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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

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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 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 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.​

ComitêsComitês

Guidelines

Livro Código de ConturaLivro Código de Contura

Learn more in our Code of Conduct

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:​

Communication & TrainingCommunication & Training

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:​

Risks & MonitoringRisks & Monitoring

Complaints Assessment Flow

How complaints are assessed by the Whistleblower Channel:

Complaints Assessment FlowComplaints Assessment Flow

Investigations​

In 2020, our Whistleblower Channel received 4,670 complaints and closed 4,562 cases, of which (i) 284 referred to complaints that were not investigated due to lack of information or pertinence to the scope of the Whistleblower Channel; (ii) 121 were consultations, which were answered by the Whistleblower Channel, but did not lead to an investigation; and (iii) 4,157 led to investigations, which confirmed violations of Vale’s Code of Conduct in 36% of these cases. All confirmed violations triggered correction plans, which are presented by managers and approved by the Whistleblower Channel.

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.​

Vale’s Whistleblower Channel investigations in 2020 resulted in 2,261 actions related to process corrections and improvements. In more severe cases, disciplinary measures were applied, such as the dismissal of 181 employees.​

Interpersonal relationships

  • Inadequate personnel management
  • Comportamento inadequado
  • Assédio moral ou sexual
  • Discriminação

Complaint

Health and Safety

  • Accident concealment

Fraud

  • Falsification of diplomas
  • Fraud in contracts management
  • Fraud in the hiring process

Third-Party Relations

  • Supplier Relations
  • Relations with Government or Communities
  • Customer Relations

Conflicts of Interest

  • Hiring relatives
  • Improper benefit through suppliers
  • Hiring companies from relatives or friends

Corporative Security

  • Robbery
  • Theft
  • Invasions

Environment

  • Environmental infractions

Others

Consultation

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
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
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.

Integrated ReportIntegrated Report
To learn more about Vale’s Ethics & Compliance Program initiatives and results, check out our 2021 semi-annual report.​

Tax Transparency 

Tax Transparency Report 2020​

The report is an important part of our new pact with society as we look to better engage our stakeholders in the places we work. It also sets out Vale’s approach to tax – one that is rooted in compliance, transparency, a long-term view, risk management and positive relationships with tax authorities.​

It builds on our first publication last year by sharing more information on how, when and why we pay tax – and includes details of our greater economic contribution in the societies we call home.​

We also share details of how Vale has supported our communities, partners and our staff through the COVID-19 crisis.​

This report details taxes and royalties paid in Brazil, where most of the operations are located, and worldwide for all government spheres, and by project, highlighting the jurisdictions with mining operations.

In 2020, Vale paid US$ 5.7 billion in taxes and royalties, out of which U$$ 4.9 billion (86%) — was paid in Brazil.​

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