Anti-corruption, public policy, compliance with laws and regulation (non-environmental), and Code of Ethics.
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Domestic and international laws have been established and enhanced to promote stronger business ethics and to increase transparency of payments to governments in order to fight bribery and corruption. Businesses are also experiencing increasing legal requirements associated with anti-corruption and tax transparency — in particular with the Canadian Extractive Sector Transparency Measures Act that came into force in 2017.
There is ongoing public pressure for, and regulation requiring, greater transparency around how companies engage with, lobby or influence governments. 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 government on regulatory and public policy initiatives primarily focused on maintaining and enhancing the competitiveness of our industry as well as its social, environmental and economic sustainability. In 2018, our public policy engagement focused on advocacy for actions to address climate change, water management, environmental regulations (including impact assessment processes) and Indigenous Peoples, among other topics.
Teck’s Code of Ethics, Code of Sustainable Conduct, Political Donations Policy set out our intentions and commitments for conducting our business in an ethical manner. Our Anti-Corruption 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.
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 Director of 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 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 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. 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
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.
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.
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 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. Through this program, we received 31 reports of alleged violations of our Code of Ethics in 2018. The areas for which we received the greatest number of reports were in relation to employee relations (52%), theft of money (10%), and safety (10%). Twenty five of these 31 cases were closed following investigation or were closed on the basis that no investigation was necessary. The remaining six cases are still under investigation. No criminal cases regarding bribery were brought against Teck or any of its affiliates in 2018, 2017 or 2016.
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.
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. No such instances of fraud were reported to the Audit Committee during 2018 and we had no involvement in any investigations regarding alleged breaches of competition laws.
We focus on being a collaborative partner with governments in the jurisdictions where we work, and we regularly engage on public policy initiatives that support the competitiveness and the social, environmental and economic sustainability of our industry. In 2018, we engaged with governments on several public policy and regulatory initiatives of relevance to Teck.
Providing input to 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 our intent to strengthen public confidence in project assessment processes, enhance Indigenous Peoples’ participation and decision-making in these processes, and support sustainable economic growth while ensuring greater regulatory certainty for all parties involved. Our advocacy also included submitting recommendations to the Government of Canada’s review of 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 and B.C. Government in support of carbon pricing that ensures policies are designed to address, not imperil, the competitiveness challenges that come from a global trade environment that has uneven carbon pricing. Included in this support has been Teck’s co-chair role on the B.C. Climate Solutions and Clean Growth Advisory Group.
Advancing the development of Canada’s Coal Mining Effluent Regulations: Teck remained actively engaged in the review process for the draft regulations through 2018. 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 2019 to help ensure the regulations are well-designed and science-based.
Contributing leadership to caribou recovery efforts in British Columbia: Teck is committed to supporting biodiversity and wildlife in the areas where we operate. As part of this commitment, we engaged the Government of Canada, the B.C. Government and local stakeholders in British Columbia on developing effective ways to assist with the protection and recovery of local caribou populations and securing additional land for caribou habitat.
Advancing environmental stewardship in Alberta: As part of our commitment to environmental stewardship, we are working with Indigenous communities and the Government of Alberta to develop a regional conservation area, known as the Ronald Lake Biodiversity Stewardship Area, which is near our Frontier project. More recently, we shared our views on oil production curtailments with the Government of Alberta and will continue to advocate for solutions that help address the price differential for oil from Alberta.
Advocating for cost-competitiveness: Teck continued to engage the Government of Canada and the B.C. 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 measures. This engagement included membership on the B.C. Mining Jobs Task Force, which is expected to report out in early 2019.
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 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 shaping some of 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 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.
Enhancing trade relations with key export markets: We continued to support the Government of Canada in enhancing relationships with key export destinations, primarily in Asia and the United States. We supported greater Canada-China trade relations, including engaging in free trade negotiations as well as addressing tariff and non-tariff barriers. We also supported the ratification and implementation of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership, and supported the Government of Canada in its efforts to successfully negotiate the United States–Mexico–Canada Agreement.
Advocating for the reauthorization of the Education Tax Credit in Alaska: Teck utilizes the Alaska Education Tax Credit through its contributions to the University of Alaska Institute of Social and Economic Research and to the Northwest Arctic Borough School District. The program was reauthorized, with some changes, through 2020. This credit is expected to continue to be utilized by Teck and others in the mining, oil and gas industries and thereby encourage continued investments in educational programs in Alaska.
Participating in the Stand for Alaska Campaign: Teck’s Red Dog Operations was a participant in the Stand for Alaska campaign, formed to oppose ballot measure 1, which would have negatively affected responsible resource development in Alaska. The measure was defeated in the November 2018 election.
Collaborating on heavy fuel oil carriage ban in the Arctic: Teck and NANA have worked with the United States Coast Guard and the United States 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.
Participating in a major international mining conference: Teck participated in an international mining conference hosted by Chile’s Regional Ministerial Secretariat of Mining and Energy that brought together government, industry and local communities. At the conference, Teck gave presentations and participated in roundtable discussions to highlight the economic benefits of our Quebrada Blanca Phase 2 project, including the new jobs created during the construction and operational stages.
Working with governments to foster more innovation in mining: Teck actively pursued government initiatives to advance innovation in our operating jurisdictions, including leading Canada’s Digital Technology Supercluster (under the federal Innovation Supercluster Initiative) as a Founding Member. We also made several policy recommendations to the Government of Canada and the B.C. Government on fostering more innovation in Canada’s mining sector, such as dedicating large-scale innovation funding to mining-specific projects and supporting the testing and commercialization of new Canadian mining technologies.
Inclusion and Diversity Initiatives
Advancing reconciliation objectives with Indigenous Peoples: 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 in various government legislative reviews that included Indigenous components.
Hosting an official visit by the Undersecretary of the Chilean Ministry of Women and Gender Equality: Teck hosted the Chilean Undersecretary of the Ministry of Women and Gender Equity, in September 2018 to showcase the initiative underway to include more female workers at our Carmen de Andacollo Operations. This initiative is designed for women from the local district to be trained as haul truck drivers.
Partnering to increase women’s participation in the Chilean mining sector: Teck and over 20 mining companies and industry associations in Chile co-signed an agreement with the Ministry of Mining and the Ministry of Women and Gender Equity with commitments to increase women’s participation in the mining industry and introduce greater labour practices and equal opportunities for female workers.
Contributions to Industry Associations
We are members of numerous industry associations and are involved in organizations that provide a platform for advancing best practice in our industry. As we implement our sustainability strategy, our involvement with these organizations provides us with guidance and opportunities to share best practices and contribute to industry standards. Our three largest contributions in 2018 were to the International Copper Association ($1.4 million), the Stand for Alaska coalition ($1.3 million), and the International Zinc Association ($0.6 million).
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 Public Filings Archive page.
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 web page for more information.
We also engage in and support the work being done to fight corruption by supporting international frameworks such as the Extractive Industries Transparency Initiative (EITI). We participate in the EITI through our ICMM membership.
Teck remains committed to upholding high moral and ethical principles as affirmed in our Code of Ethics. In 2019, we will continue to deliver our Doing What’s Right and anti-corruption programs, and engage 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. We will continue to ensure that we are compliant, transparent, cooperative and ethical in all matters, and that we meet our reporting requirements.