Why this is important for ArcelorMittal
Compliance with regulations is a core responsibility, but this alone is not enough. Organisations today must strive to create a positive culture in which everyone wants and knows how to do the right thing.
What we mean by integrity is summed up in three pillars: being honest and transparent; treating people with dignity and respect; and setting a good example. We expect all our employees to act with integrity in everything they do – from the way they treat colleagues to relationships with external stakeholders like our communities, our suppliers and our customers.
This commitment to integrity is supported by a comprehensive framework of policies in areas such as human rights, anti-corruption, and insider dealing, as well as a robust code of business conduct.
Our integrity is supported by the strong governance systems we have in place, explained in the governance section.
Respect for human rights encompasses a broad range of issues and we know this is an area of considerable interest to both our customers and investors.
Our policy draws from ArcelorMittal’s existing policies and procedures, such as those dealing with communities, security, human resources, procurement, and health, safety and the environment. When it comes to identifying and managing human rights issues, the processes are embedded into the relevant departments – human resources, purchasing, health and safety, security, compliance, environment, and community relations.
The language used to discuss human rights can vary enormously from context to context. We need to ensure such discussions are relevant and accessible to all our employees. This can be a challenge, particularly given the need to work across functions and countries on these issues. This is also true when we are engaging with host governments on human rights issues, and needs to be managed with sensitivity.
Our work on human rights is increasingly driven through the working groups for our individual outcomes, and country dashboard assessments against the 10 outcomes. For example, outcome 1 covers human rights in relation to our employees, while in outcome 7 we detail our work on conditions for tin miners in Indonesia.
Confidential reporting of breaches
Both employees and other stakeholders can report any breaches of our policies and standards via the confidential whistleblowing facility on our corporate website. We also have confidential whistleblowing hotlines in 30 major countries of operation.
In addition, all our sites have a mechanism in place for complaints, disputes and grievances in line with our company standards.
As our group compliance officer, Henk Scheffer drives the pursuit of transparent good governance across ArcelorMittal.
Ethics and integrity
Whilst four fifths of our employees have completed training in the code of conduct over the past three years, where we see particular compliance risks, we provide focused training. In 2015 we provided workshops in both Ukraine and Kazakhstan.
Our integrity project has been the main focus for us in 2015. Since integrity covers everything we do, everywhere, we’ve been reviewing the different ways in which we measure this, through stakeholder surveys, compliance reports and so on. The owners of our different policies and stakeholder surveys have been meeting regularly to share their results and identify trends. We are looking at ways to combine these measurements into a single system to monitor these non-financial aspects of the business.
It’s important to make sure that we are carrying out due diligence on the recipients of our community investment contributions. So, in 2015, we updated our community contributions procedure, linked to our anti-corruption procedure, as guidance for our employees.
During 2015, there were 175 complaints received relating to alleged fraud, which were referred to and duly reviewed by the Company’s Internal Assurance Department. Following review by the Audit & Risk Committee, none of these complaints was found to be significant.
Our human rights policy is based on the United Nations Guiding Principles for Business and Human Rights and is supported by training for all employees. We repeat general training for all employees every three years, and carry out more specific training for employees in areas of higher risk, specifically purchasing and security. In 2015, 81% of our employees were up to date with their training.
In 2015 we spent significant time engaging external parties to discuss how we assess risks related to human rights, and how we can act on them. This is an area of evolving good practice, and our continued role in co-chairing the CSR Europe Business and Human Rights Working Group allows us to share experiences and work with peer companies.
At group level, we had planned to complete some country-based human rights risk assessments in 2015, as we had done in 2012 and 2013. Instead, we decided to conduct a comprehensive review of the group’s approach to human rights, and explore how we could embed human rights further into our SD outcomes and other processes. This work, coordinated by an external consultant, showed us how much progress we’ve made in raising understanding of human rights issues across the business, and that we have some of the management tools needed for ongoing due diligence. It also highlighted where we can improve, including how we can better identify social risks at site level, and how our 10 outcomes will support us to observe human rights principles.
In 2016, we’ll be reviewing these findings across the different functions of the group and developing an action plan to make sure capitalise on the progress we have made so far, and continue to embed an effective approach to human rights into our business.