Ethics and compliance

Ethics & Compliance

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.

  • Year in review
  • Year in numbers

Business integrity

In 2021, we updated our business integrity standard and procedure to simplify and optimise the efficiency of our processes and better guide our people on how to make the right decisions and demonstrate ethical behaviours. In 2021, we updated the new country entry procedure outlining steps to assess the potential risks (including corruption risks), and internal approvals process, for us to enter a new country. This year, we also established the export controls procedure setting out the requirements for compliance with export control laws.

We have further enhanced our risk and monitoring review forum to regularly review Group-level business integrity risks, and to identify and mitigate new and existing business integrity risks across our operations. In 2021, we established the Group Ethics & Compliance Committee, a sub-committee of the Executive Committee, to provide strategic oversight and input on compliance matters. The Committee provides a formal, structured forum for senior leaders to discuss compliance risks, and ensure the compliance programme is working effectively in practice. In addition, the Board oversees ethics and compliance matters, including myVoice, our confidential reporting programme.

We encourage and equip our people to do the right thing. Our employees are required to complete annual online compliance training, tailored to suit the risks they are most likely to encounter in their specific role and team. We are also continuing our ethics ambassador programme to extend the sharing and reach of integrity initiatives and champion an integrity-driven culture across the business. In 2022, we will update our code of conduct to align with our new strategy and values. We will also ensure it reflects our increased focus on supporting a culture where everyone feels safe to challenge and speak up freely when something does not feel right.

Working with third parties

Understanding the beneficial ownership and activities of the parties with whom we transact business is an important part of living our values and maintaining impeccable environmental, social and governance credentials.

In 2021 we amalgamated the “know your supplier” and “know your customer” procedures into a single “know your third party” procedure. This simplified document aligns risk criteria and clearly articulates the due-diligence requirements for all types of third parties. We have also included additional risk criteria to address human rights, labour rights, and modern slavery risk. In March 2021, we implemented a new sanctions standard which sets out the requirements and framework for compliance with applicable economic sanctions laws and regulations in the jurisdictions where we operate, and all our third parties are screened for sanctions. During the year we commissioned an external review of our due diligence process. This work will help guide us to streamline and automate processes and better align the level of due diligence with the assessed third party's inherent risk.

Reporting violations

In 2021, we launched our enhanced confidential reporting programme, myVoice, designed to help our people voice concerns about potential misconduct or improper behaviour. We have increased the independence and effectiveness of the programme through organisational changes and clearly defined governance, responsibilities and accountabilities. The programme is managed by a dedicated Business Conduct Office (BCO) reporting to the Chief Legal Officer & External Affairs. The BCO and the Investigations team report regularly to the Group Ethics & Compliance Committee.

Our employees’ response has been positive, and we are seeing an increase in reporting and believe this means that more people are feeling comfortable to share their concerns. In 2021, for the period from 1 January to 31 December, we received 1,246 reports through the myVoice programme channels. Fifty-one per cent of the cases were substantiated, including 18 cases which were reports received in 2020. The substantiation rate increase in 2021 reflects a single substantiated incident where 139 reports were received.

 

myVoice1 case activity

2021

2020

2019

2018

2017

Number of reports

1,246

748

805

679

712

Number of reports per 1,000 employees

26.0

16.3

17.9

14.3

15.1

Substantiated claims (%)

51%

42%

34%

34%

33%

1. In March 2021, Rio Tinto launched its new confidential reporting programme called myVoice. myVoice replaces the programme formerly known as Talk to Peggy or Speak-OUT.