Implementing the Management of Business Ethics

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Business ethics by definition, is the application of the ethical business practices, sound systems of corporate governance and transparency to support sustainable development. In 2018, Teck’s public policy engagement focused on supporting actions to address climate change, water management, environmental regulations, and indigenous peoples.

At Teck, there are many individuals who are involved in implementing the management of business ethics. At the senior leadership level, they are the Senior Vice President, Commercial and Legal Affairs, who ensures proactive, timely and effective overview of the company’s legal and anti-corruption practices. The Director of Government Affairs oversees all of Teck’s public policy initiatives and government engagement. At an operational level, every employee, officer and director at Teck is also responsible for adhering to the Code of Ethics and for upholding strong business ethics. Teck works with numerous local, national and international organizations to support the company’s ethical conduct.

Teck conducts their business activities in an honest and ethical manner. The program, Doing What’s Right, is designed to maintain an ethical workplace to ensure that the moral and ethical principles within the Code of Ethics are upheld. It is supported by additional ethics-related policies and procedures such as the Competition and Antitrust Law Compliance Policy, Anti-Corruption Compliance Policy and Manual, Human Rights Policy, Employee Trading Policy, Employee Concerns Disclosure Program, and Corporate Disclosure Policy. 

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Employees are required to report any violations or potential violations of the Code of Ethics through the program which includes the whistleblower hotline and web portal, which are managed by a third party. The hotline and web portal are available 24 hours a day, seven days a week, in all jurisdictions in which they have employees providing confidential and secure means for Teck’s employees to report their concerns. Teck maintains a database of the reports made and the outcomes of each report is also tracked within the databaseю

Teck also has an anti-corruption program which focuses on potentially high risk activities such as work in high-risk countries, use of independent advisors, third-party due diligence, and sales to state-owned enterprises. One component of their anti-fraud program is Teck’s internal audit for anti-corruption. All operations and business activities are assessed for risks related to corruption which is done on a periodic basis. Every year, the Internal Audit department evaluates the effectiveness of Teck’s system of Internal Control Over Financial reporting (ICFR). This includes an overall evaluation of the design and operating effectiveness of those internal controls intended to prevent and/or detect fraudulent activities at a significant level.

Teck also provides anti-corruption training, at least every two years, to their employees who may be exposed to corruption. All charitable donations, sponsorships and community investment must comply with Teck’s Anti-Corruption Policy. This prohibits donations that would improperly benefit individuals.

Teck focuses on being collaborative and transparent with a solutions-based approach in their engagements with governments in the jurisdictions in which they operate. They take a systematic approach to monitoring and identifying political, legislative and regulatory developments in order to identify public policy opportunities and risks in areas pertaining to the business. Teck does not make use of corporate resources such as funds and goods for the purpose of contributing to a political party or any individual candidate seeking election at any level of government. 

Teck’s Government Affairs professionals engage with governments directly through written advocacy letters and submissions, and roundtable and bilateral meetings. Teck also seeks and retains advice from knowledgeable experts to augment corporate and local in-house professionals in some jurisdictions. Teck reports on their advocacy efforts in an open and transparent manner, conforming to all lobbying laws and requirements, including publicly reporting on their activities. Teck also regularly updates compliance requirements for all corporate and site-based employees who interact with governments.

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