Home People and Community Human Rights Human Rights Vale recognizes that in its activities, due to the inherent characteristics of the extractive sector and the regions where it operates, there are numerous challenges regarding respect for Human Rights. For this reason, respecting the human rights of our employees, direct and contractors, as well as of the communities that may be impacted by our activities is at the heart of Vale's operations. In addition, some areas are remote, and public social policies that guarantee the human rights of the communities that live there are not always fully present. When an extractive sector enterprise is launched in regions with these characteristics, the risk of aggravating previously vulnerable situations increases. It is necessary to take firm action in the management of the company's human rights, as well as intersectoral action that allows the confrontation of complex and systemic problems. That is why the company is committed to the UN Guiding Principles on Business and Human Rights and is alignmed with international principles and standards. Thus, Vale's management is based on the respect, awareness and promotion of human rights, as well as the prevention of risks and the management of adverse impacts, including mitigation and remediation in Vale's activities and throughout its supply chain. The company values engagement with stakeholders, aware that there is still room for improvement in this process The rupture of the B1 Córrego do Feijão Dam in Brumadinho, four years after the Fundão Dam rupture in Mariana, led the company to review the governance and health and safety processes, operational excellence, risk assessment operational, human rights and the remediation process, among others.KPIs Report Among the commitments accomplished in 2019 are: Public consultation for the review of Vale's Global Human Rights Policy. The approval by the Board of Directors of the review of the Global Human Rights Policy. Conducting Self-Assessments of Human Rights Risks in 55 projects to map critical risks, as well as proposing action plans to improve management processes - mandatory KPI for all operations in 2019. The commitment to respond to 100% of the allegations and controversies received from the Business Human Rights Resource Center (BHRRC), an international organization that makes available on its website a space for transparency in Human Rights management. Training in Human Rights for 2,250 employees, totaling 5,363 hours. Since 2016, around 27,000 professionals have been trained in human rights policy and procedures. The revision of the Brazil Human Rights Guide. Performing external due diligence, as a pilot, on priority operations and suppliers. Performance Evolution Vale's Human Rights management and performance are aligned with the UN Guiding Principles on Business and Human Rights, following the macroprocesses it proposes: Policy Commitment and Integration; Risk and Impact Assessment; Monitoring and Reporting; Grievance Mechanisms; Remediation Processes; Engagement with Stakeholders and Management of Salient Issues. Policy commitment and integration In addition to the present Global Human Rights Policy and other company regulations, Vale has a Human Rights Guide and specific documents to delve into relevant human rights issues in the extractive sector. Since the launch of the Global Human Rights Policy in 2009, the company has started efforts to disseminate and train its employees on the theme. Knowledge has been internalized through annual, face-to-face and distance training of leaders, directors, executive managers, managers, specialists and supervisors and staff (analysts) by the Human Rights team. Training courses are available in Portuguese and English, in the different countries where Vale operates, in different formats, including online versions, on Vale's platform for training (Valer), video conferencing and in-person. In 2019, training in human rights became mandatory for all Vale leaders, and it is expected to be mandatory for all company employees in 2021. In line with the Code of Conduct, the Policy is also disseminated to all company employees, in a continuous effort, in addition to internal communication initiatives on the subject. An example of a dissemination action was the message from Vale's chief executive officer, on the International Human Rights Day, in 2019, sent to all company employees worldwide, underscoring the importance of the matter for the company. Vale also disseminates to employees, suppliers and customers dates relevant to human rights issues, such as indigenous peoples, gender, forced and child labor, child sexual exploitation, diversity and inclusion and, among others through actions such as articles on the Intranet and the Vale.com, publication on social networks and messages targeted to these specific audiences. In addition, it promotes respect for human rights in commercial relations where the company has a more limited influence - including joint ventures, link two and three suppliers and customers. Regarding integration, there are three main fronts: the inclusion of the Human Rights lens in the policies, norms, and procedures related to the theme such as risk, procurement, corporate security, human resources; internalization of the results of risk assessments and due diligence in new controls to be adopted by operations through new processes; and working with the procurement area. Vale's contracts with suppliers have commitment clauses on the respect for human rights, in addition to the obligation to respect Vale's Global Human Rights Policy, and the Supplier's Conduct Guide. The results of evaluations and due diligence will continue to contribute to the evolution of human rights management in the company, through the review or creation of policies; establishment of controls, and expansion of capacity building/training processes and dissemination of Human Rights content. Risk and Impact Assessment The Risk and Impact Assessment consists of assessing potential risks and impacts of its mining activities, operations, projects and in the future of JVs. The identification of high and very high risks generates the development and implementation of action plans with preventive and mitigating controls complementary to those already adopted.Due diligence is also carried out in operations, projects and JVs, following an annual time frame. Due diligence also generates action plans which are monitored and provide feedback to the company's policies and processes. The same should be done for critical suppliers from 2021 onwards. The due diligence is carried out by the internal Human Rights team or by a specialized external institution. Monitoring and Reporting All high and very high-risk action plans are monitored, and internal reporting is carried out aligned with the company's risk management governance. Remediation The remediation process may be initiated by the identification of impacts generated by Vale's activities during the risk and impact assessment process, or by the due diligence process or by claims and complaints filed. Vale is committed to remedying the adverse impacts on human rights that it has caused or contributed to and collaborates with other initiatives relevant to Human Rights in the territories where it operates. The company does this directly and/or through partners, seeking to involve stakeholders in the design and implementation of remediation actions and is committed to the principle of non-repetition. Brumadinho On January 25, 2019, Dam I rupture of the Córrego do Feijão mine, in Brumadinho (MG) significantly impacted communities in the Brumadinho region and the Paraopeba river. In this tragedy, 270 lives were lost, which include two pregnant women, unborn babies, and 11 victims not yet located. Vale apologizes to society, deeply regrets the lives lost and the lives changed. The company recognizes its responsibility and reaffirms its commitment to promptly and fairly repairing damage to families, community infrastructure, and the environment. An important aspect of the reparation process was the expansion of the grievance spaces in the communities, social organizations and neighborhood associations. Progress has been made in the participatory construction of projects with the communities, seeking to listen to them and incorporate their expectations in the various reparation initiatives, which are being structured and implemented in the territory. It is worth mentioning that the dialogue process, with the communities, is guided by agreements settled with the institutions of Justice including the Public Defender's Office and the Public Ministry of the State of Minas Gerais. Community voices - the process of listening and engaging with communities: Family Reference Program - in order to guarantee psychosocial support to people and families affected by the rupture of the dam and evacuations, contributing to a humanized and fair damage reparation. The program brings together, in Brumadinho, a team of 32 professionals who act as a Family Reference (RF) and 2 as a Volante Reference (RV). In 2019, 478 families were monitored, and approximately 22 thousand calls were made. In 2020, the program foresees the expansion of actions with the development of collective practices as a strategy of psychosocial support, which contribute to the reframing of the lives of these families. In the program, specialized professionals accompany families in a systematic and continuous manner. For the execution of the program, three strategies were conceived: Family Reference (RF), Volante Reference (RV) and Intersectoral Articulation. Family Reference (RF): is the monitoring agent, responsible for supporting and for building and maintaining a relationship with the directly affected people and families. Volante Reference (RV): it is the service agent, responsible for subsidizing the teams of Community Relations analysts (RCs) at the Service Points (PAs), by welcoming, and articulating specific demands of affected people and families. Intersectoral Articulation:.aims to establish spaces for permanent and systematic intersectoral integration with managers and technicians who work in public policies in order to allow for a shared management of the monitoring of affected people and families. Association of Family Members of Victims and Affected of Dam I rupture of the Córrego do Feijão mine, in Brumadinho – Avabrum Avabrum is the official representative of the 270 families, recognized by the Public Ministry. In regular meetings between families and professionals from the Special Department of Reparation and Development, including their director, the agendas have been readily dealt with and with dedicated effort, in terms of supporting families in building a vision of the future. Communication with affected communities The role played by RCs, professionals who take care of Relationship with Communities, has gained more prominence. Currently, the RC team is composed of 17 professionals who work both in Brumadinho and in the 16 municipalities along the Rio Paraopeba channel. The dialogue takes place through field visits, meetings and forums with the communities. The objective is to give transparency to the actions and explain how the reparation and compensation process takes place in the territories, seeking to build spaces for dialogue. The RCs also work in the Service Posts (PAs), together with a multidisciplinary team. The company has used different means of communication, such as radio and sound car, informational by messaging apps, media in commercial areas and in mass communication vehicles (newspapers, radio and TVs), site vale.com/brumadinho and digital media, in addition to serving the press. Additionally, in the reparation actions in the Brumadinho region and in the Paraopeba basin, the Field Technicians, professionals from different backgrounds in the field of agricultural sciences, have been acting consistently so that the productive activities of the affected rural properties receive support and necessary assistance, maintenance, and, at the same time, bringing new possibilities for growth and development to this sector, in the area located near the Rio Paraopeba. They are agronomists, veterinarians, zootechnicians, rural administrators, environmental engineers and agricultural technicians, who develop, on a daily basis, emergency, planning and management actions, aiming at the restructuring that will be fundamental to produce the answers in order to maintain the expressiveness of the activities of the rural producers in the short and medium terms. Indigenous Peoples and Traditional Communities - relationship with Indigenous Peoples Pataxó and Pataxó Hã Hã Hãe, in São Joaquim de Bicas, MG, and with Quilombola Communities of Marinhos, Sapé, Ribeirão and Rodrigues, in Brumadinho. Two senior anthropologists, related to the Relationship Management with Indigenous Peoples and Traditional Communities, work in the relationship with the Indigenous Peoples Pataxó and Pataxó Hau Hãe, in São Joaquim de Bicas, MG, and with the Quilombola Communities of Marinhos, Sapé, Ribeirão and Rodrigues, in Brumadinho. The performance follows the guidelines of FUNAI and Fundação Cultural Palmares. Dialogue with indigenous peoples occurs through: Meetings in the village; Psychosocial assistance; Dedicated consultancy to supervise the Emergency Health Care Plan; Direct access by the leaders to the RC analyst, by telephone; Monitoring of emergency payments; Monitoring the execution of the Preliminary Agreement Term (TAP); Regular visits; Monitoring of the demands presented. Interaction with quilombola communities is guided by: Meetings in the territory, with leaders or with communities in general; Psychosocial support to the victims' relatives; Individualized assistance to the relatives of victims; Monitoring of emergency payments; Conducting the reparation process in compliance with the Term of Reference, issued by Fundação Cultural Palmares and the preparation of the Quilombola Component Study, by a consulting company chosen by the communities, which will point out the impacts and damages suffered by them and will stipulate the repair measures that should be implemented. Vale's attentive and close listening process takes place, also, through the daily interaction of its “front lines”, whether they are teams of professionals exclusively dedicated to the relationship with the communities, or the technicians in water and agronomy, construction teams, housing analysts. The issues that affect the lives of the communities are dealt with, weekly, by the company in meetings with representatives of the impacted communities. Regular meetings are also held with the victims' families and representatives of the Fire Brigades, with a focus on transparency and solutions to the challenge of searching for victims not yet found. There are weekly meetings, as well as, with promoters and other public authorities, to better understand what can be done to improve the quality of support offered to the population. This social dialogue and listening directs reparation efforts For a complete overview of all work fronts related to Brumadinho see Sustainability Report 2019 and ESG Portal. Mariana On November 5, 2015, the tailings containment structure of the Fundão tailings dam ruptured, at the Germano unit in Mariana (MG), operated by Samarco. 19 lives were lost, and the body of one of the victims remains undiscovered. Of the confirmed deaths, 13 were professionals from companies hired by Samarco, four were residents of the area and one was a person visiting Bento Rodrigues. Vale and BHP Billiton each hold 50% of the shares of mining company Samarco. As a shareholder, therefore, Vale has supported Samarco in its efforts to recover the damage caused by the breach of the Fundão Dam. From the first day of the breach, Vale and its employees committed themselves to responding to the emergency and, shortly thereafter, to remedying impacts on human rights and environmental recovery. Follow the remediation process on the Renova Foundation website or on the ESG Portal. Grievance and whistleblowing mechanisms Vale seeks to establish legitimate, accessible, and equitable channels to capture all types of manifestations, including requests, claims, complaints, information, suggestions and compliment. In Vale's system, negative manifestations are characterized by requests, claims or whistleblowing. In the case of whistleblowing, the company ensures the option of anonymity. Vale also provides professionals for the relationship with communities in order to strengthen the dialogue and promote engagement. The grievance and whistleblowing channels do not prevent access to other judicial or non-judicial mechanisms. Vale considers that these mechanisms are fundamental tools for actions to prevent and remedy potential impacts and violations of Human Rights. In 2019, 12,362 community manifestations were recorded globally, of which 65.2% were attended to within the agreed timeframe and 70.8% of these were treated. The average response time to protesters is 30 days, and the average time for treatment and completion of the grievance is close to 90 days. In 2019, the Whistleblower Channel received 3,507 allegations and closed 3,382, of which 87% were investigated. Of these, 38% were confirmed, resulting in 1,833 corrective actions, including the dismissal of 227 employees. In addition, 2 cases of discrimination by Vale employees were confirmed. Those involved has their contract with Vale terminated. For more information check the Impact to Communities page. Supporting the macroprocesses, is the "Stakeholders and Salient Issues" axis. This axis demonstrates that, in addition to following the management processes, the insertion of human rights also needs to consider engagement with stakeholders and salient issues, as illustrated in the following table (both lists are not exhaustive). Stakeholders Salient Issues Employees and contractors Fight Against Respect and Promotion Adequate training Security Teams modern slavery of children’s and adolescents’ rights involuntary resettlement Customers, Suppliers, and Partners: human trafficking of diversity, inclusion and non-discrimination artisanal and small- scale mining Local Communities (considering gender issues and children and adolescents) child labor of freedom of association and political freedom land use disputes Indigenous Peoples and Traditional Communities child sexual exploitation of personal freedom and safety Human Rights Defenders discrimination of any nature of health and safety of community Government and Society moral and sexual harassment of freedom of expression and incentive to transparent dialogue Stakeholders Salient Issues Employees and contractors Fight Against Respect and Promotion Adequate training Security Teams modern slavery of children’s and adolescents’ rights involuntary resettlement Customers, Suppliers, and Partners: human trafficking of diversity, inclusion and non-discrimination artisanal and small- scale mining Local Communities (considering gender issues and children and adolescents) child labor of freedom of association and political freedom land use disputes Indigenous Peoples and Traditional Communities child sexual exploitation of personal freedom and safety Human Rights Defenders discrimination of any nature of health and safety of community Government and Society moral and sexual harassment of freedom of expression and incentive to transparent dialogue Learn more about stakeholders and salient issues: Employees Vale's employees (including direct and contractors) have a dual role with respect to human rights: they are both subjects and agents of rights. Thus, Vale employees must not only have their human rights respected, but must respect the human rights of their colleagues, family members, and of the people in the communities where they operate. For more information on human resources regulations, working conditions, benefits, the right to association and collective bargaining, see the Human Capital Management chapter in the 2019 Sustainability Report (pages 76-80). For Vale, the health and safety of its employees, communities and employees of its supply chain is fundamental. The tragedy of the rupture of Dam I of the Córrego do Feijão mine, in Brumadinho, led the company to completely revise its health and safety strategy. For example, processes such as hazard identification and risk assessment involved in catastrophic activities and services - Hazard Identification and Risk Analysis (HIRA) - with employees, communities and the environment; expansion of engineering controls to block activities; improvement of the work permit process, including risk assessments by task, among others. The company's governance was also revised, establishing an executive director position, with its own budget, to act as a second line of defense. For more information see the 2019 Sustainability Report (pages 65-68). Security teams Security teams are a group that deserves special attention in relation to respect for human rights as they work to ensure the physical integrity of people, the preservation of assets and information, and the maintenance of the company's production process. At the same time that they must have their rights respected, they deal with situations of conflict and, before them, they need to seek, as a priority, peaceful solutions that respect human rights. As objectives in relation to the theme, we highlight the reinforcement of the strategic pillars of Integration and Engagement, foreseen in the Safety Master Plan, in addition to increasing the effectiveness of actions and reducing the incidence of critical occurrences in the operational areas. Vale is a signatory and applies the Voluntary Principles on Security and Human Rights (VPSHR) in its activities, as well as providing information through the report submitted to the entity and participating in the annual forums of the VPSHR. It includes potential human rights violation risks in its risk assessment of security requirements. Its management considers the following aspects: Select employees and closely follow their activities , considering the previous experience, technical capacity and emotional stability; Train security professionals regularly to carry out their activities in line with the principles of human rights and with the proportional and progressive use of force if necessary; Seek peaceful solutions that ensure the physical integrity of people, as well as the preservation of assets, information and the maintenance of the production process; Work in accordance with the United Nations Basic Principles on the Use of Force and Firearms by Law Enforcement Officials; Respect the United Nations Code of Conduct on Law Enforcement by Officials; Treat vulnerable people and groups with special care, especially when involving women and children. As advocated by the Voluntary Principles on Security and Human Rights (VPSHR), Vale is committed to collaborating with public security providers and communicating its Global Human Rights Policy to demonstrate its commitment to respecting the human rights of itsemployees and of all members of the communities in which it operates. In Brazil and Malawi, agreements and covenants are formalized with the public security forces for cooperation and support between the parties. In 2019, the International Security workshop took place in Brazil, bringing together representatives from Vale's areas in Mozambique, Malawi, Indonesia, Malaysia, Canada, Oman, Dubai, and India. An itinerant event was also held, going through the operations of Carajás, Vitória, and the Rio de Janeiro office, which provided the exchange of experiences and immersion in security processes for international security leaders, in addition to training in Human Rights. Vale repudiates the abuse of power and inhumane treatment, in order to ensure non-discrimination and the privacy of people. In addition, as part of the control over possible impacts, Vale encourages its direct employees, contractors, community members, suppliers and other interested parties to report incidents related to Security and Human Rights. Suppliers, clients and partners Vale establishes relationships with entities that share its same principles and values and are in line with its Global Human Rights Policy, the Sustainability Policy, the Code of Conduct and the Supplier Code of Ethics and Conduct. Find out more about the human rights risk management process with suppliers in the section on Evaluating and monitoring suppliers. Communities, indigenous peoples and traditional communities Vale's activities, in general, require interface with communities, indigenous peoples, and traditional communities. The company seeks to establish interactions and engagement with them, with special attention to women, children and adolescents, in addition to other groups that may be more vulnerable. Based on mutual respect and trust, Vale shares with these groups and other local actors in the territories where it operates, knowledge about the enterprise, building jointly with the community an understanding of its risks and impacts and finding ways of living together in which the company becomes the community's partner of choice. To learn more about Vale's relationship with communities, see the 2019 Sustainability Report (pages 68 to 74). Indigenous peoples have a deep and special connection with the land and natural resources,in general, which are linked to their physical, spiritual, cultural, and economic well-being. They also carry valuable traditional knowledge and experience to manage the environment in a sustainable manner. Mining and metals projects can have significant impacts on these peoples, both positive and negative. In addition to following guidelines throughout its operations and projects to establish relations with potentially impacted indigenous peoples, Vale is also adherent to international commitments and applies international references related to indigenous issues, such as the statement by the International Council on Mining and Metals - ICMM -on Mining and Indigenous Peoples, Convention 169 of the International Labor Organization - ILO, and the United Nations Declaration on the Rights of Indigenous Peoples. Nowadays, the company has relationship plans for all indigenous peoples and traditional communities which inhabit the areas of influence of its activities. In Brazil, to support the relationship with these traditional peoples and communities, the SDI (stakeholder relationship, grievance and critical issues) system is used, which has a specific model for the management of processes related to this theme, including: Voluntary Social Investment, Diagnostics and Impact Studies, Programs and Projects of Impact Mitigation and Grievance Management. In addition to Brazil, in Newfoundland, Canada, Vale partners with the Canadian government and others through the Labrador Aboriginal Training Partnership (Labrador Aboriginal Training Partnership) to develop skills and training opportunities for hiring. This program helps more than 400 indigenous participants in Labrador with an opportunity to work at the Voisey’s Bay mine. Voisey’s Bay has also introduced a Program called, Job Readiness Training, in order to qualify aborigines to enter the labor market. For more information on Vale's relationship with indigenous peoples, see the Indigenous Peoples and Traditional Communities page on the ESG Portal. The health and safety of communities is part of Vale's values: Life First. This is a challenge due to the nature of mining activities, especially when the company's work takes place in regions with a large concentration of communities. In this sense, the concept of "accidents with communities" is under review in the structure Vale's Health and Safety regulatory framework, in conjunction with the Social Management and Community Relations areas. This joint effort includes simplifying the system for recording accidents and reinforces corrective and training actions in operations. Vale participates annually in the ICMM report, which records all safety events related to communities and reported on the official channels of federal sectoral agencies (for example, National Land Transport Agency, on the railways). In terms of relationships with communities, numerous awareness-raising actions are carried out by Vale's Accident Prevention and Investigation Commissions. The accident rate on the railroads operated by Vale has been decreasing over the past few years and is better than the industry average. Despite that, it is necessary to maintain the work of raising awareness in neighboring communities, improving infrastructure and permanent monitoring information, especially along the railways. At the Carajás Railway (EFC) and the Vitória Minas Railway (EFVM), issues related to mobility and risky behaviors are a matter of concern for Vale, which develops projects to reduce impacts on communities, in addition to have internal rules and documents for these occurrences. Any accidents are monitored by Vale's Accident Prevention and Investigation Commissions. The accident rate on the railroads operated by Vale has been decreasing over the past few years and is better when compared with industry average. Human Rights Defenders In relation to human rights defenders, Vale recognizes their importance and: Respects the freedom of expression and expression of all people, provided they occur in a peaceful manner and that do not impact the human rights of any person and the local laws in force; Uses as a reference in the process of evaluating potential risks and impacts on human rights the United Nations Declaration on the Rights and Responsibilities of Individuals, Groups or Organs of the Society to Promote and Protect Universally Recognized Human Rights and Fundamental Freedoms (Resolution 53 / 144 of the UN General Assembly), which deals with the work of human rights defenders; Seeks engagement with human rights defenders to face common challenges, through regular and proactive dialogue. Vale does not tolerate, nor contribute to, threats, intimidation, and attacks against human rights defenders and provides grievance and whistleblowing mechanisms to register and address potential adverse impacts arising from its activities. The company seeks to engage with human rights defenders to address common challenges, through regular and proactive dialogue. States and Society In relation to States and society, Vale recognizes the importance of its collaboration and performance in the development and implementation of sustainable policies and practices in partnership with governments and civil society, through social responsibility actions and direct contributions to raise awareness and promote human rights. In order to reinforce Vale's contribution to society, the Institutional Relations, Communication and Sustainability Executive Director established the Sustainability and Social Investment Department, which brings together the company's socio-cultural and environmental projects and programs of a mandatory and voluntary nature, including the Vale Foundation. Vale also maintains the Vale Fund, a Civil Society Organization of Public Interest (Oscip) created in 2009. Learn more about this performance in the 2019 Sustainability Report (pages 74-76 and 84). Vale is committed to this challenging moment of the pandemic. And as part of communities, where it is inserted, and aware of its responsibility, has contributed significantly to public authorities and other entities in the fight against the new coronavirus (COVID-19). Follow the company's performance: http://www.vale.com/brasil/EN/people/coronavirus/Pages/news.aspx Goals and Deadlines Expected outcomes for 2020: Development of a Human Rights Guide for international operations. Review of internal regulations related to the theme of Human Rights. Updating the content of the Human Rights training and capacity building (in-person and online courses), with insertion in the orientation process of new employees and in actions customized by theme and audience. Continued training of leaders and employees in Human Rights - a revised online course will be mandatory for all employees starting at the end of 2020. Insertion of Human Rights in Vale's management methodology, with the Human Rights area being part of the 2nd line of defense with the operational areas (which compose the first line of defense). Monitoring 100% of the action plans of the enterprises that carried out assessments or due diligence in 2019. Improved Human Rights management in Procurement processes, including reviewing the classification of critical suppliers, applying new risk controls and updating the Supplier Conduct Guide. Governance Human rights commitments must be respected by all company professionals, regardless of their position or function. Beginning with the Board of Directors and unfolding to all employees. This commitment is reflected in the company’s main documents, for instance, in the Bylaws which states that the Board of Directors has the responsibility to act as guardian of the commitments related to Human Rights' respect. The policy documents on the topic - among which we highlight the Human Rights Policy and the Code of Conduct - are global and follow an elaboration and approval process that involve the technical areas that address the theme, such as Legal, Sustainability, Human Resources, Health and Safety, Risk Management, Community Relations, Procurement, Corporate Safety, among others. After content consolidation, the standards are approved by the Executive Board, Sustainability Committee, which is formed by members of the Board of Directors and independent members and, finally, by the Vale's Board. The process of handling grievance and response mechanisms, complaints and demands, as well as critical internal issues that may impact or violate human rights are addressed at different levels according to complexity. Thus, if the matter cannot be resolved locally, it is submitted to higher levels, including regional, business, national management committees and even the Executive Board or the Board of Directors and its Committees. This governance allows the resolution of grievances and the improvement of the human rights management processes. Learn more about Vale's Governance in the 2019 Sustainability Report (pages 45-52) Impact Management Human Rights impact management is regulated by the Global Human Rights Policy. The process takes place through the assessment of risks and impacts or the treatment of allegations and complaints. The process can take place through assessments, verification of the Human Rights area, as a second line of defense, investigation by the Audit or the Whistleblower channel or through external due diligence. Processes that identify human rights impacts on employees (direct or contractors) or on communities generate action plans to mitigate or remedy these impacts. In addition to Brumadinho and Mariana previously mentioned, other current engagement and remediation processes can be followed by the links: Pico Mine, Brazil Indigenous People - Carajás Railway, Brazil Indigenous People - Onça Puma Nickel Mine, Brazil Dust Emissions - Espírito Santo Belo Monte, Brazil Resettlements, Mozambique Policies and Procedures Vale has had a Human Rights Policy aligned with the United Nations Protect, Respect and Remedy matrix since 2009. In 2014, the policy underwent its first review to align with the United Nations Guiding Principles on Business and Human Rights and, in 2019, concluded a new review process, including public consultation, in Portuguese and English, via the Vale website, various social media, and e-mail to different stakeholders. 382 respondents from different sectors and social groups with important contributions participated in the consultation. Survey results were analyzed to absorb the maximum contributions. Normative Commitments The formalization of commitments, including policies and guidelines: Code of Ethical Conduct Human Rights Policy Human Rights Guide Risk Management Policies Anti-corruption Sustainability Sanctions and Compliance Socioenvironmental Investments The policies guide the management of Human Rights and the positioning on topics such as: respect for diversity, political and union freedom, awareness of moral and sexual harassment, child sexual exploitation; non-discrimination, corporate security practices; relationships with communities, including indigenous peoples and traditional communities; involuntary removal; grievance channels; child and forced labor and modern slavery and artisanal and small-scale mining. Vale's commitments are adherent to international standards of respect for human rights, including the Universal Declaration of Human Rights; the UN Guiding Principles for Business and Human Rights; the Voluntary Principles of Security and Human Rights (VPSHR); the Fundamental Conventions of the International Labor Organization (ILO); the United Nations Declaration on the Rights of Indigenous Peoples; the United Nations Global Compact; the Principles of the International Mining and Metals Council (ICMM); the Organization's Guidelines for Economic Cooperation and Development (OECD) for Multinational Enterprises; the Sustainable Development Goals (SDGs); and the International Financial Corporation (IFC) Performance Standards. Risks Vale has a risk management governance based on the concept of lines of defense: First line of defense: Has primary responsibility and directly manages risks, identifying, assessing, treating, preventing, and monitoring them in an integrated manner. Second line of defense: It is responsible for developing and maintaining risk management, internal controls, compliance; identify and monitor new / emerging risks, ensure continuous improvement and compliance with the risk management model, laws, regulations, and standards. Third line of defense: It consists of Internal Audit and the Ombudsman, areas with total independence from management. They carry out, subject to their respective areas of expertise, assessments and inspections, by carrying out tests control and investigating complaints, providing exempt assurance, including on the effectiveness of risk management and prevention, internal controls and compliance. In 2019, with the review of the company's governance and risk management, the Human Rights area started to act as a second line of defense and human rights issues are dealt with in the Operational and Compliance Risk Executive Committees/Compliance. Risk management considers all issues related to human rights in the company's activities, through the identification, elaboration, and implementation of preventive and mitigating controls. In addition to the human rights risks and controls, transversal to the business, assessments and verifications are also carried out by the Human Rights area and external due diligence. In 2019, 55 out of 67 operations carried out assessments (11 projects that were suspended due to the decommissioning of dams and the company Biopalma, which underwent external due diligence, did not participate). In order to prepare operations for carrying out Human Rights risk assessments, training sessions were held focused on the use of the methodology, reaching an audience from the most diverse areas of operations, such as: Human Resources; Institutional Relations; Corporate Security; Health and safety; Environment; Regional Sustainability (with Community Relations teams); Communication; Operation; Infrastructure; Maintenance; Exploration; Procurement; Risk, among others. In 2019, there was no consultation on risk perception directly with communities, but this is an improvement foreseen in the Global Human Rights Policy, to be adopted in the next assessment cycles. In order to capture the risks and impacts identified by the communities, the grievance mechanisms channels and information from the Community Relations teams were used. This initial process contributed to the mapping of the risks associated with the company's activities and allowed the identification of preventive and mitigating controls that must be adopted by the operations. It also served as a basis for the company to insert the human rights risk assessment into the company's risk management system, which follows the bow-tie methodology. Even though they are undergoing methodological adaptation, the operational areas have developed action plans that are being implemented on 2020 onwards. Learn more about the identified and assessed risks: Risk of human rights violations in communities Environmental and socioeconomic impacts that affect health, well-being, livelihoods or communities' access to public services, accidents that affect community members or animals in their possession, water and land use dispute, disrespect for Human Rights Defenders and grievance channel failure. Risk of degrading work conditions and modern slavery Risk of modern slavery among direct employees, contractors and/or suppliers, due to disrespect for the rights of immigrant workers; human trafficking; working hours above what is permitted by law; the inadequacy of working conditions or the infrastructure necessary to carry out the work (including PPE, places for food and rest, bathrooms and changing rooms, among others); inadequate remuneration; failure to monitor and comply with labor or social security obligations; illegal wage deductions; retaining documentation; illegal withholding of remuneration; vacations and/or leave, as well as restrictions on mobility outside the operational area after the work shift. Risk of human rights violations in labor relations Risk of violations in working relationships with employees, contractors, and suppliers, resulting from the restriction to free association and collective bargaining; the risk of discrimination of any kind and of moral and/or sexual harassment, resulting from the inappropriate conduct of direct employees and/or contractors and of failures in the grievance channels. Risk of Child Labor and Risk of Child Sexual Exploitation Risk of hiring employees under the age of 18 or below the age required by law between employees, contractors and/or suppliers (apart from those between 14 and 18 years old and in an apprentice condition, legally supported); risk of hiring an employee between 14 and 18 years old for any night activity, unhealthy, dangerous, and painful. Risk of sexual exploitation of children and adolescents near of Vale's operations and/or in the supply chain by its employees, contractors, and suppliers. Risk of violation of rights resulting from the conduct of private or public security Risk of violations resulting from private or public security conduct, in actions of interest or with support from Vale, including violation of the privacy of its employees, contractors, suppliers and/or communities; the disproportionate use of force; unjustified property or body searches and private incarceration. Risk of human rights violations on a large scale Risk of violations resulting from major accidents, with impacts on people and the environment, such as: explosion and/or fire in operational structures; leakage or rupture of dams, ore, pipeline and/or gas pipeline; railway accident, air accident and ship accident. The main risks identified with “high” and “very high” levels that generated action plans for implementation in 2020 were the risks affecting communities; risks of large-scale human rights violations, and risks of human rights violations in labor relationships. The high and very high risks are with action plans in 2020 and the Human Rights team is monitoring their execution. It is important to emphasize that in the case of risk assessment in human rights, as well as environmental assessments, the focus is on the risk that the company's activities offer to the human rights of its employees, contractors, employees of the supply chain, community members, including in the case of Indigenous Peoples and Traditional Communities. This care is being considered in the methodology. In addition, the integration of the results of these assessments is being considered in the company's management, in a permanent process of continuous improvement, so the monitoring of controls is carried out with the aim of analyzing their effectiveness both in Vale's activities and in relation to its suppliers and business partners. In 2020, we highlight the integration of human rights content into the company's Integrated Global Risk Map and management system. Evaluating and monitoring suppliers There may be risks of violation of relevant human rights in the relationship with contractors and suppliers. The risks identified by Vale include: Risk of modern slavery (degrading working conditions, work hours above what is permitted by law, debt bondage, physical and emotional coercion, document retention, etc.); Risk of child labor; Risk of child sexual exploitation; Risk of human trafficking; Risk of discrimination and harassment. In order to detect these and other risks in contractors and suppliers, Vale establishes controls such as grievance channels, analysis of documents, field inspections, including interviews with workers. The contracts with suppliers have a commitment clause of respect for Human Rights and an obligation to respect Vale's Global Human Rights Policy and the Supplier's Conduct Guide. The new supplier registration process checks for possible inappropriate conduct related to Human Rights. See the Human Rights criteria in the steps of Vale's Supply process: 1. Certification and Registration - Vale's policies and documents are sent to suppliers. Vale conducts a process of HSE, integrity and human rights (i.e. modern slavery among other salient issues) verification when the supplier fills out the application to enter the Vendor List. An assessments in carried out in 100% of tier 1 suppliers through a background check (including, in Brazil, consultation of the 'Dirty List' of slave labor (Lista Suja, in Portuguese), web search of keywords and questionnaires (environmental crimes, corruption, human rights, etc.), and the submission of documents, such as a self-declaration form presenting the suppliers HSE qualification details. 2. Selection, Quotation and Contracting - Suppliers sign the Supplier Conduct Guide. The Guide includes items on combating child labor and forced or modern slavery labor, non-tolerance to discrimination, respect for freedom of association and collective bargaining, as well as customized clauses. If the suppliers' principles and practices are aligned with those of the Guide of Vale's Supplier Conduct, the supplier forwards a copy of its company's internal code of conduct. 3. Contracts and Supplier Management - The criticality of contracts and vulnerability of suppliers is classified based on the questionnaires answered. Suppliers classified as highly critical are monitored by Vale and may undergo due diligence and auditing processes. In Brazil, there is the Third Party Contract Evaluation Center (NACT) which monitors suppliers in relation to Health and Safety issues and working conditions and will be expanded to all suppliers in 2021; the Supplier Performance Index (IDF) indicator, which monitors the performance of suppliers based on technical health and safety criteria, protection of the environment, respect for labor rights and continuous improvement through an action plan and also goes through review and improvement in 2020. At this stage, Health Safety Environment (HSE) and Human Rights management in suppliers considered critical also takes place. 4. Supplier Development - Training to improve performance Vale seeks to ensure quality, transparency, and continuous improvement in the relationship with its suppliers by promoting sustainable and competitive businesses. If there is an impact or violation of human rights, appropriate measures are taken. In addition, in Brazil, in each edition of the ‘Dirty List’, the entire supplier base is verified and if a legal entity or person is identified in the list, the contract is suspended; Learn more about the ‘Dirty List’ The Employer Register, which subjected workers to conditions of modern slavery, is also known as the “Dirty List”. It is a public transparency mechanism of the Brazilian State, created in 2003, which discloses the names of individuals or legal entities that were caught making use of slave labor. Currently, the rules governing the composition of the “Dirty List” are described in Ordinance No. 4 of 05/11/2016 (signed jointly by two ministries), and their list has been published by the Labor Inspection Secretariat, linked to the Ministry of Economy. Auditors are trained to carry out these missions and follow a comprehensive document of national and international legislation, internal regulations on the roles, competencies, and responsibilities of tax auditors, as well as instructions from other administrative documents that support the work of the inspection and its various dimensions, one of them being inspection against slave labor. After the allegation, a group formed by the Public Ministry of Labor, tax auditors, federal police or federal highway police (or any police available) goes to the site to verify the conditions reported. Once the situation is proven, the employer is assessed and will be subject to: Administrative proceeding, which, if final, with final and unappealable decision, a fine may be applied to the employer. And, if the employer does not enter into or fail to comply with a court agreement or Conduct Adjustment Term, pursuant to Ordinance MTb/DH-MJC n. 4 of 11/05/2016, it will have its name listed in the “Dirty List”, provided that, at the time of the inspection, the infraction notice provided for in article 444 of the CLT was drawn up due to the finding of modern slavery work; - Public civil action of the Public Ministry of Labor, which may seek, mainly, a moral reparation for the practice committed; - Criminal proceedings based on article 149 of the Penal Code, if the evidence is confirmed, the employer can face 2 to 8 years in prison. The punishment is aggravated if aspects of discrimination by race, ethnicity, age, gender etc. have been identified). Based on the new commitments in the Human Rights Policy, in the clear guidelines of the Human Rights Guide and in the opportunities for improvement in management identified in the human rights risk assessment, a work plan was developed in conjunction with the Procurement area, in the second half of 2019. Between 2019 and 2020, Vale is reviewing the Human Rights management process in relation to its suppliers and new controls will be incorporated in 2021. Also, in 2020, in addition to the existing process of evaluating the supplier's history for registration purposes, a more robust process for assessing the criticality of suppliers from the perspective of Human Rights is being implemented, which will direct the monitoring of suppliers considered critical. Perspectives For the next five years, Vale's main fronts of action in this area are the remediation of the impacts caused in Brumadinho, Mariana and the treatment of allegations and impacts, in addition to the development of a roadmap for improving the macroprocesses adopted by the company in the management of human rights including Policy commitment and Integration: disseminate the updated version of the Global Human Rights Policy to all employees and leaders. Insert Human Rights content in existing company policies and integrate the Human Rights lens in risk processes, procurement, corporate security, among others, and promote respect for human rights in commercial relations where the company has a more limited influence - including joint ventures, suppliers, and customers. Risk and Impact Assessment: integrate human rights risk and impact assessment into the company's revised risk process, develop regulations, follow up on the operations' action plans. Maintain due diligence for operations, projects, and JVs and improve risk management in the supply chain. Monitoring and reporting: improving the process of recording and reporting information related to human rights management, including the development of indicators and continuous improvement in reporting of human rights issues, as our commitment to transparency. Grievance and Whistleblowing Mechanisms: continue to improve mechanisms and use them as a source of continuous learning, based on engagement and dialogue with stakeholders. Implement registration systems in all operations, ensuring basic criteria adapted to each location. Continue to address all allegations, giving visibility to the responses in the Business and Human Rights Resource Center. Remediation: In addition to the priority reparation processes, ensure that human rights impacts caused by the company are effectively remedied and, if the company's activities contribute to or are linked to impacts, that Vale is part of the solutions. Vale recognizes that the adoption of the UN Guiding Principles on Business and Human Rights is essential in addressing the risks inherent to the territories where the company operates, the risks and impacts related to its activities, and the ongoing remediation processes. Vale will continue to participate in the main global forums on the subject, monitor trends and changes in legal requirements and seek good practices in Human Rights management with a focus on the continuous improvement of management policies and processes. Volunteer Actions Vale participates in important human rights initiatives and institutions, proposing standards, procedures, and sharing challenges and good practices. Among the initiatives and institutions to mention, the following stand out: the Global Business Initiative on Human Rights (GBI), the International Mining and Metals Council (ICMM), the Voluntary Principles on Security and Human Rights (VP), the World Business Council for Sustainable Development (WBCSD) and the Brazilian Business Council for Sustainable Development (CEBDS). In 2019, the WBCSD launched the CEO's Guide on Human Rights, endorsed by 45 executives from large companies, including Vale. The "call to action" demonstrates the leadership of these CEOs in Human Rights issues, positioning them in relation to the incorporation of human rights in the corporate culture, the expectations about their suppliers and business partners to respect human rights, and the promotion of intersectoral collaboration on the topic. At the end of 2019, Vale entered into new partnerships with Childhood Brasil and InPACTO - National Pact Institute for the Eradication of Slave Labor, whose projects and initiatives will be developed throughout 2020-2021. These partnerships reinforce Vale's commitment and action, both in defending the rights of children and adolescents, with a focus on preventing and fighting child sexual exploitation; and in combating modern slavery and child labor in its supply chain. Childhood Brasil The partnership with Childhood Brasil is focused on the implementation of the "Na Mão Certa" Program. Launched in 2006, the program aims to combat the sexual exploitation of children and adolescents on Brazilian highways. The main strategy adopted is to raise truck drivers' awareness of the topic so that they act as agents to protect the rights of children and adolescents. The state of Pará will be the pilot area for the implementation of the project, since there is a large circulation of trucks at Vale's service. By joining the program, Vale adhered to the Business Pact Against the Sexual Exploitation of Children and Adolescents on Brazilian Highways. InPACTO Through its association with InPacto, Vale seeks to contribute to the development of tools for the identification of vulnerabilities in the places of origin of suppliers, and the provision of services, with the objective of contributing to the elimination of modern slavery, as well as child labor. Vale remains committed to the principles of the UN Global Compact and Ethos. However, due to the rupture of Dam I of the Córrego do Feijão mine, in Brumadinho, and the impact on issues of sustainability and human rights, its membership was suspended in both institutions. For the same reason, the Corporate Human Rights Benchmark removed Vale's 2018 and 2019 results. Vale remains engaged with the Corporate Human Rights Benchmark to identify gaps and to continuously improve human rights management in the company. Institutional and stakeholder engagement is essential for the company to keep up to date, to actively contribute to debates, to develop joint actions, in addition to improving its human rights management processes. The critical issues that are being addressed are complex and systemic; therefore, intersectoral collaboration is essential if effective and transformative results are to be achieved.