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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 with respect to Human Rights. This is why the Company is committed to the UN Guiding Principles on Business and Human Rights.

Vale operates on a foundation of respect, awareness and promotion of Human Rights, as well as the prevention of potential adverse impacts and Human Rights violations and their mitigation and remediation in Vale's activities and throughout its productive chain when necessary. The Company values stakeholder engagement and alignment with international principles and standards.

The rupture of the B1 Corrego do Feijão Dam in Brumadinho, four years after the Fundão Dam rupture in Mariana, led the company to review its governance and operational risk assessment, Human Rights and remediation processes and other practices once again.

KPIs Report

In 2019, aligned with the Company's strategic pillars, Vale defined indicators of our employees’ respect for Human Rights as benchmarks for performance evaluation and variable compensation purposes.

 These indicators, called Key Performance Indicators (KPIs), include a Human Rights risk self-assessment, which considers 91 risk situations. In 2019, 51 ventures, including operations, projects and mineral exploration, forwarded their self-assessments and proposed action plans that will be analyzed by Human Rights professionals who can make recommendations.

In 2019 and in the coming years, in addition to the self-assessment of Human Rights risks, an external due diligence assessment is also planned.

Performance Evolution

Vale's Human Rights management is aligned with the United Nations Guiding Principles on Business and Human Rights and is assessed through initiatives such as the Corporate Human Rights Benchmark (CHRB). This is comprised of investor and civil society organizations such as the Business & Human Rights Resource Centre, Aviva Investors, APG, Eiris Foundation, the Institute for Human Rights and Business, VBDO and Nordea.

The CHRB evaluates the largest companies in the extractive, apparel and food sectors and the degree to which these companies implement the UN Guiding Principles in their management processes. Given its focus on continuous improvement, Vale evolved from 27th place in 2017 to sixth place in 2018 in the general list, and to third place among extractive companies, as shown below:

Due to the breach of Dam B1, on January 25, 2019, in Brumadinho, Minas Gerais, Vale´s 2018 scores were suspended by the Corporate Human Rights Benchmark. For 2019–2020, Vale will not be ranked given the Brumadinho Dam breach. Regardless, the Company remains committed to the initiative, to working in line with the UN Guiding Principles on Business and Human Rights and to answering the basic ranking questionnaire.

Goals and Deadlines

Some of Vale’s 2019 commitments are:

To review the Human Rights Policy that has been in place since 2009 and was updated in 2014 and again in 2019. This year, in addition to the internal participatory process, a public consultation was held with 382 contributions from various stakeholders.
To review the Human Rights Guide.
To conduct Human Rights Risk Self-Assessments in 51 projects, as well as to propose Action Plans to improve management processes.
To conduct Human Rights training for leadership and thematic areas, including the Reparation team.
To perform external due diligence on priority operations and suppliers.
To ensure a 100% response rate to the allegations and controversies received from the Business & Human Rights Resource Centre (BHRRC), an international organization that provides space for the transparency of Human Rights management on its website.

From 2020 onward the plan is to:

    Monitor the action plan for the sites that carried out self-assessments, as well as expand external due diligence.
    Improve Human Rights management in procurement processes, including the risk controls review and the Supplier Code of Ethics and Conduct.
    Expand the Human Rights training and update the in-person and online content, orientation for new employees and customized actions by theme and audience.
    Review internal regulations related to the theme of Human Rights.
    Strengthen business risk management as a second line of defense along with operational areas.

Impact Management

The Human Rights theme is transversal and informs the processes of different areas of the Company. To manage in an integrated manner and ensure alignment between regulatory standards and process management, Vale has an area dedicated to the theme. The structure, made up of nine professionals with different backgrounds and experiences in the private and public sectors, is part of the Sustainability and Social Performance Area, which is linked to the Executive Director for Institutional Relations, Communication and Sustainability.

Governance

Vale’s Human Rights commitments encompass all levels of the Company and are deployed from the Board of Directors to all Vale professionals.

The normative documents on the subject – among which we highlight the Human Rights Policy and the Code of Ethical Conduct – are global and follow an elaboration and approval process that applies to technical areas 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 Directors; the Sustainability Committee, which is made up of members of the Board of Directors and independent members; and finally, by Vale's Board of Directors.

Human Rights issues are also addressed by the Risk Management Committee, which is also made up of members from the Board of Directors. This committee has its own governance and is assigned to address the most critical risks that have already been analyzed in the operational area (first line of defense), the second line of defense that involves the normative areas of Human Rights issues, and other areas.

Grievance mechanisms, as well as internal critical issues that may impact or violate Human Rights, are addressed at different levels according to their complexity. If a matter cannot be resolved locally, it is referred to higher levels, including the Regional, Business, National Management Committees and even the Executive Directors or the Board of Directors/Committees.

This governance allows for the resolution of grievances and the improvement of the management processes for Human Rights issues.

Regulatory Commitment

In addition to the Human Rights Policy and other Company regulations, Vale has a Human Rights Guide and specific documents that delve into relevant Human Rights issues in the extractive sector. Vale makes its contents available to all employees and leaders through dissemination processes and onsite and online training.

Due diligence

Vale implements the Human Rights due diligence process by following the steps below:

Assess potential risks and impacts of the Company’s activities on Human Rights by identifying, designing and implementing detective, preventive and mitigating controls.
Integrate the results of the above assessments into the Company's processes, including policies and standards review, procedures, budget, among others.
Monitor controls to analyze their effectiveness in Vale's activities in relation to its suppliers and its production chain.
Report the Company´s risk and impact management performance on Human Rights.

Remediation

When necessary, Vale undertakes measures to remediate 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.

Access information about the reparation process related to:

Establishment of grievance and reporting mechanisms

Vale seeks to establish legitimate, accessible and equitable channels for capturing all types of Human Rights issues, including claims, complaints and demands. In the case of complaints, the Company ensures the option of anonymity through the Ombudsman. Vale also provides community relations professionals to strengthen dialogue and promote engagement. Grievance and reporting channels do not prevent access to other judicial or non-judicial mechanisms. Vale considers these mechanisms to be fundamental tools for preventing and remediating potential Human Rights impacts and violations.

Policies and Procedures

Since 2009, Vale has had a Human Rights Policy aligned with the United Nations Protect, Respect and Remedy matrix. 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 email 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 benefit from the contributions.

Normative Commitments

The Company has formalized our Human Rights commitments and practices. They are detailed in the following documents, among others:

The norms guide the management of our Human Rights commitments and the positioning of topics such as: respect for diversity, 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 labour and modern slavery; and artisanal and small-scale mining. Other relevant topics are considered and foreseen in the 2019 update of the Human Rights Policy.

These commitments are in line with international standards for respecting Human Rights, including the United Nations Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the Voluntary Principles on Security and Human Rights (VPSHR), the International Labour Organization (ILO) Fundamental Conventions, the United Nations Declaration on the Rights of Indigenous Peoples, the United Nations Global Compact, the International Council on Mining and Metals (ICMM) Principles, the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises, the Sustainable Development Goals (SDG), and the International Finance Corporation (IFC) Performance Standards.

Risks

Risk and impact management considers all Human Rights issues in the Company's activities, by identifying, elaborating, and implementing detective, preventive and mitigating controls.

In addition to business-related Human Rights risks and controls, we also perform self-assessments and external due diligence.

The Company's self-assessment methodology considers 91 risk situations that address socioenvironmental, labour, procurement, and health and safety issues; respect for Human Rights defenders; discrimination; inclusion and accessibility; incidents involving workers and communities; land use conflict; water access; forced labour or modern slavery; child sexual exploitation; community engagement and dialogue; relationships with Indigenous peoples and traditional communities; artisanal and small scale mining; involuntary removal; mobility and access issues; moral and sexual harassment; among others.

Self-assessments are conducted with the participation of multidisciplinary groups of professionals from different areas of the Company that identify and analyze each risk situation in an integrated manner and with different points of view. These professionals consider the current controls; the probability of occurrence, severity and degree of each risk; and propose action plans when necessary.

The Company integrates the results of these evaluations in its management through a process of continuous improvement. Vale monitors the controls to analyze their effectiveness in its activities and relationships with suppliers and business partners.

Evaluating suppliers

Vale’s supplier contracts have a commitment clause that outlines a supplier’s obligation to respect human rights and comply with Vale's Human Rights Policy and Supplier's Code of Ethical Conduct. The new supplier registration process identifies possible Human Rights violations. If Human Rights violations are verified, appropriate measures are taken. In 2019 and 2020, Vale is reviewing its Human Rights management process as it relates to suppliers and will incorporate new controls.

Perspectives

For the coming years, Vale’s main commitment is to remedy the impacts caused by the Company's operations and projects in Brumadinho and to increase the effectiveness of its risk and impact management, ensuring the Human Rights of our communities, employees and impacted third parties.

Vale participates in leading global forums on the subject, monitor trends and changes in legal requirements, and pursues good practices in Human Rights management, focusing on the continuous improvement of management policies and processes.

Volunteer Actions

Technical and institutional commitments

Vale participates in important Human Rights initiatives and institutions, proposing standards and procedures and sharing challenges and best practices. Among the initiatives and institutions we can mention are: Ethos, the Global Business Initiative (GBI), the International Council of Mining and Metals (ICMM), the World Business Council for Sustainable Development (WBCSD), the Brazilian Business Council for Sustainable Development (CEBDS), the Voluntary Principles Initiative on Security and Human Rights (VPI), and the Corporate and Human Rights Benchmark (CHRB).

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