Human Rights and Operations
Investment and Procurement Practices
We take our commitment to act with integrity very seriously. Our Code of Conduct specifically addresses Goldcorp’s dealings with third parties, such as contractors, and requires these parties to act in compliance with our Code while conducting business for or on behalf of Goldcorp. The Code prohibits kickbacks, rebates or “under-the-table” payments for purchases. The Code also provides clear guidelines with regard to giving and receiving gifts and entertainment to or from business partners.
We have been working hard to raise the visibility of this commitment across the entire organization and particularly those locations and functions that have greater exposure to corruption risks. Violations of the Code are subject to disciplinary action, up to and including termination of employment. In 2012, Goldcorp launched the Ethics from the Ground Up program to maintain and increase awareness of the company’s ethical principles and to assist our employees and other stakeholders to understand Goldcorp’s culture of compliance. This program promotes awareness of our third-party-managed channels for reporting concerns related to the Code. Each concern raised through the dedicated hotline, email or mailing address is reviewed and managed by our Director, Ethics and Compliance, along with the corporate Ethics Committee and site-based committees made up of local management. In 2013, Goldcorp created an Ethics Committee Charter, which gives the Ethics Committee a mandate from the Board of Directors to ensure that all sites are in compliance with our Code of Conduct and to investigate any reports to the contrary as reported through our Ethics hotline. More information on the types of issues that were raised in 2013 can be found under Human Rights Grievances.
As part of our approach to risk management and impact assessment, we review significant investments against numerous criteria, including human rights risks. This issue is of particular interest in areas that have a history of alleged violations. Goldcorp defines “significant agreements” as those that either moved the organization into a position of ownership of another entity or initiated a capital investment project that was material to financial accounts. There were 221 such investments and contracts reported signed at our sites in 2013, and 43% had been screened or included human rights clauses in them when signed.
In addition to investment screening, we recognize that we have a responsibility to be diligent regarding our supply chain. In December 2013, the Canada and US region incorporated human rights clauses into the Standard Terms and Conditions for supply contracts.
Out of 318 contracts signed by our sites with suppliers and contractors, 71% were screened for human rights or included human rights clauses. No significant contractors or suppliers were declined or removed as a result of these screenings. However, we did work with 42 different suppliers to address concerns related to human rights.
Human Rights Training
We want to ensure that all employees, contractors and partners uphold Goldcorp’s commitments in our Human Rights Policy and our Code of Conduct. Every employee is responsible for reading and acknowledging the Code of Conduct upon hiring. A structured training and awareness program on the Code of Conduct is in place and executed on an annual basis. The majority of our sites undertook human rights related training above and beyond the Code of Conduct and other standard induction training. Over 2,000 operational and project site employees received training on human rights, equivalent to 34% of our employee base. More than 1,200 hours of employee time were spent in human rights training in 2013. Additional information on human rights training specific to security is available in the Voluntary Principles on Security and Human Rights section.
The International Finance Corporation (IFC) defines child labour as “work by children that is economically exploitative or likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral, or social development”. The legal age at which young people may work varies from jurisdiction to jurisdiction. Goldcorp will not knowingly employ a person who is under the legal age of employment, or where that employment would contravene the IFC definition of child labour.
No incidents of child labour were reported in 2013, nor were any operations considered to have significant risk for incidents of child labour.
Forced or Compulsory Labour
Goldcorp supports the principle that individuals must be accorded an equal opportunity to participate in the free enterprise system and to develop their ability to achieve their full potential within that system. This includes the concept of "a fair day’s pay for a fair day’s work”. Goldcorp does not engage in, or condone, forced or compulsory labour.
No incidents of forced or compulsory labour were reported in 2013, nor were any operations considered to have significant risk for incidents of forced or compulsory labour.
Freedom of Association and Collective Bargaining
In our Human Rights Policy, Goldcorp commits to respect workers’ rights, including freedom of association, the right to peaceful protest and assembly, and engagement in collective bargaining in association with the International Labour Organization (ILO).
In 2013, at Cerro Negro, in Argentina, freedom of association and collective bargaining were identified as being potentially at risk. Our Cerro Negro site has noted that there is increased risk of trade union members exerting undue pressure on workers. To support these rights, Goldcorp supports and permits employees to form a union as laid out in Argentinian law. We also maintain a constant dialogue with suppliers and unions to ensure that all personnel are covered by an appropriate collective bargaining agreement.
Human Rights Grievances
Commitments listed in Goldcorp’s Corporate Social Responsibility Policy include the establishment of grievance mechanisms based on international best practices. Goldcorp acknowledges the corporate responsibility to respect human rights, which means that the company and its subsidiaries must act with due diligence to avoid infringing on the rights of others. In light of the UN Guiding Principles for Business and Human Rights, we also acknowledge that sound grievance procedures, particularly related to human rights, contribute to the “access to remedy” pillar included in the guiding principles.
Grievances may come from both internal and external stakeholders. Examples of internal stakeholders include employees, former employees and contractors. External stakeholders are those such as local communities, civil society and government.
At Goldcorp we have two formal channels for receiving complaints and grievances, and other informal channels, which are implemented on a site-by-site basis. The first of the two formal mechanisms is our Ethics from the Ground Up program, which includes a hotline and dedicated email address and mailing address to receive complaints, questions and concerns related to the implementation of our Code of Conduct. While any person can access this mechanism, it is most often accessed by our employees and contractors. We encourage employees to bring concerns and complaints to their supervisors and human resources staff on-site, but we recognize that often people want a degree of separation and neutrality. The initial complaint is received in confidence by an external third party, and the cases are investigated and resolved by the corporate Ethics Committee. Complaints raised through the system are not limited to human rights issues, and include a wide range of concerns such as fraud or theft. The most frequent potential human rights impacts raised through the system are from cases related to discrimination and harassment.
The second system is the Community Response System, which is also accessible by anyone but specifically geared to local communities and other external stakeholders. While each Community Response System at our operating sites is tailored to the local context, they are all designed to comply with the Goldcorp Grievance Mechanism Framework. Goldcorp’s projects are at various stages of formalizing their Community Response Systems. Interim channels exist through their community relations teams. Éléonore and Cerro Negro finalized their systems in 2013 and will be implementing them in 2014.
Some overlap may exist between these channels. Due to the confidential nature of grievance management, as well as the ability of a stakeholder to escalate their grievance through multiple channels, verifying at the corporate level the precise number by category has proven difficult.
HR4, HR9, HR11
In 2013, one grievance was reported at Musselwhite via the Community Response System and was directly related to human rights, as well as to Indigenous rights. Twenty grievances were received at Peñasquito related to potential human rights issues. In addition, our Ethics from the Ground Up mechanism responded to 30 complaints and/or inquiries regarding discrimination, harassment and other issues that could relate to human rights. Since the grievance management system is site-based, and therefore contextually specific as well as confidential in nature, we have not attempted in this report to define or describe the specific issues raised.
|Ethics from the Ground Up hotline
(human rights related complaints only)
|Received||Investigated||Resolved||Received in previous period, resolved in current period|
|Harassment (includes bullying, unwanted sexual advances)||21||21||21||0|
|Impacts to livelihood||0||0||0||1|
|Impacts on personal safety and security||1||1||1||0|
|Community Response System1
(all grievances received)
|Received||Investigated||Resolved||Received in previous period, resolved in current period|
|Harassment (includes bullying, unwanted sexual advances)||0||0||0||1|
|Impacts to personal property||16||17||16||1|
|Impacts to livelihood||9||9||8||0|
|Impacts on personal health and well-being||6||6||6||0|
|Impacts to shared natural resources (e.g., water, air)||1||1||1||0|
|Impacts on personal safety and security||2||2||2||0|
|Impediment to peaceful association/collective bargaining||0||0||0||0|
|Impediments to access to land and infrastructure||4||4||4||0|
|Impacts on cultural site/object and access to site/object||0||0||0||0|
|Lack of consultation or access to information||4||4||4||0|
1 This table shows all grievances received through our Community Response mechanisms. It does not attempt to filter by those that had potential human rights impacts.