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CSR Abroad – Anti-Corruption and Bribery

Corruption and bribery are present in many countries where mining and exploration activities take place. This section looks at practices Canadian companies have implemented to ensure their operations remain ethically sound and in accordance with accepted principles of good conduct, transparency, and honesty. Below are CSR practices that Canadian companies have implemented in their policies or activities to help counter corruption and bribery:

Responses by Company

Agnico Eagle Mines Limited

We have a code of ethics that is signed by all employees and contractors. We have a whistleblowing line available to all our employees. We have a grievance mechanism with communities.

American Vanadium Corp.

This will be developed as part of the overall governance program for the company.

Angkor Gold Corp.

From the CEO down to the local logistics staff, Angkor Gold has made it clear and refuses to participate in passing cash as an incentive. Our commitment has been to assist communities in improving the health, education, and economic diversification and we do that and use that as a replacement to any suggestion of corruption or bribery.

AuRico Gold Inc.

The company has anti-bribery and corruption policies in place. These policies are reviewed annually and the company’s management and site teams sign-off on their understanding.

Banro Corporation

We have a company-wide Business Conduct policy that covers this and other aspects of ethical behavior as well as a whistle-blowers policy. These are given to and discussed with all employees and posted on the Company website; all departments also have their own financial and operating guidelines that cover bribery and corruption, among other related matters. In addition, employees are required to read and sign off on such policies on a regular basis.

Barrick Gold Corp.

With thousands of employees, suppliers and contractors, working in highly-diverse countries, our exposure to potential incidents of bribery and corruption is real. Not only is corrupt and unethical behavior contrary to our corporate values of integrity and responsibility, it also erodes the social fabric of the communities where we operate. It is therefore paramount that we clearly articulate our expectations and enforce our policies on ethical conduct and decision-making across all facets of our business.

Response continued

Barrick has implemented a cross-functional global Anti-Corruption Compliance Program and has an Anti-Corruption and Anti-Bribery Policy which is available on our website. This policy guides us in all activities where corruption or bribery may be a possibility. Our annual Code of Conduct training now includes a section on Anti-Bribery and Anti-Corruption as well, with more than 4,600 employees receiving training in 2014. 

More information:

Cameco Corporation

We have an International Business Conduct Program that sets out the principles, practices and rules to follow to ensure compliance with anti-corruption laws. Footnote 1

Delta Gold Corp.

Corruption and bribery are considered simply unacceptable at the company.

Goldcorp Inc.

Goldcorp’s commitment to acting with integrity includes not engaging in or tolerating fraud or corruption. We invest time and resources to create an awareness of Goldcorp’s commitment to acting with integrity. This means clearly defining the expectations we have for employees and third parties with regards to ethical leadership and the negative implications that these unethical practices could bring to the company and to those parties involved in this type of activity.

Response continued

Goldcorp defines fraud as an intentional act or omission designed to deceive another person or to obtain a benefit that one is not entitled to. For example, fraudulent activities could include instances of theft of assets, misuse of company resources, intentional misreporting of financial and/or operational data, among others. Corruption, by definition, is an instance of fraud triggered by giving or offering monetary or other benefit to another person in order to secure a benefit, retain business or obtain any other improper advantage in conducting business. Corruption can occur at two different instances: private sector corruption (between private companies and/or individuals) and public sector corruption (between private entities and government officials). The Code of Conduct sets clear standards and expectations for employees, officers, directors and third parties providing goods and services to Goldcorp relating to compliance with the anti-fraud and anti-corruption provisions. Violations of these provisions are grounds for disciplinary action up to and including immediate termination of employment and possible legal prosecution. In an effort to provide more clarity and further guidance around Goldcorp’s stance on bribery and corruption, the company released a stand-alone Anti-Bribery and Anti-Corruption Policy in 2013, together with a structured rollout program to ensure awareness and adherence to this new policy throughout the organization. Goldcorp also has risk-based programs in place to prevent and detect potential instances of fraud and corruption proactively in order to ensure compliance with our internal policies and with local and international laws and regulations related to these topics. Footnote 1

More information:

HudBay Minerals Inc.

Our code of conduct includes specific provisions prohibiting corrupt practices including bribery, and has been translated into Spanish for our South American colleagues. We carry out anti-corruption and code of conduct training for employees, including comprehensive training at our foreign operations, and require personnel with signing authority to annually sign an acknowledgement of the code of conduct.

Response continued

Through our internal audit program we carry out reviews of the enterprise level and local level processes for communicating and complying with our code of conduct and with the United States Foreign Corrupt Practices Act. In 2014 we had an external consultant make a presentation to our corporate development group on how to conduct anti-corruption due diligence on acquisition targets and in 2015 we intend to review our vendor onboarding due diligence to ensure the integrity of our vendors.

Kinross Gold Corp.

The Kinross Code of Business Conduct and Ethics (Code) establishes policies for Kinross directors, employees and contractors, and applies to all Kinross operations and to Kinross-operated joint ventures. The Code is available in all of the applicable official languages and addresses workplace policies, environment, health and safety issues, third-party relationships, legal compliance, confidentiality issues and the use of Kinross assets.

Response continued

We carry out compliance training and education programs with all sites and regions to ensure employees understand and respect company expectations for ethical behaviour and compliance, and risks of non-compliance with the Code. In addition, all employees in management roles are required to acknowledge by signature on an annual basis that they have read and understood, have not violated, and are not aware of any violations of the Code. The Code and the associated training establish strict controls to prohibit corruption, including participation in any bribes, kickbacks, or improper inducements or payments to any public official.

In addition, the Company has established a position of Vice-President, Compliance to provide dedicated leadership and oversight of the Company’s global compliance program.

More information:

MBAC Fertilizer Corp.

We created a direct line to our Audit Committee where employees can openly and confidentially communicate any knowledge of corruption (whistleblower), bribery and fraud to the committee. We also have some internal controls in place that try to prevent corruption and bribery.

NOVAGOLD Resources Inc.

Our Anti-Corruption, Anti-Bribery, Anti-Fraud Policy sets out NOVAGOLD’s expectations and requirements relating to the prohibition, recognition, reporting, and investigation of suspected corruption, bribery, fraud, deceit, or other improper conduct.

Sherritt International Corporation

There is an enterprise-wide anti-corruption and bribery program in place. We provide training on the corresponding policy and subject matter at all our divisions, using culturally appropriate methods. In addition, the policy and training are regularly updated to align with best practices. We also have an internal communication program to build general awareness on this issue.

Silvercorp Metals Inc.

The company attempts to discourage corruption and bribery by having the programs address the Corruption of Foreign Public Officials Act. Footnote 1

Suncor Energy Inc.

The foundation of our anti-corruption and anti-bribery program is our improper payments policy that details our expectations around anti-bribery and corruption. Our program also consists of implementing contractual protections, audits and third-party contractor pre-qualification. To ensure continued adherence to policies prohibiting bribery and corruption, all employees and certain contractors and suppliers must annually read and sign off on the Improper Payments policy, as well as other policies relating to Suncor’s expectations for lawful and ethical conduct.

Response continued

We also complete more comprehensive training for those employees working in higher-risk roles such as in supply chain or our international operations. We also encourage our employees and contractors to raise ethical concerns with management, Legal, Corporate Security, Human Resources and/or our Internal Audit departments, without fear of reprisal. In addition, we have established an integrity hotline to provide a means for our employees and contractors to report issues of concern anonymously to a third-party service provider. The integrity hotline is available 24 hours a day, seven days a week. All issues of a serious nature are investigated by Internal Audit or the chief compliance officer. The audit committee receives regular updates on activities relating to the integrity hotline.

Unigold Inc.

The company addresses corruption and bribery through policies, procedures, and by having strong controls on finances.

U.S. Oil Sands Inc.

Governance is established by our Board of Directors and is captured within various sub-committee charters and policy statements; notably in our Code of Business Conduct and Ethics.

Other Practices

A company has an anti-corruption and anti-bribery policy, a whistleblower policy and a code of business ethics that have been approved by its Board.  This company has provided training on these policies to all its personnel and does annual policy attestations. The policies are also reviewed annually by a corporate governance and nominating committee.

A company indicated that it conveys to all employees the necessity of scrupulous avoidance of any act or payment that could be interpreted as contributing to corruption. This company indicated that memos on this subject that include recent Canadian government laws have been circulated.

In addition, the following companies indicated that they have a program or plan to prevent corruption and bribery, but declined to include any further details:

  • Candente Copper Corp.
  • Handa Copper Corp.
  • Nortec Minerals Corp.


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