Teck Logo

Business Ethics

Anti-corruption, public policy, compliance with laws and regulation (non-environmental), Code of Ethics.

GRI Indicators
102-17, 203-2, 205-103, 205-1, 205-2, 406-103, 415-103, 415-1, 419-103

Why was Business Ethics a Material Topic in 2016?

Strong business ethics help prevent corruption, which, if unchecked, can lead to resource misallocation, lower employment and exacerbated poverty1. Domestic and international laws have been established to promote stronger business ethics and to increase transparency of payments to governments in order to fight bribery and corruption. There is also increasing public pressure for, and regulation requiring, greater transparency around how companies engage with and lobby or influence governments. As a result, businesses are experiencing increasing legal requirements associated with anti-corruption and tax transparency.  

(1) The Moral Compass of Companies: Business Ethics and Corporate Governance as Anti-Corruption Tools, Global Corporate Governance Forum and IFC World Bank Group, http://www.ifc.org/wps/wcm/connect/3a387c8048a7e613a4bfe76060ad5911/Focus7_AntiCorruption.pdf?MOD=AJPERES

As a global industry that operates in a wide range of jurisdictions including underdeveloped and developing countries, business ethics and anti-corruption are a major focus for the mining industry. The importance of business ethics is reflected in the International Council on Mining and Metals (ICMM) Principles. ICMM Principle 1, to “implement and maintain ethical business practices”, states that companies must implement policies and practices that seek to prevent bribery and corruption. Anti-corruption efforts and complying with local laws and regulations remained key activities within the mining industry, and were an essential component of gaining and maintaining a social licence to operate in 2016.

Teck operates primarily in relatively low-risk jurisdictions that are characterized by stable political and economic conditions and robust legal systems. We sell our products in countries around the world that have varying degrees of political and social development.

We focus on being a collaborative, solutions-based partner with governments in the jurisdictions where we work, and we regularly engage with government on public policy initiatives primarily focused on maintaining and enhancing the competitiveness and the social, environmental and economic sustainability of our industry. In 2016, our public policy engagement focused on climate change, water management, tax competitiveness and Indigenous Peoples, among other topics.

The primary countries we operate in (Canada, United States, Peru and Chile) have well-established anti-corruption laws. In addition, Teck has comprehensive management systems in place, guided by our Code of Ethics, that are designed to ensure Teck upholds high moral and ethical principles in everything we do.

Performance Highlight

98%

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.

Our Targets and Commitments

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. 

How Does Teck Manage Business Ethics?

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:

  • Competition and Anti-Trust Law Compliance Policy
  • Anti-Corruption Compliance Policy and Manual
  • Human Rights Policy
  • Employee Trading Policy
  • Employee Concerns Disclosure Program
  • Corporate Disclosure Policy

 

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:

  • Work in high-risk countries
  • Use of independent advisors
  • Third-party due diligence
  • Sales to state-owned enterprises

 

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.

How we evaluate effectiveness

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:

  • Support our sustainability objectives, including improved environmental, social and economic performance/outcomes and improved outcomes for Indigenous Peoples and the communities where we operate
  • Support identified cost-competitiveness challenges for jurisdictions where Teck operates
  • Streamline processes and reduce administrative burden to lower transaction costs while maintaining or enhancing performance

 

 

 

 

What was Our Performance in Business Ethics in 2016?

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.

Doing What’s Right Program

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.

Anti-Corruption

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.

Public Policy Initiatives

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:

  • Advancing reconciliation with Indigenous Peoples in Canada: In 2016, we supported efforts to advance reconciliation with Indigenous Peoples in Canada by supporting the ongoing work of Reconciliation Canada and the recommendations flowing from the Truth and Reconciliation Commission final report; advancing and being a signatory to a Memorandum of Understanding between the BC Assembly of First Nations and the Business Council of British Columbia — “Recognizing and Accelerating the Opportunities and Economic Reconciliation between First Nations and the Business Community in British Columbia”; advocating for the advancement and strengthening of consultation frameworks; supporting dialogue and the development of mutually beneficial mechanisms for implementing the United Nations Declaration on the Rights of Indigenous Peoples; and investing in Indigenous education, skills training and capacity building. We will continue these efforts through 2017.
  • Partnering with UN Women to empower Indigenous women in Chile: In 2016, we began working with UN Women and the Government of Chile on a collaborative project to promote the empowerment, leadership, and economic and social participation of Indigenous women in northern Chile. The project is scheduled to continue to 2018. 
  • Participating in the Government of Canada’s review of environmental assessment processes: In 2016, Teck made several recommendations to the Expert Panel reviewing environmental assessment processes in Canada. Our recommendations are in alignment with the Government of Canada’s intent to ensure that environmental processes are robust and that they incorporate science, protect the environment, respect the rights of Indigenous Peoples and support economic growth. Please see Teck’s submissions on the Expert Panel’s website
  • Ensuring there is adequate resourcing, capacity, and cross-ministry and jurisdictional coordination mechanisms in place to facilitate the effective and efficient implementation of processes, legislation and regulation related to project reviews: We continuously seek enhancements to permitting and consultation frameworks across jurisdictions where we have operations and projects.
  • Providing input into the Government of Canada’s Metal Mining Effluent Regulations (MMER) Review and supporting the development of a steelmaking coal mining regulation under Canada’s Fisheries Act: We engaged on the continued development of these regulations through 2016 and will continue to do so in 2017. We view the conclusion of this work as vital to the future of Canada’s mining industry and as a significant opportunity for the federal government to both improve regulatory certainty and strengthen environmental protection. For Teck, this is important to the future of our steelmaking coal mines in Canada.
  • Advocating for tax competitiveness and Provincial Sales Tax (PST) modernization in British Columbia: In 2016, Teck submitted detailed recommendations to the B.C. Commission on Tax Competitiveness and to the B.C. government on how to address tax competitiveness challenges, with a specific focus on modernizing the PST and addressing the risks of carbon leakage and competiveness challenges in the B.C. Carbon Tax policy framework for emission-intensive trade-exposed (EITE) industries, as well as other business taxes in order to support mining competitiveness in the province. Please view Teck’s recommendations on the Government of B.C.’s website.
  • Advocating for effective and efficient climate change policies, including carbon pricing regimes that avoid carbon leakage and address the competitiveness of EITE industries: We support the development of effective and efficient carbon pricing regimes in jurisdictions around the world. Teck is a Paris Pledge signatory and, in 2016, we were proud to be the first Canadian natural resource company to join the World Bank’s Carbon Pricing Leadership Coalition. In Canada, we established and participated in a civil society-industry working group through which we discussed the B.C. Carbon Tax policy framework, and explored and developed policy options for the development of competitiveness mechanisms for EITE industries. As the federal and provincial governments in Canada continue to advance the Pan-Canadian Framework agreement, we will continue to share our insights and the outcome of our working group process. We have also participated directly with the Alberta government as they work toward implementing the jurisdiction’s first comprehensive carbon tax regime, including the development of an EITE mechanism and an output-based allocation system for large emitters. In other jurisdictions, we continue to advocate for climate change policies and carbon pricing regimes that support the world’s transition to a lower-carbon economy while ensuring a level playing field for EITE industries. For more details about carbon policies, see the Energy and Climate Change page.
  • Participating in various public-private mining working groups in several regions of Chile: To support ongoing activities at our Quebrada Blanca and Carmen de Andacollo operations, as well as other projects and exploration activities across Chile, we actively participate in these working groups to ensure key issues such as water scarcity and economic development are addressed. In 2016, we participated in a panel at the CRU World Copper Conference on the topic of "International benchmarks and productivity gaps”, relating to recent studies prepared by Chile’s National Commission on Productivity. We will continue this work in 2017 with local partners, including the Pro Investment Committee and SERNAGEOMIN, Chile’s National Geology and Mining Service.
  • Advocating for changes to the Canada Transportation Act (CTA): In 2016, Teck continued to advocate for changes to the CTA that support a reliable supply chain, and trade and economic growth across all sectors. As a major Canadian transportation stakeholder and the country’s largest rail shipper, Teck advanced recommendations aimed at enhancing the performance, reliability and transparency of Canada’s rail system and balancing the railway-shipper relationship. In 2017, we will continue to engage the Government of Canada on these recommendations and how they might be reflected as part of its proposed Transportation 2030 strategy. 
  • Encouraging Canada to meaningfully enhance diplomatic and economic ties with key markets in Asia, with a focus on China: As a major exporter to China, in 2016, we continued to advocate for Canada to advance an economic dialogue with China in a timely fashion. In 2017, we will continue to support the advancement of discussions on launching Canada-China free trade negotiations.
  • Advocating for a comprehensive approach to address the fiscal (deficit) challenge in Alaska: As the Alaskan state legislature continued to look at both revenue and spending solutions to address a significant budget deficit, Teck Alaska worked closely with association and state legislators to support a comprehensive approach that did not look to any one sector for new revenue measures. In 2017, we will continue to advance this approach as the state undertakes a review of mining sector taxation.

 

Political Contributions

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

Political group

Donation amount

BC Liberal Party

$147,900

BC New Democratic Party

$650

 

Compliance with Laws and Regulations

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.

Outlook for Business Ethics

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.

Teck Logo

Teck is a diversified resource company committed to responsible mining and mineral development with business units focused on copper, zinc, steelmaking coal and energy.