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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 considered 91 risk situations in 2019. Thus, 55 ventures, including operations and mineral exploration (excluding only operations halted by the need to dams decommission), in Brazil and across the world forwarded their self-assessments and action plans to be analyzed and commented by Human Rights professionals. In 2020, the Ventures Action Plans will be monitored quarterly by the Human Rights area, as the second line of defense.

In addition to the self-assessment of risks in Human Rights, external due diligence was also carried out in 2019 and others are also planned for 2020 and for the coming years.

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 concluded commitments

From 2020 onward the plan is to:

Impact Management

Since 2009, Vale has a Human Rights Policy aligned with the United Nations 'Protect, Respect and Remedy' framework. In 2014, it carried out the first review to align it with the United Nations Guiding Principles on Human Rights Framework for Business and completed a new process review, including public consultation, in the end of 2019.

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 eight 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

Human rights' commitments are respected by all company professionals, regardless of their position or function. Beginning with the Board of Directors and unfolding to all Vale's employees. This commitment is reflected in the company's main documents, for example, 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 normative documents on the subject – among which we highlight the Human Rights Policy and the Code of 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 and response 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 subject-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 and its Committees.

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

Human Rights Management at Vale – Based on United Nations Guiding Principles on Business and Human Rights

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:

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 to capture all types of manifestations, including requests, claims, complaints, informations, suggestions and compliment. In Vale's system, negative manifestations are characterized by requests, claims or complaints. 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, response 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 themes related to Human Rights in the company's activities, through the identification, elaboration, implementation and monitoring of 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 methodology adopted for self-assessments considered, in 2019, 91 risk situations that were listed in a standardized manner during this process. The assessments consisted of an applicability analysis - not all 91 risk situations were applied to all operations. The risks addressed socio-environmental, labor, supply, health and safety issues, respect for human rights defenders; discrimination; inclusion and accessibility; accidents involving employees and communities, conflict over land use; access to water; forced or compulsory labor; child sexual exploitation; engagement and dialogue with the community; relationship with indigenous peoples and traditional communities; artisanal and small-scale mining; involuntary removal; mobility and access; moral and sexual harassment.

The operations were prepared to carry out Self-Assessments through methodology training reaching 344 professionals from 55 operations, from the most diverse areas.

Self-assessments are performed with the participation of multidisciplinary groups that identify and analyze entirely each risk situation. Different analysis on current controls, probability and severity risk occurrence were considered and action plans were proposed.

The evaluations results are being considered in our management, in a permanent process of continuous improvement. The monitoring of controls is carried out to ensure effectiveness in Vale's activities and in the relationship with its suppliers and stakeholders.

In 2019, the self-assessments applicable to the 55 ventures in operations in Brazil, Canada, Chile, China, Indonesia, Japan, Malaysia, Mozambique, New Caledonia, Oman, Peru, United Kingdom, were grouped into 8 risk groups, according to relevance. These situations represent the main risks faced by Vale in its operations. As noted in the Ranking:

The results of the Self-Assessments have already contributed and will continuously contribute to the evolution of Human Rights management and for the development, adaptation and expansion of the training and dissemination processes of the theme, to engage professionals, to review normative documents and to identify synergies and good practices related to Human Rights content.

Among the existing risk situations and controls, there was a need to develop corporate monitoring and control instruments for human rights risks in the supply chain, a work that was initiated by the Procurement area along with the Human Rights area support in 2019, with implementation taking place in the second half of 2020.

Evaluating and monitoring suppliers

The contracts with suppliers have a commitment clause  on the respect for Human Rights and the obligation to respect Vale's Human Rights Policy and the Supplier's Code of Ethical Conduct. The registration process for new suppliers includes a background check for possible misconduct related to Human Rights.

In 2020, in addition to the existing process of evaluating the supplier's background for registration purposes, a process for assessing salient issues, from a Human Rights perspective, within suppliers is being implemented, which will guide the monitoring of the suppliers considered critical. If there is an impact or violation of Human Rights, appropriate measures will be taken.

Between 2019 and 2020, Vale is reviewing the Human Rights management process regarding its suppliers and new controls that will be incorporated.

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 Institute, 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 Human Rights Benchmark (CHRB).

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