Glencore : 2022 Ethics and Compliance Report

Key topics

Welcome

Welcome to Glencore's 2022 Ethics and Compliance Report. This report provides a detailed overview of our Ethics and Compliance Programme (our Programme) and gives insight into the achievements and progress we have made throughout the year.

Keep an eye out for the "Our Programme in action" stories and the stories from our Compliance colleagues from around the globe which provide a glimpse into their daily activities.

Total commitment

to being a responsible and ethical operator

Quick link

Ethics and compliance page on our website:

Explore our annual reporting suite online at: glencore.com/publications

Video links

Throughout the report, see the video links to find out more.

Introduction

Governance and structure

Our approach

Key topics

Our business partners

Additional information

Committed to acting ethically and responsibly across all aspects of our business

Since the publication of that report, we have resolved the investigations by authorities in the United States, the United Kingdom and Brazil concerning bribery and market manipulation, and in relation to past misconduct in the Democratic Republic

of the Congo. We also continue to cooperate with the Swiss and Dutch authorities on their ongoing investigations.

Under the resolutions with the US Department of Justice, two independent compliance monitors are to be appointed. We look forward to constructively working with them to see how we can improve on the extensive efforts we have made over the last number of years to improve our Ethics and Compliance Programme.

We are hopeful that as a result, our Ethics and Compliance Programme will be stronger than ever, both in design and in implementation.

This Ethics and Compliance Report serves as a comprehensive guide to our Ethics and Compliance Programme and provides insight on the continuous improvements we have made. Together with our other reports - see here - it reflects our commitment to genuine transparency.

There is still work to do. We will keep on challenging and supporting our management team as the Company seeks to capitalise on the opportunities presented by the future in an ethical and transparent manner.

Kalidas Madhavpeddi

Chairman

Kalidas Madhavpeddi

Chairman

Dear Stakeholders,

Last year we published our first Ethics and Compliance Report, which was positively received both internally and externally. Our stakeholders rightfully expect transparency from us. They want to understand what we are doing to promote ethics and compliance in our Company and in our industry, and we hope by sharing what we are doing at Glencore, we can contribute to enhancing governance more broadly.

Glencore today is not the company it was when the unacceptable practices identified in the investigations occurred. The Board and the management team are committed to operating a company that creates value for all stakeholders by operating transparently under a well-defined set of Values, with openness and integrity at the forefront. We want Glencore to be an employer of choice, attracting and retaining the best talent and competing not only in terms of the unique value proposition that Glencore has to offer, but also in its commitment to acting ethically and responsibly across all aspects of its business.

Operating responsibly and ethically, while creating sustainable long-term value

Let me be clear - we own the misconduct which occurred. One of our core Values is Responsibility - this means we acknowledge what happened, take responsibility for it, but most importantly, learn from it and prevent it from happening again. The matters investigated are therefore behind the Company but not forgotten.

Unethical behaviour has no place in Glencore, and the Board, management team and I are very clear about the culture that we want and our complete commitment to being a responsible and ethical operator.

We have taken significant action and made significant investments towards building and implementing a best-in-class Ethics and Compliance Programme to ensure that our core controls are entrenched and effective across our business.

This trust does not develop through talking about responsibility, integrity and openness in a glossy publication, but is rather built through our actions and demonstrating these qualities in all that we do.

This report embodies our commitment to being transparent with you, our stakeholders, about these very real actions we have taken and the progress we have made. It is also, however, about being honest about where we are behind and the gaps we have to fill. We have made significant strides in our efforts, but the journey will never be over.

We have a great business, with a unique position in producing, recycling, sourcing, marketing and distributing the commodities that enable the energy transition and

have the portfolio of energy and critical minerals necessary to meet the needs of

Gary Nagle

Chief Executive Officer

I'm pleased to share with you this year's Ethics and Compliance Report.

A lot has happened since we published our first Ethics and Compliance Report

a year ago. Most notably, the investigations which began in 2018 into past misconduct have ended in resolutions with the US, UK and Brazilian authorities, which include the obligation for the Company to appoint two independent compliance monitors.

We take pride in the company we work for and believe in our Purpose of responsibly sourcing the commodities that advance everyday life. I am very proud of the Ethics and Compliance Programme that we have built and the strides that we have made to reinforce our commitment to an ethical culture throughout our business. This report is a testament to these efforts, which began before the investigations commenced.

We recognise that there is always room for improvement. We are therefore looking forward to working constructively with the monitors that are to be appointed as part of our resolutions with the DOJ.

We understand, now more than ever, that any wrongdoing can impact our reputation, our relationships with stakeholders and our bottom line. Building and maintaining trust takes time and effort.

today and tomorrow.

As always, we remain focused on operating responsibly and ethically and creating sustainable long-term value for all our stakeholders.

Thank you for your continued support and trust in Glencore.

Gary Nagle

Chief Executive Officer

Our approach

Key topics

Introduction

We believe that a strong Ethics and Compliance Programme grounded in our Values, particularly integrity and openness, is critical to ensuring we are a responsible and ethical company.

Shaun Teichner

General Counsel

Daniel Silver

Head of Compliance

We recognise that a number of our stakeholders, including our investors, governments, as well as employees, have an interest in our compliance culture and our Programme. This is particularly so given the challenges we have faced as a Group over the last few years arising from the ongoing investigations and the historical misconduct which they identified.

Glencore has invested substantial resources, starting before the investigations commenced, to build and implement a best-in-class Programme and has made significant investments in compliance personnel, systems and external assurance. We believe that a strong Ethics and Compliance Programme grounded in our Values, particularly integrity and openness, is critical to ensuring we are a responsible and ethical company.

We have therefore prepared this report to provide a detailed overview of our Programme, including a summary of our approach, compliance structure and the various systems and processes that we implement, to support our Programme and promote an ethical culture. We want to be transparent about the challenges we face, how we learn from them and how we use them as an opportunity to improve and push ourselves to do better. This report sets out the efforts that have gone into building our Programme, raising awareness of it, monitoring it, and maintaining and improving it, and the steps we take to ensure it is properly embedded across

our business.

Our business is diverse and broad, and ensuring our Programme is implemented in every office and industrial asset requires significant ongoing effort. Because of the size and diversity of our business, comprehensive Programme implementation across the entire business remains our biggest challenge. It was a focus area in 2022, and continues to be a key priority in 2023. Also, by openly communicating on our Programme, we hope we can contribute to the continued development and evolution of ethics and compliance programmes and the promotion of responsible business practices in our industry and elsewhere.

In order to measure the effectiveness of our Programme and ensure it remains up to date, we regularly assess the Programme against guidance from relevant authorities and NGOs, industry best practice and peer benchmarks. We have this year particularly considered the specific recommendations made by various NGOs following the resolution of our investigations.

We similarly understand that our stakeholders want us to report on our Programme in a manner that supports their assessment and understanding of it. Accordingly, we have set out in the Appendix to this report, a table which includes a number of key indicators on ethics and compliance programmes from various organisations and where we address those indicators in this report.

We look forward to continued engagement on this critical topic.