Vale

Ethics and Conduct Office

Overview

Vale S.A. is a global metals and mining company headquartered in Brazil. Its main focus is on iron ore mining and the production of nickel. In addition, it produces biodiesel coal, cobalt, copper, ferroalloys, fertilizers, manganese, pellets and PGMs  and operates hydro-electric plants, refineries and steel plants. It operates in 27 different countries across the globe. Vale’s Code of Ethics and Conduct sets out the ethical standards Vale’s employees are expected to abide by. The Ethics and Conduct Office, available for Vale’s internal and external stakeholders, is an independent communications tool for reporting violations or suspected violations of any of the points described in this Code.

Who can access it? 

Anyone, whether or not connected with Vale, who feels negatively affected by Vale due to a violation of the Code of Ethics or our values, or who has a problem that has not been resolved through the company’s everyday channels, may use the Ethics and Conduct Office. Vale specifically mentions employees, suppliers, members of the Executive Board, Board of Directors, Advisory Committees and Audit Council, as well as community representatives as users of the mechanism.

How does it work?

Allegations to bring to the Ethics and Conduct Office may include issues related to accounting, auditing, internal controls, standards, policies, ethics, human rights or the environment. The Ethics and Conduct Office may also be used when Vale’s more everyday mechanisms for resolving problems, such as call centres, do not provide an adequate solution to a problem that has already been reported.

There are five ways of submitting an allegation:

  1. Electronic form
  2. E-mail: ethicsandconduct@vale.com
  3. Letter to: Vale S.A. – AlertLine, PMB 3767, 3950 Ballantyne Corporate Place, Suite 300, Charlotte, NC 28277, USA
  4. Phone: Calls are toll-free and there is a specific number for each country. Click here to see a list of phone numbers by country. Note: from a country without a specific phone number, a collect call to the phone number in Brazil can be made.
  5. In person: To schedule a visit to the Ethics and Conduct Office, please call 55 21 3814 5380. 

When making an allegation using the electronic form, by phone or by email, the complainant will receive an access code and password that may subsequently be used to submit additional information or verify the investigation’s progress and results. To check the status of a submitted allegation, the complainant can access the Ethics and Conduct Office's online platform by inserting the access code and password.

Allegations may be made in the official language of the complainant’s country of origin, and should whenever possible feature enough details to enable the reported facts to be investigated.

According to the Ethics and Conduct Office, whether or not complainants identity themselves, their anonymity is always guaranteed. Anonymous allegations will be investigated provided that they feature enough data and information to enable a proper investigation and that they are permitted by the country’s legislation.

In the case of Vale employees in Canada, allegations about possible irregularities or improprieties related to the workplace and employees should be reported directly to local management. Such as the following:

  • Workplace health and safety issues that endanger people’s lives;
  • Violence, bullying, threats or harassment at work;
  • Sexual harassment involving employees;
  • Issues related to the workplace, such as discipline, promotions, job recommendations, and shifts;
  • Allegations related to the company’ local environmental obligations. 

When an allegation is submitted it is forwarded to the Ethics and Conduct Office, which reports to the chairman of Vale’s Board of Directors. The Ethics and Conduct Office is the area delegated by the Board of Directors to handle investigations of complaints or other issues arising from the channel, and to manage the flow of information together with the Board of Directors. The Ethics and Conduct Office issues a report giving the results of each investigation within the channel’s scope directly to the chairman of the Board of Directors, recording the evidence obtained for the reported situations, as well as appropriate actions to resolve irregularities.

After being submitted to the Ethics and Conduct Office, complaints go through a strict screening process that verifies, for example, whether there is enough information for an investigation. In the case of complaints with insufficient information, the Ethics and Conduct Office may request more details via the complaint-tracking page. Complainants then have a period of 30 days to provide additional information. Complaints that are feasible to investigate are submitted to this end. The Ethics and Conduct Office is committed to seeking fast and agile resolutions to complaints and also to identifying opportunities to improve Vale’s processes. Once an investigation has been completed, the appropriate measures are taken and the case is closed.

Vale states to commit to guaranteeing confidentiality, independence, impartiality and immunity in the treatment, investigation and filing of information received, including the rights of complainants and the people cited. Any kind of retaliation against those who use the Ethics and Conduct Office in good faith is forbidden, regardless of the results of investigations.

Outcome 

Whenever a complaint is corroborated, corrective action is taken, which may involve penalties, whose severity will vary in accordance with the type of wrongdoing and the facts reported. The action taken may range from a simple statement to the person’s superiors to counselling with the HR area, scheduling of coaching, formal warnings or even termination (for cause or otherwise).

Whether or not a complaint is corroborated, whenever a case is closed, the complainant has access to this information on the complaint follow-up page. With regard to actions and penalties incurred by reported people, in general we do not inform complainants of the measures taken in order to respect the right to privacy of all those involved.

References 

Vale Company Website

Code of Ethics and Conduct

Webpage of the Ethics and Conduct Office

Last edited: 
March, 2015

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