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Business Ethics

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

GRI Indicators

102-17, 203-2, 205-1, 205-2, 415-1

Business Ethics

Populism and economic nationalism have increased, due to growing public concerns over corruption, tax evasion and illegal financial flows.1 Businesses are also experiencing increasing legal requirements associated with anti-corruption and tax transparency. Transparency and accountability that foster good governance are therefore vital for businesses to succeed in the current context.

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. Maintaining open and transparent communications with governments and regulatory parties is essential to mitigating risk and responding to future regulatory changes, and to forming good and transparent relationships with government entities, agents and intermediaries.

We focus on being a collaborative, solutions-based partner with governments in the jurisdictions where we work. We regularly engage with governments on regulatory and public policy initiatives, primarily focused on maintaining and enhancing the competitiveness of our industry as well as its sustainability. In 2019, our public policy engagement focused on advocacy for actions to address climate change, innovation, socio-economic initiatives, conservation and environmental management, and Indigenous Peoples, among other topics.


1 Progress Report 2019. Extractive Industries Transparency Initiative. 2019 (https://eiti.org/sites/default/files/documents/eiti_progress_report_2019_en.pdf)
 

Our Approach to Business Ethics

Demonstrating ethical behaviour and compliance with applicable laws and regulations is core to our company and essential to sustainable operations. We recognize that transparency in meeting our business ethics obligations is critical for earning trust and maintaining our social licence to operate.Teck operates primarily in Canada, United States, Peru and Chile, which are characterized by relatively stable political and economic conditions and robust legal systems. As part of our approach to ethical business practices and public policy, we focus on being a collaborative, solutions-based partner with governments in the jurisdictions where we work. We regularly engage with governments on public policy initiatives primarily focused on maintaining and enhancing the competitiveness and the social, environmental and economic sustainability of our industry.

Demonstrating good corporate governance is a priority for the Board of Directors and senior management team at Teck. Sound governance structures and systems protect the interests of investors and other stakeholders, and ensure that the company is well managed. The Corporate Governance Committee, supported by the company’s general counsel, ensures that our governance practices are up to date and that those practices meet the highest standards in Canada and abroad wherever we conduct business. The Audit, Corporate Governance and Nominating, and Compensation Committees of the Board are composed entirely of independent directors.

The following senior leaders are involved in implementing the management of business ethics:

  • The Senior Vice President, Commercial and Legal Affairs ensures proactive, timely and effective overview of our company’s legal and anti-corruption practices
  • The Head, Government Affairs oversees all of Teck’s public policy initiatives and government engagement

 

Every employee, officer and director at Teck is also responsible for adhering to our Code of Ethics and for upholding strong business ethics.

Teck’s Code of Ethics, Code of Sustainable Conduct and internal Political Donations Policy set out our intentions and commitments for conducting our business in an ethical manner. Our Anti-Corruption Compliance Policy supplements the Code of Ethics and reinforces Teck’s commitment to prevent and combat corruption in all its forms, including extortion and bribery. Our Board of Directors is responsible for the oversight of our Code of Ethics.

Teck works with numerous local, national and international organizations and programs to support ethical business conduct:

  • International Council on Mining and Metals (ICMM): A global industry association that represents leading international mining and metals companies who are required to implement the ICMM 10 Principles, including Principle 1 on ethical business and sound governance
  • Extractive Industries Transparency Initiative (EITI): Aims to strengthen governance by improving transparency and accountability in the extractives sector. The only EITI-implementing country where we currently have operations is Peru, and payments from the Antamina mine in that country to government are publicly disclosed in accordance with EITI standards. We engage in EITI through our ICMM partnership
  • Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises: Includes voluntary principles and standards for responsible business conduct that address a variety of issues, including employment and industrial relations, human rights, environment, information disclosure, combating bribery, consumer interests, science and technology, competition and taxation
  • United Nations Global Compact (UNGC): Provides a framework for businesses committed to aligning their operations and strategies with 10 principles spanning human rights, labour, the environment and anti-corruption

Doing What’s Right is our program designed to maintain an ethical workplace and to ensure that our moral and ethical principles within our Code of Ethics are upheld. It also 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 to certify compliance with our Code of Ethics annually, and to report any potential infractions. Every two years, these employees undertake 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 given an opportunity 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 the languages of all jurisdictions in which we have employees. They provide a confidential and secure means for our employees to anonymously report concerns about conduct that may be contrary to our values and standards.

Teck maintains a database of the reports that are delivered through the whistle-blower hotline, or raised to the attention of the Senior Vice President, Legal and Commercial Affairs in another manner. The outcome of each report is also tracked within the database.

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.

Our anti-corruption compliance program focuses on activities that are potentially higher risk, including:

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

 

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.

Charitable Donations and Indigenous Peoples Funding Guidelines

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.

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 (1) the provision of the payments is not made corruptly to assist the company in obtaining or retaining business, and (2) the provision of the payments is not prohibited by the applicable country or local laws.

Anti-Corruption Training

We provide anti-corruption training to employees who may be exposed to corruption risks due to the nature and location 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.

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.

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 systematic 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.

As outlined in our internal Political Donations Policy, Teck does not make use of corporate resources, including funds, goods, property or services, for the purpose of contributing to a political party or any individual candidate seeking election at any level of government.

Teck’s Government Affairs professionals engage with governments directly through written advocacy letters and submissions, and roundtable 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 and requirements, including publicly reporting on our activities via applicable lobbyist registries in jurisdictions where we undertake such advocacy efforts. We regularly update compliance requirements for 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, social and sustainability objectives, and those of 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 in jurisdictions where Teck operates
  • Streamline processes and reduce the administrative burden to lower transaction costs while maintaining or enhancing environmental, social and economic performance

Each year, Teck reports 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). Our Economic Contribution Report is our annual independent report of payments to governments and other economic contributions. It complements and enhances our report under ESTMA. To learn more, see the Economic Performance and Contributions page on our website.

We are committed to upholding high moral and ethical principles as affirmed in our Code of Ethics. While Teck’s business practices must be fully compliant with the legal and ethical standards of the communities in which we operate, we believe that honesty is the essential standard of integrity in any locale. Although local customs may vary, Teck’s activities are universally based on honesty, integrity and respect.

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.

We use an online system operated by a third party to screen consultants, agents or intermediaries who may have contact with a government official on behalf of Teck, for prior reports of corrupt activity, and to ensure that these parties are aware of and agree to abide by Teck’s policies. This enables Teck to conclude with reasonable assurance that the service providers understand and will fully abide by applicable anti-corruption laws and Teck policies.

We report on our performance against these indicators and our performance in public policy, business ethics and anti-corruption practices on an annual basis in our sustainability report.

 

Our Performance in Business Ethics in 2019

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 our Anti-Corruption Policy. No new significant risks associated with corruption were identified through these assessments.

The Internal Audit department reports to the Audit Committee on a quarterly basis on any cases of fraud identified, other than those reported through the whistle-blower hotline. Zero such instances of fraud were reported to the Audit Committee during 2019 and we had no involvement in any investigations regarding alleged breaches of competition laws.

Teck’s Anti-Corruption Policy supplements the Code of Ethics and reinforces Teck’s commitment to anti-corruption, which is an integral part of employees’ performance appraisals. While select employees are required to certify that they have read and understood these policies and standards and that nonconformity would lead to disciplinary action, they also undergo anti-corruption training at least every two years. We have criteria in place to determine which employees are required to complete anti-corruption training based on location, engagement with government and a number of other factors. Based on this criteria, 1,445 employees were required to participate in anti-corruption training in 2018 and 2019, and over 99% of those employees have completed the training. The following tables provide more information about training on anti-corruption policies and procedures.

Teck expects its supply chain partners to also adhere to the same fundamental principles, including those relating to legal compliance, fairness and honesty and anti-corruption, which are outlined in Teck’s Expectations for Suppliers and Contractors.

Table 37: Number of Employees Who Have Received Training in Anti-Corruption During the 2018/2019 Training Cycle

Country Number of Employees
Canada 896
United States 154
Chile 291
Total 1,445

Other locations (China, Australia, Ireland, Mexico, Namibia, Peru, Turkey and Japan) included 104 employees trained.

 

Table 38: Governance Body(1) Members Who Have Received Training in Anti-Corruption

Region Number Percentage
Canada 1 7%
United States 0 0%
Chile 0 0%
(1) Governance body members is interpreted as the Board of Directors at Teck.

 

Public Policy Initiatives

We focus on being a collaborative partner with governments in the jurisdictions where we work and we regularly engage in public policy initiatives that support the competitiveness and sustainability of our industry. In 2019, we engaged with governments on several public policy and regulatory initiatives of relevance to Teck.

Environmental Initiatives

Providing input into government reviews of environmental assessment and regulatory processes: Teck contributed detailed recommendations into government-led reviews relating to the Government of Canada’s Impact Assessment Act and the B.C. Government’s Environmental Assessment Act. Our advocacy focused on ensuring that the final design of the legislation and associated regulations are clear, robust and fair, and that they enable continued responsible natural resource development in Canada. Our related advocacy efforts also included submitting recommendations to the Government of Canada for its review of regulatory changes to the Fisheries Act.

Supporting effective climate change policies: Teck continued advocating to governments across Canada for policies that support the transition to a lower-carbon economy while ensuring the competitiveness of Canadian emissions-intensive, trade-exposed (EITE) sectors. We submitted detailed recommendations to the Government of Canada, the B.C. Government and the Alberta Government in support of climate action policies that are designed to address, not imperil, the competitiveness challenges that come from a global trade environment that has uneven climate change policies. Included in this support has been Teck’s co-chair role on the B.C. Climate Solutions and Clean Growth Advisory Group and Teck’s contributions to designing the federal Clean Fuel Standard, the B.C. Low Carbon Industrial Strategy and Alberta’s Technology Innovation and Emissions Reduction system.

Advancing the development of Canada’s Coal Mining Effluent Regulations: Teck remained actively engaged in the review process for the draft regulations through 2019. For Teck, the final design of these regulations is critical for long-term planning for our steelmaking coal operations in Western Canada. We will continue to participate in the review and dialogue process with the Government of Canada in 2020 to help ensure the regulations are well-designed and science-based.

Progressing biodiversity and wildlife management initiatives: Teck is committed to supporting biodiversity and wildlife in the areas where we operate. As part of this commitment, we supported actions by the Government of Canada, the B.C. Government and the Alberta Government on developing effective ways to assist with the protection and recovery of local caribou populations and securing additional land for caribou habitat. We also supported the Government of Canada’s amendments to Migratory Birds Convention Act regulations that are intended to benefit bird species across Canada.    

Making significant progress in reaching transboundary water quality objectives: Teck continued making progress towards achieving the objectives of the Elk Valley Water Quality Plan, which is a long-term approach to addressing the management of selenium and other substances released by mining activities in B.C. We worked with federal, provincial and state governments in Canada and the U.S. towards our goal of stabilizing and reversing the trend of these substances to ensure the ongoing health of the Canada-U.S. transboundary waterway, while at the same time allowing for continued sustainable mining in the region.

Collaborating towards a revised B.C. mine reclamation security policy: Teck collaborated with the B.C. Government in its review of the provincial mine reclamation security policyWe will continue to work with the B.C. Government and interested parties in 2020 to ensure the revised financial security requirements are practical and fair.

Socio-Economic Initiatives

Advocating for cost competitiveness: Teck continued to engage the Government of Canada, the B.C. Government and the Alberta Government to address cost-competitiveness issues relating to carbon taxation, rising costs in electricity, the ongoing administrative inefficiencies around the provincial sales tax, transportation costs, and other federal and provincial tax and regulatory measures. This engagement included membership on the B.C. Mining Jobs Task Force, which submitted detailed, consensus-based recommendations to the B.C. Government on improving mining sector competitiveness, the federal Economic Strategy Table for Resources of the Future and various government-led technical committees and working groups.

Rebalancing the shipper-railway relationship in Canada: Teck continued to advocate for changes to Canada’s transportation legislation and regulations for enabling a transparent, fair and efficient rail freight regime that meets the needs of all users. As Canada’s single largest rail user, Teck advanced recommendations to the Government of Canada aimed at enhancing the performance and reliability of Canada’s rail system to ultimately rebalance the shipper-railway relationship. We actively engaged in dialogue on the legislative changes made to the Canada Transportation Act and the associated regulations.

Ensuring the competitiveness of Canada’s ports: Teck is a leading commodity exporter from Canada’s Pacific coast ports, and our export competitiveness depends on port infrastructure and service levels that are reliable, cost-effective and efficient. As such, we communicated our concerns to the Government of Canada about the non-competitive business environment relating to Canadian port infrastructure, as well as the need to ensure that competitiveness considerations inform decision-making as it relates to port ownership structures. We also joined industry peers in communicating concerns to the B.C. Government about potential changes that would affect port taxation competitiveness.

Enhancing trade relations with key export markets: We continued to work with the Government of Canada in enhancing relationships with key export destinations, primarily in Asia and the United States. This included advocating for the ratification and implementation of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership, and encouraging progress towards finalizing the United States-Mexico-Canada Agreement.

Collaborating on heavy fuel oil carriage ban in the Arctic: Teck and NANA worked with the U.S. Coast Guard and the U.S. Department of Transportation, requesting a gradual and responsible time frame for the shipping industry to make the transition away from heavy fuel oil ships to diesel distillates, thereby avoiding negative economic impacts on the local, regional and state economy.

Reviewing potential for amendments to U.S. mining legislation: Teck continued to review where potential changes could be made to federal U.S. mining legislation affecting how mineral rights are secured on federal lands and how these lands can be used for activities ancillary to mining, including community and recreational activities. This review of federal legislation will continue in 2020. 

Innovation Initiatives

Working with governments to foster more innovation in mining: Teck actively pursued government initiatives to advance innovation in our operating jurisdictions, including continuing to work with Canada’s Digital Technology Supercluster (under the federal Innovation Supercluster Initiative) as a Founding Member. We also engaged with the Government of Canada and the B.C. Government on fostering more innovation in Canada’s mining sector, including contributing ideas to the Canadian Minerals and Metals Plan as well as the development of a BC Mining Innovation Roadmap. 

Inclusion and Diversity Initiatives

Advancing reconciliation objectives with Indigenous Peoples: In Canada, Teck continued advancing reconciliation objectives through our participation in the BC Assembly of First Nations–Business Council of BC Champions Table, through ongoing work with Reconciliation Canada, and through active engagement and support for various government legislative reviews and initiatives that included Indigenous components, such as the federal Impact Assessment Act and the B.C. Environmental Assessment Act. We also supported the B.C. Government’s Bill 41 — the Declaration on the Rights of Indigenous Peoples’ Act — which relates to establishing a new legal framework for advancing reconciliation.

Advancing Inclusion and Diversity in Chile: Teck participated and supported several workshops and events to promote inclusion and diversity, including the Asia-Pacific Economic Corporation 2019 workshop "Participation of Women in the Mining Industry", the International Forum on Gender Equality in the Extractive Sector, and the official launch of a short story initiative on women empowerment that resulted in over 1,600 entries and an online book publication. Teck is represented by the Vice President, Sustainability and Corporate Affairs on the National Mining Association of Chile’s (SONAMI) Board of Directors for 2020 to 2022. SONAMI was founded in 1883 to support the development of Chile’s mining sector, to represent the interests of the mining sector before the government and National Congress of Chile, and to engage government and elected officials on environmental, tax, economic, labour and legal matters.  

Contributions to Industry Associations

We believe it is important to engage with industry associations to advance research, share best practices and contribute to improving the regulatory systems and industry performance across the extractive sector and beyond. There can be a wide range of views within the membership of each association and, as members, we may not always agree with every position or approach. This is especially the case when the association’s membership is large and the mandate is broad, covering a wide range of issues. This diversity of perspectives creates a rich and full debate.

When disagreement arises, Teck may provide greater clarity on our own positions and activities with policy-makers, work with the association to understand alternative points of view and to seek common ground for progress, consider our ability to influence on policies or perspectives of the organization, or ultimately consider whether or not to continue participating the association.

Our three largest contributions in 2019 were to the International Copper Association ($1.4 million), the World Economic Forum ($0.7 million), and the International Council on Mining and Metals ($0.6 million). For more information on associations to which Teck pays annual memberships fees of $50,000 or more, visit Memberships and Partnerships on our website.

Commitment to Transparency

Teck publicly reports on payments to governments in the countries where we operate, as required under the Canadian Extractive Sector Transparency Measures Act (ESTMA). These payments include taxes, royalties and other payment types, by country and on a project-by-project basis, in relation to the commercial development of oil, gas and minerals. See our ESTMA disclosure on the Annual Public Filings Archive page (https://www.teck.com/investors/financial-reports/public-filings-archive/) on our website.

Teck publishes an annual voluntary Economic Contribution Report to complement and enhance our ESTMA disclosure. This report, first published in 2017, demonstrates our overall value generation in the areas where we operate through wages and benefits, payments to contractors and suppliers, community investment, payments to governments and other payments. See our Economic Contributions page on our website for more information.

We also engage in and support the work being done to fight financial corruption by supporting relevant international frameworks such as the Extractive Industries Transparency Initiative (EITI). We participate in the EITI through our ICMM membership.


Outlook for Business Ethics

Teck remains committed to upholding high moral and ethical principles as affirmed in our Code of Ethics. We will continue to be compliant, transparent, cooperative and ethical in all matter, and meet our reporting requirements. Our focus for 2020 will be on the continuation of our Doing What’s Right and anti-corruption programs and engagement in related public policy initiatives. We will also continue to expand the application of our anti-corruption and Code of Ethics training programs to projects as they advance.


Teck

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