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Ethics and Conduct Office

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  • 1. Why does Vale have an Ethics and Conduct Office?

    Vale has this channel as a way of enhancing its ethical values, constituted in line with the Code of Ethical Conduct, corporate governance principles and prevailing legislation in each country where Vale operates or has its shares traded on a stock exchange.

  • 2. What is the channel’s scope?

    The Ethics and Conduct Office can receive complaints about any ethical subjects concerning Vale. Complaints about accounting irregularities or improprieties or any other issues related to auditing, internal controls, standards, policies, ethics, human rights or the environment may be submitted. The channel may also be used to answer queries related to the Code of Ethics and Conduct and when Vale’s more everyday mechanisms for resolving problems, such as call centres, do not provide an adequate solution to a problem that has already been reported.

    If any issues are more suited to Vale’s other communications mechanisms, the Ethics and Conduct Office will, as far as possible, advise the complainant as to the most appropriate way of proceeding.

  • 3. Who can use the Ethics and Conduct Office?

    Employees, suppliers and customers of Vale Group companies, as well as members of the Executive Board, Board of Directors, Advisory Committees and Audit Council, as well as community representatives.

  • 4. What options are there for submitting a complaint through the channel?

    There are five ways of submitting a complaint: electronic form, phone, email, letter, or by visiting the Ethics and Conduct Office in person. Click here to see more details about the options for making complaints.

    Note: In the case of Vale employees in Canada, complaints about possible irregularities or improprieties related to the workplace and employees should be reported directly to local management. Such complaints may concern the following issues, among others:

    - Workplace health and safety issues that endanger people’s lives;
    - Violence, bullying, threats or harassment at work;
    - Sexual harassment involving employees;
    - Issues related to the workplace, such as discipline, promotions, job recommendations, and shifts;
    - Complaints related to the company’s local environmental obligations.

  • 5. Can I make anonymous complaints?

    Yes, you can. It isn’t necessary to identify yourself to make a complaint, although if you do, this will facilitate investigation of the case. If you wish to identify yourself, your confidentiality will be guaranteed throughout the process.

  • 6. How long does it take to receive a response?

    The time taken to complete the investigation of a complaint will depend on its complexity.

  • 7. Is it possible to track the progress of cases? If so, how?

    If you make a complaint via phone, email or the electronic form, you will receive a protocol number that you may subsequently use to submit additional information or verify the investigation’s progress and results. Click here to check your complaint’s status.

  • 8. Who are the complaints forwarded to?

    The complaints are forwarded to the Ethics and Conduct Office, which reports to the chairman of Vale’s Board of Directors.

  • 9. Which area is responsible for processing and checking information submitted to the Ethics and Conduct Office?

    The Ethics and Conduct Office is the area delegated by the Board of Directors to handle investigations of complaints or other issues arising from the channel, and to manage the flow of information together with the Board of Directors.

  • 10. How is the chairman of the Board of Directors informed of the results of investigations?

    The Ethics and Conduct Office issues a report giving the results of each investigation within the channel’s scope directly to the chairman of the Board of Directors, recording the evidence obtained for the reported situations, as well as appropriate actions to resolve irregularities.

  • 11. In what way does the Ethics and Conduct Office act and what procedures does it follow?

    After being submitted to the Ethics and Conduct Office, complaints go through a strict screening process that verifies, for example, whether there is enough information for an investigation. In the case of complaints with insufficient information, the Ethics and Conduct Office may request more details via the complaint-tracking page. Complainants then have a period of 30 days to provide additional information. Complaints that are feasible to investigate are submitted to this end. The Ethics and Conduct Office is committed to seeking fast and agile resolutions to complaints and also to identifying opportunities to improve Vale’s processes.

    Once an investigation has been completed, the appropriate measures are taken and the case is closed.

  • 12. What is not within the Ethics and Conduct Office’s scope? What doesn’t the Ethics and Conduct Office do?

    - We do not investigate complaints if there is not enough information for an investigation.

    - We do not deal with personal or private issues that are unrelated to Vale’s activities.

    - We do not modify internal processes, although we do contribute to improving them.

    - We do not deal with certain issues that are more suited to Vale’s other service channels, unless these channels have provided an unsatisfactory response.

  • 13. What are Vale’s other communications channels?

    It is through dialogue and trust that Vale expects to obtain enough information to understand and respond to society’s demands. We have a communications channel for queries, complaints, suggestions and praise, called “Talk to Us.” Click here to access it.

  • 14. Might I suffer retaliation if I make a complaint?

    In all cases, confidentiality, independence, impartiality and immunity are guaranteed in the treatment, investigation and filing of information received. The rights of complainants and the people cited are also guaranteed, and any kind of retaliation against those who use the Ethics and Conduct Office in good faith is forbidden, regardless of the results of investigations. This tool should be used in a conscientious manner to maintain the credibility of the process.

  • 15. Can I only make a complaint if I have concrete evidence of wrongdoing?

    It is very important for complaints to be based on facts that can support an investigation. If there is a lack of concrete evidence, one may use witnesses, who must be specified in the complaint. If there is not enough information for an adequate investigation, the Ethics and Conduct Office will request additional information, which must be provided by the complainant within 30 days.

  • 16. Can I only report situations that are taking place now, or can I also denounce past cases?

    Yes, you can also report cases that occurred in the past.

  • 17. If a complaint is corroborated, what penalties may the reported person suffer?

    Whenever a complaint is corroborated, corrective action is taken, which may involve penalties, whose severity will vary in accordance with the type of wrongdoing and the facts reported. The action taken may range from a simple statement to the person’s superiors to counselling with the HR area, scheduling of coaching, formal warnings or even termination (for cause or otherwise).

  • 18. If a complaint is corroborated, is the complainant informed of the completion of the case and the penalties and actions applied to the reported person?

    Whether or not a complaint is corroborated, whenever a case is closed, the complainant has access to this information on the complaint follow-up page. With regard to actions and penalties incurred by reported people, in general we do not inform complainants of the measures taken in order to respect the right to privacy of all those involved.

  • 19. What does moral harassment mean?

    Moral harassment means conduct that repeatedly and systematically exposes a person to humiliating or embarrassing situations at a company. It is intended to destabilize a person psychologically or emotionally.

    Examples of conduct classified as harassment: assigning tasks that are useless, degrading or with impossible deadlines, verbal aggression or aggressive gestures, explicit or veiled threats, exposure to ridicule, using an employee as an example of poor performance, assigning tasks not related to a person’s professional activity.

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Do you have any more questions?

If you want to submit a new question about the Code of Ethics and Conduct, about the Ethics and Conduct Office or talk about any other subject, use our contact channel – Talk to Us.

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