Anti-corruption, public policy, compliance with laws and regulation (non-environmental), Code of Ethics.
102-17, 203-2, 205-103, 205-1, 205-2, 406-103, 415-103, 415-1, 419-103
of non-union, non-hourly employees completed Code of Ethics certification through a web-based compliance and ethics training program to refresh and enhance awareness of the Code of Ethics, including issues such as insider trading, conflicts of interest and harassment.
We are committed to upholding high moral and ethical principles as affirmed in our Code of Ethics. While Teck’s business practices must be consistent with the business and social practices of the communities in which we operate, we believe that honesty is the essential standard of integrity in any locale. Thus, although local customs may vary, Teck’s activities are based on honesty, integrity and respect.
We conduct our business in an honest and ethical manner. We expect our employees to deal with everyone in a fair and open manner and to conform to the spirit and intent, as well as the technical requirements, of all contracts and agreements that we enter into, and with all laws, regulations and rules that govern us. Our approach to business ethics is guided by our Code of Ethics, which is implemented through our Doing What’s Right program, supported by our Anti-Corruption Policy, and has provisions for conflicts of interest. We maintain and implement a tax policy and disclose our engagement in the development of public policy.
Doing What’s Right, our program designed to maintain an ethical workplace, is overseen by our Senior Vice President, Commercial and Legal Affairs. We have a Code of Ethics available in English, Spanish, Chinese and Turkish for our employees and contractors located at our operations, sites and offices worldwide. Through this code, we affirm our commitment to uphold high moral and ethical principles. It specifies the basic norms and behaviours for those conducting business on our behalf.
Our Doing What’s Right program is supported by additional ethics-related policies and procedures, including:
All non-union, non-hourly employees are required annually to certify compliance with our Code of Ethics and to report any potential infractions. Biannually, these employees undergo a web-based compliance and ethics training program to refresh and enhance awareness of the Code of Ethics, including issues such as insider trading, conflicts of interest, and harassment.
Our employees are required to report any violations, or potential violations, of our Code of Ethics through our Doing What’s Right program, which includes a whistle-blower hotline and web portal that are managed by a third party. The hotline and portal are available 24 hours a day, seven days a week, in all jurisdictions in which we have employees, to provide a confidential and secure means for our employees to report concerns about conduct that may be contrary to our values and standards. We do not tolerate any form of retaliation against employees raising concerns. All allegations of harassment or intimidation by others as a result of contacting the hotline/web portal are investigated and, if required, appropriate disciplinary actions are taken, which can include dismissal.
We engage in and support the work being done to fight corruption by supporting international frameworks such as the United Nations Global Compact (UNGC) and the Extractive Industries Transparency Initiative (EITI). We participate in the EITI through our ICMM membership.
Our Code of Ethics requires that we conduct global business in a moral and ethical manner, and that employees comply with all applicable laws. Under our anti-corruption compliance policy, available in English and Spanish with additional overviews available in Chinese and Turkish, payments, charitable donations, travel expenses, gifts and entertainment may not be made to government officials or customers to assist us in obtaining or retaining business, nor can employees provide payments, gifts or entertainment that are prohibited by applicable country or local laws.
Our anti-corruption compliance program focuses on cases of perceived higher risk, including:
All charitable donations, sponsorships and community investments must comply with Teck’s Anti-Corruption Policy and follow Teck’s charitable donations and community investment guidelines, which prohibit donations that would improperly benefit a government official or other individuals. Compliance with the Anti-Corruption Policy is subject to periodic review by internal audit.
Our Indigenous Participation Funding Guidelines provide guidance on payments made to Indigenous Peoples for participating in Teck-related activities, such as regulatory assessment and approval processes. It is not illegal for a company to provide these types of payments to Indigenous Peoples so long as (i) the provision of the payments is not made corruptly to assist the company in obtaining or retaining business, and (ii) the provision of the payments is not prohibited by the applicable country or local laws.
We provide anti-corruption training to employees who may be exposed to corruption risks due to the nature of their work. For example, employees who work with government officials or who could potentially have contact with government officials are required to complete an anti-corruption training program. Employee anti-corruption training is conducted at least every two years. Third-party service providers, agents and consultants who represent Teck to government officials are asked to complete our Third-Party Anti-Corruption questionnaire and, in some instances, to complete our training.
Our Code of Ethics contains provisions regarding conflicts of interest for employees. As a Canadian company, we are subject to the Canada Business Corporations Act. As such, directors of the Board are required to disclose a material interest in any transaction or opportunity that the company is considering. To ensure the exercise of independent judgment, directors who have disclosed such an interest are prohibited from participating in the Board discussion or voting on the transaction.
ur corporate Government Affairs team guides Teck’s approach to public policy. Teck focuses on being collaborative and transparent, with a solutions-based approach in our engagements with governments in the jurisdictions in which we operate. We take a systemic approach to monitoring and identifying political, legislative and regulatory developments in order to identify public policy opportunities and risks in areas pertaining to our business.
Teck employs in-house Government Affairs professionals who engage government directly through written advocacy letters and submissions, roundtable meetings and bilateral meetings. In some jurisdictions, Teck also seeks and retains advice from knowledgeable experts to augment corporate and local in-house professionals. We also engage with governments directly and indirectly through various business and industry associations. We report on our advocacy efforts in an open and transparent manner, conforming to all lobbying laws, including publicly reporting on our activities via applicable lobbyist registries in jurisdictions where we undertake advocacy efforts. We regularly update compliance requirements to all corporate and site-based employees who interact with governments.
Teck regularly evaluates the effectiveness of our public policy engagement by identifying where our advocacy has resulted in outcomes that support our business and the sustainability objectives of those in the broader mining industry. For example, successful outcomes include, but are not limited to, results that:
Our performance in business ethics includes reporting on alleged violations against our Code of Ethics through our Doing What’s Right program, auditing of our anti-corruption policies, compliance with laws and regulations, public policy initiatives and political contributions.
Through this program, we received 15 reports of alleged violations of our Code of Ethics in 2016 (one report contained two types of alleged violations). The most common case types were bribery/corruption (19%) and employee relations (19%), followed by a range of other matters, including allegations regarding fraud and substance abuse. By the end of 2016, 13 of the 15 cases were closed following investigation, of which six resulted in management action, such as discipline or amendments to practices or policies. No criminal cases regarding bribery were brought against Teck or any of its affiliates in 2016 or 2015.
All operations and business activities are assessed for risks related to corruption, and internal audits are conducted on a periodic basis to assess compliance with the Anti-Corruption Policy. Annually, our Internal Audit department evaluates the effectiveness of our system of internal control over financial reporting (ICFR). This includes a consideration of the company’s vulnerability to fraud, as well as an evaluation of the design and operating effectiveness of those internal controls intended to prevent and/or detect fraudulent activities at a significant level. One deficiency in ICFR was identified in 2016. The Internal Audit department also reports to the Audit Committee on a quarterly basis on any frauds identified, other than those reported through the whistle-blower hotline; no instances of fraud were reported to the Audit Committee through normal channels during 2016.
Our internal audit for anti-corruption is one component of our anti-fraud program, which is reported annually from our Risk Group to our CEO and other members of the senior management team.
In 2016, we engaged directly and indirectly (i.e., through industry associations) with governments on several public policy and regulatory initiatives of relevance to Teck, including:
From time to time, we make political contributions in the province of British Columbia. All contributions are made in accordance with applicable laws. We did not make political contributions outside of British Columbia in 2016. In 2016, our contributions totalled $148,550:
Table 19: Political Contributions
BC Liberal Party
BC New Democratic Party
In May 2017, Teck will report on payments to governments in our principal operating countries, including taxes and other payment types, by country and on a project-by-project basis, as required under the Canadian Extractive Sector Transparency Measures Act (ESTMA). The Act, which came into force on June 1, 2015, introduces new reporting and transparency obligations for the Canadian extractive sector and contributes to global efforts against corruption in the sector. To learn more about Teck’s work with regards to ESTMA, see the Economic Performance and Contributions page.
Teck remains committed to upholding high moral and ethical principles as affirmed in our Code of Ethics. In 2017, we will continue to deliver our Doing What’s Right and anti-corruption programs and engage in public policy initiatives. We will continue to ensure we are compliant, transparent, cooperative and ethical in all matters and meet our reporting requirements.