Anti-corruption, public policy, compliance with laws and regulation (non-environmental), and Code of Ethics.
102-17, 203-2, 205-103, 205-1, 205-2, 406-103, 415-103, 415-1, 419-103
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.
According to the global professional services firm EY, regulatory risk continued to increase for the mining and metals industry in 2017 as governments demand a greater return from, and oversight of, their natural resources.13 There is also increasing 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. The importance of business ethics is reflected in Principle 1 of the International Council on Mining and Metals (ICMM) 10 Principles: to implement and maintain ethical business practices that seek to prevent bribery and corruption.
Maintaining open and transparent communications with governments and regulatory parties is essential to mitigating risk and responding to future regulatory changes.
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 of, and the social, environmental and economic sustainability of, our industry. In 2017, our public policy engagement focused on climate change, water management, tax competitiveness and Indigenous Peoples, among other topics.
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 relatively low-risk jurisdictions that are characterized by 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 government 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. 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, ensure that our governance practices are up to date and 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:
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, 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.
Teck works with numerous local, national and international organizations and programs to support ethical business conduct.
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:
All non-union, non-hourly employees are required to certify compliance with our Code of Ethics annually, and to report any potential infractions. Biannually, 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 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.
Our anti-corruption compliance program focuses on activities that are potentially higher risk, including:
Compliance with the Anti-Corruption Policy is subject to periodic review by the corporate Internal Audit group. 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 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:
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 Contributions 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 about Teck’s work with regards to ESTMA as well as our Economic Contributions Report, see the Economic Performance and Contributions page.
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.
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 22 reports of alleged violations of our Code of Ethics in 2017. The areas for which we received the greatest number of reports were in relation to employee relations (27%), health and safety (22%), discrimination (18%), and allegations regarding commercial fraud (9%). By the end of 2017, 17 cases were closed following investigation or were closed on the basis that no investigation was necessary. The remaining five cases were still under investigation. No criminal cases regarding bribery were brought against Teck or any of its affiliates in 2017, 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 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 instances of fraud were reported to the Audit Committee through normal channels during 2017. In 2017, we had no involvement in any anti-competitive investigations.
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 that support the competitiveness and the social, environmental and economic sustainability of our industry.
In 2017, we engaged directly and indirectly (i.e., through industry and trade associations) with governments on several public policy and regulatory initiatives of relevance to Teck, including:
Advancing reconciliation objectives with Indigenous Peoples
Teck continued active and direct engagement in advancing reconciliation through our participation in the BC Assembly of First Nations – Business Council of BC Champions Table, through ongoing work with Reconciliation Canada, and through engagement in various government legislative reviews that included Indigenous components. We also developed and advanced our Reconciliation Action Plan in 2017, the first of its kind created by a Canadian mining company. The Plan will be released later in 2018.
Joining the Government of Canada in fostering a more dynamic innovation culture in Canada
Teck actively pursued several government initiatives to advance innovation in our operating jurisdictions, led by our work to participate in the Government of Canada’s Innovation Superclusters Initiative. Teck was a founding member of two supercluster proposals that advanced to the final round of evaluation in 2017: Canada’s Technology Digital Supercluster and the Clean, Low-energy, Effective, Engaged and Remediated mining sector submission.
Submitting solutions to the Government of Canada’s reviews of environmental assessment and permitting processes and legislation
The federal government advanced comprehensive reviews of key environment-related legislation — which we made several recommendations to, while working closely with industry associations to advance constructive approaches to improving legislative structures. Our advocacy focused on our intent to strengthen public confidence in project assessment processes, enhance Indigenous People’s participation and decision-making in these processes, and support sustainable economic growth while ensuring greater certainty for all parties involved.
Providing input into the Government of Canada’s Coal Mining Effluent Regulations (CMER) Review
Teck was actively engaged in the review process for these draft regulations through 2017. For Teck, the final design of these regulations is critical for the 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 to help ensure the CMERs are well-designed and science-based, and that they enhance regulatory certainty and environmental protection.
Advocating for cost-competitiveness policies in British Columbia
Teck continued to engage the B.C. Government to address cost-competitiveness issues related to carbon taxation, rising costs in electricity input expenses, ongoing efforts to detail the administrative inefficiencies around the provincial sales tax (PST), and expanding the tax exemptions framework. Overall, we continue to advocate for cost-competitiveness measures that support key provincial objectives, including job growth and effective and efficient environmental policy.
Supporting effective climate change policies, including carbon pricing regimes that prevent carbon and investment leakage
We support the development of effective and efficient carbon pricing regimes in jurisdictions around the world. Teck is a Paris Pledge signatory, and, in 2017, we were the first Canadian natural resource company to join the Carbon Pricing Leadership Coalition. In Canada, we engaged in a working group of stakeholders to analyze the B.C. system and explore and recommend policy options for the development of competitiveness mechanisms for emissions-intensive and trade-exposed (EITE) sectors. We also engaged with the Canadian government on issues related to the Pan-Canadian Framework on Clean Growth and Climate Change, including providing feedback on backstop EITE-related legislation and on the proposed Clean Fuel Standard. In other jurisdictions, we continued advocating 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 Canada’s EITE sectors.
Advocating for changes to the Canada Transportation Act
Teck continued to advocate for changes to Canada’s transportation legislation in order to enable a transparent, fair, efficient and safe rail freight regime that meets the needs of all users. As Canada’s largest rail user, Teck has advanced recommendations to the Government of Canada aimed at enhancing the performance and reliability of Canada’s rail system to ultimately balance the railway-shipper relationship. We are actively engaged in the review of the proposed legislative changes to the Canada Transportation Act tabled in late 2017.
Supporting efforts to enhance diplomatic and economic ties with key international markets
As a major Canadian exporter with virtually all our output destined for markets abroad, we continued to support the Government of Canada in enhancing diplomatic and economic ties with export destination countries primarily in Asia, as well as the United States. We continued to support discussions on launching Canada-China free trade negotiations as well as the ratification and implementation of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership. As the U.S. is the third-largest export jurisdiction for Teck’s products, we continue to support the Government of Canada in maintaining and enhancing the certainty and shared benefits enabled by the existing North American Free Trade Agreement. In addition, Teck participated in a visit by Canada’s Minister of International Trade, Philippe Champagne, to Chile as part of the 20-year anniversary celebration of the Canada-Chile Free Trade Agreement.
Partnering to empower Indigenous women in Chile
In early 2018, UN Women and Teck announced an extension of their partnership and the development of a new training centre to empower Indigenous Women in Northern Chile, funded through a US$1 million investment from Teck. The investment will extend the Originarias programme, and support the goal of providing Indigenous women in northern Chile with access to high-quality, culturally relevant, flexible training programs with a focus on economic development, entrepreneurship, and business management skills.
Furthering two major public health initiatives
Through our Zinc & Health program, we were proud to join our partners in the Zinc Alliance for Child Health (ZACH) — the Government of Canada and Nutrition International — to announce a $4 million commitment to extend ZACH through 2020. Since its launch in 2011, ZACH has provided 44 million children with access to life-saving zinc treatments. Building on the success of our Zinc & Health program, we developed our new Copper & Health program to address the growing risk of healthcare-acquired infections (HAIs) in Canada. Copper surfaces are being installed in healthcare facilities around the world as an innovative and cost-effective solution to HAIs. In 2017, we launched an antimicrobial copper study in four hospitals across Canada to build on the existing evidence base and help healthcare decision-makers better understand how to reduce infection rates in hospitals.
Advocating for a comprehensive approach to address the fiscal deficit challenge in Alaska
As Alaska’s state legislature continued to look at both revenue and spending solutions to address a significant budget deficit, we continued to work closely with industry associations and state legislators to support a comprehensive approach across different industries. While no review of the mining sector taxation occurred in 2017, the modest recovery in commodity prices has the state of Alaska focused on ensuring growth of the tax base to build a stronger fiscal foundation.
Regulatory engagement in Chile
We made significant progress advancing the Quebrada Blanca Phase 2 project through the Chilean Environmental Assessment process. We conducted regular engagement and dialogue with government agencies responsible for oversight and implementation of the process.
Developing employment skills in the mining industry in Chile
Teck and Fundación Chile, an innovative non-profit organization, launched a technical training program called Programa Elige Crecer. The program aims to assist people in developing new skills that can be applied in the mining industry. The program provides resources and tools that will help to boost employability in the mining industry, specifically in the Tarapacá region.
Improving mine productivity and technical training in Chile
As part of Teck’s participation in Consejo Minero (Mining Council of Chile), Teck participated in an international benchmarking study organized by the Consejo Minero’s productivity commission for large-scale copper mining, and facilitated a benchmarking visit to our Highland Valley Copper Operations in Canada. In addition, we helped to coordinate a visit between Chilean and B.C. authorities to discuss public policies for the assessment and approval of mining projects. Teck also participated in the Eleva Project, which promotes innovation and improvements to professional or technical education in mining. The project is backed by the Chilean Ministry of Economy, the Ministry of Education, the Ministry of Labor and Social Security, Corfo, the Mining Competency Council and is coordinated by Fundación Chile.
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, enabling us to evolve with the best sustainability practices in our industry. Our five largest contributions in 2017 in this area were all to trade associations. Contributions, as membership fees, totalling $3.6 million in 2017 went to the International Copper Association, Canada’s Oil Sands Innovation Alliance, the International Zinc Association, the Mining Association of Canada, and the Mining Association of British Columbia.
Political Donations Policy
In 2017, we developed and released a Political Donations Policy. This policy confirms that Teck does not make political donations and 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 in any jurisdictions. Prior to the release of our policy, we had historically made political contributions in British Columbia, including in early 2017. All contributions were made in accordance with applicable laws. We have not made political contributions outside of British Columbia.
Table 29: Political Contributions
Donation amount in 2017
BC Liberal Party
BC New Democratic Party
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 of our website. In 2017, Teck began publishing an annual voluntary Economic Contributions Report to complement and enhance our ESTMA disclosure. This report 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 the Economic Contributions page on our website for more information.
Extractive Industries Transparency Initiative
We 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 2018, 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 that we are compliant, transparent, cooperative and ethical in all matters, and that we meet our reporting requirements.