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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
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Russell A. Stamets
Contributing Editor

Richard Bistrong
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Eric Carlson
Contributing Editor

Benchmarking Alert: Digging into Glencore’s anti-bribery policy

Switzerland-based mining and commodities giant Glencore plc landed on the FCPA Blog’s top ten last year when it paid $700 million to settle widespread FCPA offenses. How does its anti-corruption and bribery policy compare?

1. Impact on peer group.

We assert our influence over joint ventures we don’t control or operate to encourage them to act in a manner consistent with our Values and Code.

2. No political contributions.

We do not seek to influence the political process by improper or corrupt means. To mitigate this risk, we do not contribute any funds or resources towards any political campaign, political party, political candidate or any politically affiliated organization.

3. No facilitation payments.

Facilitation payments are a form of bribery. We never pay, or authorize the payment of, facilitation payments. If we are asked to make a facilitation payment, we must not pay and we must inform Compliance immediately.

This is similar to Ferrari, Kraft Heinz, Burberry, Disney, Unilever, Carlsberg, Apple, Novartis, Microsoft, Volkswagen, Airbus, GM, 3M, and Pfizer that all ban facilitating payments. Coca-Cola, Tesla, and ExxonMobil might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. Extortion defense.

Glencore prioritizes the physical safety and well-being of all its employees and contractors. If our welfare or safety is at risk, we take reasonable steps to remove ourselves from danger. In exceptional circumstances, this may include making a payment to a public official to ensure our safety in the situation. We must report any such incident to Compliance as soon as we are safely able to.

5. Managing successor liability.

When considering entering into a merger or acquisition, we conduct risk-based due diligence to understand any bribery and corruption risks associated with the transaction and take steps to address any identified issues. Where we acquire the right to control or operate a business, we promptly implement this policy, associated procedures and controls.

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View the full eight-page Glencore anti-corruption and bribery policy.

View more anti-corruption policy benchmarks here.

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