Business Ethics and Compliance
At Goldcorp, we are committed to upholding Our Values, one of which is Acting Ethically. Over the years, we have worked hard to ensure that an ethical culture doesn't reside in policies, but rather in the way we conduct our business every day.
Code of Conduct
Our Code of Conduct (the Code) documents the guiding principles of conduct and ethics to be followed by all employees, officers, directors and third parties who work for, or on behalf of, Goldcorp. The principles in the Code summarize what Goldcorp expects from each of us and provides valuable advice on how to conduct our work with integrity. Aspects in the Code include but are not limited to: compliance with the law, prevention of conflicts of interest, anti-bribery and anti-corruption, third-party compliance and oversight, anti-competitive practices, and zero tolerance for fraud. Through a combination of in-person and online training, and supported by a structured awareness and communications campaign, we make every possible effort to ensure that everybody working for, or on behalf of, our company clearly understands the principles that must be followed while doing their job.
Goldcorp reviews and updates the Code every three to five years in an effort to keep it current and relevant to the changing business and regulatory environments in which we operate. The Code was last updated and approved by the Board in 2014.
Our efforts in promoting ethics and compliance awareness are reflected in the number of Code of Conduct concerns and inquiries reported. In 2015, the reports-to-employees ratio was two reports (including queries and requests for guidance) for every 100 employees, compared to an average of 1.3 across all industries, as stated by NAVEX Global’s 2015 Ethics and Compliance Hotline Benchmark Report. This represents a 6% increase compared to 2014 and a 23% increase compared to 2013.3 The activity of our ethics reporting process is a key input in order to determine the effectiveness of our awareness, training and detection efforts for all of the matters covered under our Code.
We also developed the Acting Ethically Is Important to Me campaign, in which Mine General Managers (MGMs) spoke about why ethical behaviour was important.
In order to address Code matters in a timely, unbiased and appropriate manner, we have an internal Ethics Committee that oversees the Ethics compliance program. Our Ethics Committee is a multidisciplinary group of corporate employees and officers chaired by our Executive Vice President and General Counsel.
Conflict of Interest
Goldcorp understands that conflicts of interest may arise in the ordinary course of business. Therefore, it is important to ensure that there is transparency and that all conflicts of interest and potential conflicts of interest are fully disclosed. Our Code of Conduct sets out the steps to take in the event of a potential or actual conflict of interest.
In 2015, there were no significant fines or non-monetary sanctions for non-compliance with the applicable laws and regulations that prohibit restraints of trade, unfair practices, anti-competitive behaviour, anti-trust and abuses of economic power. In addition, in 2015, we did not receive any reported fines that on an individual basis exceeded US$100,000 for health and safety, employment and corporate social responsibility matters. For further information on environmental fines and sanctions, please visit the Compliance section, under Environmental Stewardship.
Disclosure, Confidentiality and Insider Trading
Our obligations under the provisions of securities laws and stock exchange rules relating to the disclosure of material information are guided by our Disclosure, Confidentiality and Insider Trading Policy, which ensures that Goldcorp and all persons to whom this policy applies meet their obligations regarding the timely disclosure of all material information.
Fraud and Corruption
Goldcorp’s commitment to acting with integrity includes not engaging in or tolerating fraud or corruption. We invest time and resources to create awareness on our commitment to acting with integrity. This means clearly defining the expectations we have for employees and third parties who work with us with regards to ethical behaviour.
Managing Fraud and Corruption Risk
Goldcorp manages risk through a system of internal controls over our financial reporting compliance program; our entity-level controls; and transactional controls, such as delegation of financial authority for expenditures, transaction authorization requirements, segregation of duties and information technology security. We have developed a fraud risk assessment model identifying the fraud schemes we were more vulnerable to and the minimum level of controls to be put in place to mitigate those risks. We have also implemented a risk-based transactional monitoring process to flag and follow up on unusual transactions as part of our anti-corruption compliance program.
We created a stand-alone Anti-Bribery and Anti-Corruption Policy in 2014, together with a compliance program to ensure awareness and adherence to this policy. During 2015, significant efforts were placed in managing third-party risk and in enhancing our risk-based detection capabilities. A robust, structured and globally applicable process to assess the risk that individual third parties pose to the organization, and conduct due diligence in accordance to the identified level of risk, is one key way we manage corruption risks. A global, web-based tool was also implemented to facilitate compliance with these new requirements and to allow corporate oversight of the process. In addition to complying with the defined due diligence requirements, third parties assessed as posing a higher risk to Goldcorp were included in our anti-corruption training program.
100% of our business units were analyzed for risks related to corruption during the reporting year. All reports of alleged corrupt activity received during 2015 have been resolved or are currently under active investigation. In the event that we confirm an allegation of corruption, the individual(s) and/or entities involved will face disciplinary measures that could include termination of employment or contract and criminal and/or civil liability as applicable. Our commitment against corruption goes beyond the boundaries of our company. Since 2014, we have supported Transparency International Canada (TI), a leading NGO working to encourage governments to establish and implement effective laws, policies and anti-corruption programs.
Ethics Training and Capacity-Building
In 2015, we delivered in-person anti-corruption training for all key staff in eight locations and conducted a training session with our senior management team at corporate, regional and site levels. During several of these sessions, third parties working for, or on behalf of, Goldcorp who posed a higher risk to the organization were also in attendance to reasonably ensure proper alignment.
We have an annual mandatory online training and certification process. Employees are required to review key topics of the Code (refreshed every year) and then certify compliance. In 2015, 98% (3,534 employees) of the target population (e.g., employees with permanent access to a computer) completed the course and certification. The certification process included a requirement for all supervisors to have an in-person discussion with their teams about the importance of acting ethically. A similar online training and certification is in place for our Anti-Bribery and Anti-Corruption Policy. This training runs every two years; during the off-years, such as 2015, in-person training takes place. 220 new employees (new hires) took the anti-corruption online course during 2015.
In addition to our corporate-driven efforts, our operations also conduct additional site-based programs related to anti-corruption and ethics compliance. In 2015, 6,164 employees received either a workshop or a training related to the Code of Conduct or anti-corruption policies, compared to 4,586 employees in 2014 and 3,528 employees in 2013.