tool in reshaping our culture and it demonstrates what living our values of care, courage and curiosity should look like. The code sets out our commitment to conducting business with integrity and provides clarity about the behaviours we expect and why responsible business conduct matters. The new code is broader in scope than our previous code and reflects changes in both internal and societal expectations regarding business conduct. It will help our people reflect on the potential impacts our decisions may have on the business and others. Updates to our code of conduct will be made available on our website pursuant to relevant laws and regulations.
myVoice, our confidential reporting programme
We have continued to develop our confidential reporting programme myVoice, which is designed to help our people voice concerns about potential misconduct or improper behaviour. Our care for our people and our desire to understand contributing factors for misconduct sit at the core of this programme.
The Business Conduct Office (BCO) is working to increase transparency and improve how we capture learnings from the myVoice programme by expanding the team to include a reporting and governance function. We continue to see an increase in reporting and we believe this means that more people are feeling comfortable to share their concerns. In 2022, we received 1,459 reports through the myVoice programme channels. Of these cases, 63% were substantiated, including 77 cases which were reports received in 2021.
The BCO is currently implementing two key recommendations from the Everyday Respect Report that was released in February 2022.
We are setting up a discrete unit of experts who will support and care for our people who have been impacted by harmful and disrespectful behaviours. The team will also be available to support leaders and human resources professionals in how to respond, and other people who have been affected by those behaviours. Separately we are also redesigning our investigation process to make sure it is trauma-informed, caring and people-centred. The BCO reports to our Chief Legal Officer, Governance & Corporate Affairs; the Board; and the Global Ethics and Compliance Committee.
