Glencore : 2022 Voluntary Principles on Security and Human Rights

Committed to respecting human rights.

Introduction

We recognise that our industrial assets have the greatest potential to impact the security and human rights of both our workforce and neighbouring communities.

Glencore is one of the world's largest global diversified natural resource companies and a major producer and marketer of more than 60 commodities. Our industrial business spans the metals and energy markets, producing multiple commodities. Our marketing business moves commodities from where they are plentiful to where they are needed. We have a strong footprint of industrial assets and offices in over 35 countries.

In March 2015, Glencore became a member of the Initiative of the Voluntary Principles on Security and Human Rights (VPs). We support, implement and promote the VPs. We train our security employees and private security contractors on the VPs and are clear about our expectations when engaging with public security.

This report covers the actions Glencore has taken to implement the VPs during 2022 and details our implementation of the VPs at our industrial assets. It excludes our activities at our marketing offices.

Quick link

Our sustainability communications are available on our website:

glencore.com/publications

Find out more

How we are implementing the VPs in the DRC, see page 7

Introduction

Commitment to the Voluntary Principles

Policies, procedures and related activities

Country implementation

Public Statement of commitment

Senior management oversight

Our Board Health, Safety, Environment and Communities (HSEC) Committee sets the strategic direction for our sustainability activities and oversees the development and implementation of our strategic health, safety, environment, social performance, and human rights programmes.

Its members are Peter Coates (Committee Chair), Cynthia Carroll, Patrice Merrin, and Kalidas Madhavpeddi (Group Chairman). All four members are non-executive directors with extensive operational experience. Their knowledge and understanding, acquired over a number of years in operational roles, equips them to oversee the embedding of human rights and HSEC principles, including those

Mining Principles (ICMM) and UN Sustainable Development Goals (SDGs).

We seek to avoid causing or contributing to adverse human rights impacts; preventing or mitigating adverse human rights impacts; and we seek to make a positive contribution to the advancement of human rights of all people, including vulnerable groups. In the event we directly or indirectly cause or contribute to an adverse impact on human rights, we provide for, or cooperate in, processes to enable appropriate remedy and/or a corrective action plan.

Our approach is based on increasing awareness of human rights, building capacity and promoting stakeholder dialogue. We aim to build strong and trusting relationships in the societies where we operate and pay special attention to the rights of vulnerable groups that may be impacted by our operations.

We require our industrial assets to operate grievance processes designed to be legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of continuous learning, and based on engagement and dialogue. Where people have complaints or grievances, we aim to investigate and resolve them at a local level.

During 2022, we reviewed and updated our Incident Management Procedure which includes Social Performance and Human Rights Incidents Classifications. This Procedure sets out the process for capturing, recording and reporting security incidents. We require our industrial assets to classify, notify and report actual or potential social performance or human rights incidents in accordance with the Procedure's requirements. We undertake investigations to identify direct and/or contributing factors to prevent repeat occurences.

As part of the rollout of the revised Procedure, we held a series of global workshops attended by representatives of our Health and Safety, Environmental and Social Performance, Human Rights and Legal functions.

We are committed to working alongside neighbouring communities and strategic stakeholders to protect the safety and security of our workforce and the communities that interact with our industrial assets. We do this in a manner that respects human rights and aligns with our Values and commitment to operating responsibly and ethically.

While some of our operating jurisdictions have a higher potential risk of security-related human rights breaches, we expect our people to avoid complicity and uphold international standards at all our industrial assets.

relevant to the implementation of the VPs, into our corporate culture, policy, and strategy.

Our CEO and Chairman reference our membership of the VPs, when appropriate, in their engagement activities with both our external stakeholders and our workforce.

Commitment to respecting human rights

We respect the dignity and human rights of our workforce and our business partners, the communities in which we live and work, and others who may be affected by our activities.

We are committed to respecting human rights in line with the UN Universal Declaration of Human Rights, International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the ILO Forced Labour Protocol, the UN Guiding Principles and the UN Global Compact. We are also aligned with the ICMM

In July 2022, we hosted a three-day internal human rights workshop attended by our human rights, security, social performance and sustainability practitioners from across our industrial assets. Opened by our CEO and facilitated by external subject matter experts, the workshop addressed a range of human rights and security topics with keynote speakers including a representative of DCAF (the Geneva Centre for Security Sector Governance) who spoke about emerging issues in security sector governance.

The workshop was an opportunity for participants to share knowledge and build their understanding of Glencore's salient human rights issues as well as the practical application of cross-functional human rights risk assessments. One outcome of the July human rights workshop was a commitment to host a series of security and VPs specific workshops, which will be held during 2023.

Our global presence:

Engagement in the Voluntary Principles Initiative (VPI)

During 2022, we engaged with the Swiss government on the VPs, including on the application of the government of the Democratic Republic of the Congo (DRC) to become a member of the VPI.

In May 2022, we participated in the annual VPI Plenary in Toronto, which provided knowledge building and networking opportunities.

Our local teams have participated in the in-country working groups active in the DRC and Peru (both in Lima and Cusco).

In the DRC, the working group is led by DCAF. In 2022 it raised awareness of the VPs among extractive companies present in the DRC. Glencore also participated in a multi- stakeholder advisory group that supported the DRC's application to join the VPI.

In Peru, the National Society of Mining, Petroleum, and Energy initiated a working group on the VPs. This working group has conducted training and shared case studies contributed by members. Our industrial asset Antapaccay has participated in all meetings organised by this working group.

In December 2022, we joined the VPI SteerCo in Geneva as part of the corporate pillar team.

We continued to take part in the corporate pillar calls, which enabled us to input into the activities of the VPI.

We are committed to providing timely responses to reasonable requests for information from other participants of the VPI to facilitate greater understanding of the issues related to the implementation of the VPs. We participate in national and regional VPs working groups where they exist in our operating jurisdictions.

Our participation in the annual Plenary, the corporate pillar and in-country working groups, as well as this report, are aligned with the requirements set out in the VPI's Governance Rules.

A representative of DCAF was a guest speaker at our Human Rights workshop, see page 2, addressing the topic of "Emerging issues in security sector governance.

In early 2023, we became an observer of the International Code of Conduct Association

- ICoCA.

Transparency

We report on our membership of the VPI and implementation of the VPs in our Annual and Sustainability Reports. We make our annual VPs report publicly available on our website at Glencore.com/publications.

We are a member of the ICMM. We align our policies with its Sustainable Development Framework, which includes a commitment to uphold human rights and to address risks relating to security-related human rights breaches.

Awareness and embedding of the VPs in our operating procedures occurs on a continuous basis. In 2022, we hosted a three-day human rights and security workshop attended by representatives from across our industrial assets, see page 2. We appointed a Corporate Security Advisor to supplement and support existing operational and department security specialists and reinforce the operationalisation of the VPs across our industrial assets.

In 2022, we launched our Responsible Sourcing Policy and Standard including supplier training modules on Glencore's commitment to human rights and the VPs. Our Responsible Sourcing Policy and Standard, along with our Group Security Standard, make explicit our requirements for appropriate due diligence on private security providers and adherence to the VPs.

Extensive internal engagement has been undertaken with regional and local Procurement Teams to further embed our commitments into our processes.

An outcome of the 2022 Human Rights Workshop was a commitment to host a series of specific workshops on security and the VPs during 2023, starting in Johannesburg in March, with other regions

• Latin America, Kazakhstan, Europe, North America, and Asia/Pacific - planned for the rest of the year.

Respect for human rights is enshrined in our Code of Conduct, which reflects our Values and our Purpose, and sets our expectations on how to do business safely, responsibly, ethically and legally. It references our commitment to the VPs and we also endorse the VPs within our public Group Human Rights Policy, and through our internal Human Rights and Security Standards.

We disseminate our Values, Code of Conduct, policies, and standards to our industrial assets, where they are included in induction training with annual refreshers for employees. Training on these reflects local and job function needs. Our industrial asset-based management teams also run site-specific training programmes, which reflect local needs and cultures.

The development of our current Group policy architecture and its underlying policies, standards, procedures, and guidelines considered the commitments we are required to meet through our membership and support for external organisations. These include the VPs, the United Nations (UN) Global Compact, International Labour Organization Declaration on Fundamental Principles and Rights at Work, UN Guiding Principles on Business and Human Rights and the ICMM's Performance Expectations.

Our current Group Human Rights Policy was peer-reviewed by leading international human rights practitioners, academics, and community members prior to its adoption. The Policy applies to all employees, directors and officers, as well as contractors under Glencore's direct supervision, working for a Glencore office or industrial asset directly or indirectly controlled or operated by Glencore plc worldwide.

Our Policy requires our industrial assets to conduct human rights due diligence to identify, prevent and mitigate human rights risks and impacts across our industrial activities.

We aligned our Human Rights and Security Standards with leading practice. They were developed in consultation with Glencore functional specialists and external peer reviewers. Following their rollout in 2021, we are tracking implementation progress through a gap analysis for each industrial asset and targeting substantial implementation by the end of 2023.

Our approach to assurance is designed to be as effective and efficient as possible, and requires our commodity departments to plan and execute assurance plans for their industrial assets that include our Human Rights and Security Standards, with a risk-based prioritisation.

In 2022, our Internal Audit function continued its programme of assurance against the VPs with our industrial assets, with a risk-based prioritisation.

Our HSEC&HR Incident Management Procedure required our industrial assets to monitor and review high-potential security incidents to identify causes and improve controls and management systems. These findings and the lessons learnt are shared across the Group.

We value our relationships with our business partners, so we strive to be fair, open and transparent in our dealings with them. In turn, we expect them to share our commitment to ethical, safe and responsible business practices.

We have a Group target for community and human rights: do not cause or contribute to incidents resulting in severe human rights impacts. We report on our progress against this target in our annual Sustainability Report.

In January 2023, Glencore formalised its Observer status with ICoCA (International Code of Conduct Association for Private Security Service Providers' Association), and has presented and participated in its regional security workshops.

Assessing security impact, risks, and opportunities

Our Human Rights Standard requires our industrial assets with a high risk rating to conduct a human rights impact assessment (HRIA) using competent third-party external expert(s) and to review, and where required update, the HRIA at least every five years, or sooner if required based on risk. Our Security Standard defines the minimum requirements for our industrial assets to identify, assess and manage security-related threats, risks, and potential impacts to people and assets.

We developed the Security Standard to align with the requirements of our Human Rights and Social Performance Policies and to meet our internal and external commitments. It recognises that from a security perspective our area of influence may be impacted by our private security activities, as well as those undertaken by public security providers.

We require our industrial assets to conduct threat and risk assessments and security vulnerability assessments based on the local security context. These assessments identify security-related threats, risks, and potential impacts to people (including women,

children, Indigenous Peoples, and other vulnerable groups) and our industrial assets.

Our industrial assets must integrate the findings into their business planning and review annually, at both industrial asset and commodity department levels. The security impacts, risks and opportunities are reviewed at a suitable frequency based on risk, and updated, if required, in response to changes in the industrial asset's area of influence and security context.

We require our industrial assets to identify, report, investigate, and record security- related incidents, as well as human rights allegations, community complaints and grievances, impacts or abuses by both public and private security providers as they pertain to the industrial asset, in accordance with our revised HSEC&HR Incident Management Procedure. Our industrial assets must communicate lessons learnt from incident investigations with relevant stakeholders, taking into consideration the classification and sensitivity of security-related information.

Working with private security providers

We require our industrial assets to conduct due diligence and screening of their private security providers in accordance with our Responsible Sourcing Policy and our internal Responsible Sourcing and Know your Counterparty Standards prior to engaging their services and to verify whether the organisation has:

• The relevant competencies, qualifications, experience, and authorisations as appropriate;