Ethics and Transparency

"Do what is right": that is one of our values. That is why ethics and integrity are principles that guide our daily activities.

In a big company such as Vale, we interact with different partners every day, being those employees, suppliers, clients, communities, public agents, investigators, shareholders and journalists, among others. We also constantly deal with the tangible and intangible assets of our company.

All these relations should be guided by the highest ethical standards, expressed in our Code of Ethical Conduct, with principles and guidelines to drive the professional conduct of all Vale’s employees as well as our subsidiaries and both directly and indirectly controlled companies.

The general Ethical Conduct rules included in this Code should be respected by the members of the Board of Directors and its Advisory Committees, Fiscal Council, CEO, Executive Directors, employees, interns, service providers and all those acting on behalf of Vale or its controlled companies. All other entities in which Vale has an interest should also follow this Code, to the extent possible.

• Code of Ethical Conduct

The Code of Ethical Conduct provides guidance on several subjects, such as Health and Safety, Human Rights, diverse and inclusive working environment, fair competition, conflict of interest, anti-corruption, environment, besides relations with suppliers, utilization of company resources, gifts and hospitalities, data protection and others.

Global Anti-Corruption Program

Vale's Code of Ethical Conduct has a chapter dedicated to the company's Global Anti-Corruption Program.

That is because Vale has zero tolerance towards corruption, and believes that abuse of power for obtaining personal gain is not a fair way to do business. It is strictly prohibited to offer or receive any kind of gift, favor or any valuable objects, direct or indirectly, to influence a decision or obtain an improper advantage.

The Global Anti-Corruption Program is one of our instruments for preventing and fighting corruption by public officials. It is a comprehensive set of rules that reinforce one of our values, “Do what is right”, and which must be followed throughout the company. The management of this program is the responsibility of the Corporate Integrity area, which, in 2018, continued to disseminate and reinforce the culture of compliance and anti-corruption within the workforce.

One of the topics highlighted by the program is the prohibition of donations and/or contributions to campaigns, political movements and/or candidates, either directly or indirectly. This prohibition is registered in Vale's bylaws and also includes its subsidiaries in Brazil and abroad.

The program's main documents are the Code of Ethical Conduct, the Global Anti-Corruption Policy and the Global Anti-Corruption Manual.

The program follows the laws and regulations to which it is subject, including, but not limited to, Law 12,846/13 - Brazilian Anti-Corruption Law, the FCPA, U.S. Foreign Corrupt Practices Act and the UK Bribery Act.

• Vale's Global Anti-Corruption Policy
• Vale's Global Anti-Corruption Manual
• Code of Ethical Conduct
• Laws 12,846 / 13 - Brazilian Anti-Corruption Law and FCPA
• U.S. Foreign Corrupt Practices Act
• UK Bribery Act

The program in practice

In 2018, initiatives such as in-person and online training (mandatory for all employees with computer access), sending announcements, intranet program page redesigning and periodic follow-up meetings with critical areas of the company were carried out.

In 2018, announcements concerning the anti-corruption policy and procedures were made to the senior governance, employees and suppliers, who should adhere to the Supplier’s Code of Ethical Conduct. In addition, companies rated by the program as high-risk suppliers - representing 7.64% - also receive the Anti-Corruption Policy and must apply its rules when providing services to Vale. In the jurisdictions where we operate (South America, Europe, Africa, Asia Pacific, the Middle East and Canada), more than 6,000 people underwent training, among 626 leaders (from supervisors to senior leadership) and 5,243 employees. Vale makes available, for access by all employees, the policies and rules regarding this subject.

Every year, on the World Anti-Corruption Day, an email is sent to all employees, in which the CEO and the general consultant reinforce Vale's values and zero tolerance for any kind of corruption.

As part of the Global Anti-Corruption Program, in 2018, 18,000 due diligences were carried out by Corporate Security, around 4,000 more when compared to 2017, as well as due diligences in third parties that negotiated with Vale, whether these be suppliers, subcontractors, surface-right owners or entities prior to any donation or sponsorship payment.

Our policies and standards are aligned with the best market practices.

Ethics and Integrity Program

One of the main initiatives to promote ethics and transparency in the company is the Movement for Integrity. Held annually since 2015, the action is aimed at all Vale leaders, employees and third parties. They are encouraged to debate ethical values and to report incorrect behaviors at all hierarchical levels of the company. In 2018, the action reached 58,000 employees and third parties in our worldwide operations.

Perspectives

Vale plays a key role in discussions concerning regulations within the mining field. With this, it closely followed the regulation, in 2018, of the new Mining Code and the creation of the National Mining Agency, initiatives that seek to encourage financing for the sector and the application of stricter environmental rules. Now, any practices that compromise the environment or the biodiversity of areas where the mining companies operate will be immediately punished. The regulations, widely supported by Vale, reinforce the company's commitment to dialogue and transparent measures for the sector over the coming years.

Ethics and Ombudsman Channel

The Ethics and Ombudsman Channel, available to Vale's internal and external public, is a proactive, transparent, independent and impartial communication tool for reporting violations or suspected non-compliance with any of the topics described in our Code of Ethical Conduct. Among them, we highlight possible accounting irregularities or improprieties or any other accounting issues, audit matters and those related to internal controls, standards, policies, ethics, human rights and environment. The Ombudsman Channel can also be used when regular problem solving mechanisms provided by Vale, such as call centers, do not provide an adequate solution to a problem already reported.

According to the organization chart below, the Ombudsman area reports directly to Vale's Board of Directors; being, therefore, impartial in its activities and, especially, in handling complaints.

History of the Channel

The Ethics and Ombudsman Channel was created in 2006 and operated within the Internal Audit, and was called Whistleblowing Channel. In 2013, the General Ombudsman Office was created with two main attributions: the Promotion of Ethical Conduct, developing several communication and training actions to continuously improve Vale’s ethical awareness, and the operation of the Ethics and Ombudsman Channel, with the receipt, analysis and coordination of investigations concerning complaints and claims from both the internal and external publics.

Throughout these years, the Ombudsman has been improving its processes and way of acting, and, since its creation in 2013, the receipt of complaints and claims more than doubled (increase of 131%), considering our projections for 2019.

The Ethics and Ombudsman Channel handles all cases confidentially, and all complaints made are carefully received and handled by the responsible team. There is a formal process conducted by the Ombudsman team to handle a complaint.

Complaints Assessment Flow

How complaints are assessed by the Ombudsman Channel:

Complaint

The whistleblower makes a complaint in one of the Ombudsman Channels. The complaint may be anonymous or identified.

Analysis

Complaints are analyzed to verify whether there is sufficient information for the assessment, and then classified according to their criticality and theme.

Assessment

After analysis, the complaints are sent to specialized areas in the Company or are directly assessed by the Ombudsman.

Closure

For confirmed cases, the results of the assessment are shared with the leadership and an action plan is defined to address the identified issues.

Feedback

A final response is provided to the whistleblower, who can access it through the protocol initially received during registration. The action plan is executed by the responsible persons.

Investigations

In 2018, investigations carried out by the Ombudsman resulted in 2,007 corrective actions, including the dismissal of 214 employees. In addition, three cases of discrimination by Vale employees were confirmed. All of them were analyzed by the company, which proceeded with the dismissal of those involved.

The chart below shows the distribution of complaints received in 2018 by subject:

Cases Monitoring

The Ombudsman constantly monitors the cases at various times of the year

Below we can see how the treated cases are managed and their levels of service:

Vale’s Ombudsman has several channels for reporting complaints:

Electronic form

Access the form at the Ombudsman page, available here on Vale’s website.

Email

ouvidoria@vale.com

Phone

Calls are free of charge and there is a specific number for each country.
Brazil: 0800 821 5000 or +55 21 3485-3000 (Vale internal phone)
Canada: 1-844-450-5001
Mozambique – Vodacom: 84 5000 (cell phone) / 3208 or 801 3208 (internal extension) / +258 21 24 3208 (external number)
Other countries, collect call to +55 21 3485-3000
Ethics and Conduct Office webpage.

Letter

Vale’s Ethics and Ombudsman Channel
P.O. Box 521 - ZIP Code 06320-971
Carapicuíba – São Paulo - Brazil

Personally

Directly to the ombudsman, by appointment, which can be scheduled by phone(+55 21 3485 3400).

Go to the Ethics and Conduct Office for more information.