Ethics, Compliance and Tax Transparency
Vale believes that everything starts with ethics and integrity. These principles permeate
all of our values.
To reaffirm its commitment to ethics, Vale integrates into its strategy an ethics and
compliance approach.
Vale's Ethics & Compliance Program has clear governance, guidelines and rules on
how to overcome dilemmas and make the best decisions in a responsible and ethical way.
Ethics & Compliance History at Vale
Ethics & Compliance Program
Every day, Vale seeks to build a culture of ethics and integrity based on principles. This journey is
guided by the Ethics & Compliance Program.
Composed of six pillars, the global program adopts a preventive posture by promoting ethical conduct
among all who work at Vale or act on its behalf.
Governance
The Audit and Compliance Department is responsible for Vale's Ethics & Compliance Program. The
department works in partnership with the Conduct & Integrity Committee, is supervised by the Audit
Committee and has direct reporting to Vale's Board of Directors.
This structure guarantees the autonomy and independence required for the Audit and Compliance Department
to conduct the areas of Internal Audit, Whistleblower Channel and Corporate Integrity, the latter being
the 'guardian' of Vale's Ethics & Compliance Program.
Anti-Corruption Rules
Vale has zero tolerance for corruption and bribery. In addition to the Code of Conduct,
the Ethics & Compliance Program presents anti-corruption rules and guidelines.
The
Global Anti-Corruption Policy is the main document governing the subject and
reinforces Vale's commitment to doing business with integrity.
Employees can also count on the Global Anti-Corruption Manual for practical guidance. All
suppliers and contractors must follow the guidelines of the guide entitled
Fighting Against Corruption, developed especially for third parties.
Vale complies with 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.
Communication & Training
Vale takes responsibility for engaging and empowering all its employees to participate in the Ethics
& Compliance Program. The goal is to guide people on how to behave correctly, to overcome dilemmas
and always make the best decisions in an ethical and responsible manner.
Communications, movies, videos and training are just some of the program vehicles. Among the initiatives
that make up the annual program planning, the following stand out:
Risks & Monitoring
To effectively measure and monitor Vale's potential risks and strengthen governance practices, Vale
has a Risk Management Policy.
To manage risks related to ethics and compliance, we ensure an integrated risk management governance
flow based on the concept of Lines of Defense.
The First Line of Defense, which is composed of professionals responsible for an operational or
administrative area, acts to implement and execute effective prevention and mitigation controls, ensure
adequate definition and execution of action plans and establish corrective actions to continuously
improve risk management.
Corporate Integrity acts as the Second Line of Defense, as a specialist in managing ethics and
compliance risks. It is responsible for defining minimum methodologies, technical standards and
management, as well as mandatory risk indicators that must be adopted by the First Line of Defense.
The Whistleblower Channel is part of Vale’s Third Line of Defense and is responsible for investigating
complaints, providing exemption assurance, and reporting on the effectiveness of risk management and
prevention, internal controls and compliance.
Click here to find out more about Risk
Management at Vale.
Whistleblower Channel
Anyone, inside or outside of Vale, who wants to report a case of suspicion or ethical misconduct, should
use Vale’s Whistleblower Channel. This channel is an exclusive tool for this purpose, operated by an
independent company, and structured to ensure there is:
Complaints Assessment Flow
How complaints are assessed by the Whistleblower Channel:
Investigations
In 2021, Vale’s Whistleblower Channel received 6,248 reports. These included allegations,
inquiries, and complaints. Over the year, 5,526 investigations were closed. All confirmed violations
triggered correction plans. In this year, 3,014 corrective actions were established, including the
action for dismissal of 157 employees.
As a general rule, these plans contain measures to promote process improvements, training
initiatives and feedback to employees. Depending on the seriousness of the allegations, employees
involved may be subject to administrative measures, such as warnings, suspensions or terminations.
Suppliers involved in serious violations of the Code of Conduct are also subject to punitive measures,
such as fines or contract termination.
Allegations in 2021 - accurate and confirmed reports
Interpersonal relationships
- Inadequate personnel management
- Comportamento inadequado
- Assédio moral ou sexual
- Discriminação
Fraud
- Falsification of diplomas
- Fraud in contracts management
- Fraud in the hiring process
Conflicts of Interest
- Hiring relatives
- Improper benefit through suppliers
- Hiring companies from relatives or friends
Environment
- Environmental infractions
Others
Vale’s Whistleblower Channel can be accessed through different platforms:
Electronic form
Access the form at the
Whistleblower
Channel page, available
here on Vale’s website.
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
Other countries, collect call to +55 21 3485-3000
Conduct Office webpage.
Letter
Vale’s
Whistleblower
Channel
P.O. Box 521 - ZIP Code 06320-291
Carapicuíba – São Paulo - Brazil
Go to the
Whistleblower Channel for more information.
Consequence Management
Vale’s Whistleblower Channel acts with independence and confidentiality to ensure a fair investigation
of the facts. Fair investigation allows us to manage consequences for confirmed cases.
However, it is not only through the Whistleblower Channel that consequences can be managed. They can
also be managed when misconduct is identified during routine management. Consequence management is
another way to correct eventual ethical misconduct.
Disciplinary measures for confirmed misconduct are conducted fairly, according to local legislation and
the proper terms of collective bargaining agreements.
Find out more about this in
Vale's Code of
Conduct.
To learn more about Vale’s Ethics & Compliance Program initiatives and results, check out
our
report 2021.
Tax Transparency
Tax Transparency Report 2021
The report is designed to share information about the taxes we pay and contributions we make to the
places where we work. This is an ongoing, albeit small, part of our 'New pact with society' to
engage with our stakeholders.
Building on the first publication in 2020, this year we have taken important steps to align to GRI 207,
considered a benchmark in the disclosure of information on tax practices.
This report details the taxes and royalties paid in Brazil, where most of our operations are located,
and those paid globally to all government levels and by project. We highlight the jurisdictions in which
we have our mining operations, as our tax contribution plays a key role in supporting the communities,
people and governments of the regions where we operate.
In 2021, Vale paid US$9.3 billion in taxes and royalties, of which US$8.3 billion (89%) was paid in
Brazil. We believe this is a fair and proportionate reflection of the value created and we are proud to
share this with society.
