Human Rights

Vale understands and 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.

In addition, in remote regions, 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, there is a risk of aggravating the socioeconomic vulnerability of these territories. The company's human rights management needs a firm stance, as well as an intersectoral approach which allows the confrontation of complex and systemic problems.

The company is committed to the UN Guiding Principles on Business and Human Rights and is aligned with international principles and standards.

Thus, Vale's Human Rights strategy and 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 and Human Rights violations, and when necessary, the mitigation and remediation in Vale's activities and throughout its supply chain. The company valuesengagement with stakeholders, mindful that there is still room for improvement in this process.

The rupture of the B1 Dam at Córrego do Feijão in Brumadinho, four years after the collapse of the Fundão Dam, in Mariana, led the company to review the governance and health and safety processes, the operational excellence, the operational risk assessment, the remediation process and the Human Rights governance and management, among others.

Latest highlights of Human Rights management at Vale:

Review of the Vale’s Global Human Rights Policy (2019), including a Public Consultation;
The Risk of Human Rights Violation is part of Vale's Global Integrated Risk Map since 2020;
Insertion of the Human Rights lens in policies and fronts related to the topic, such as risk management, supplier management, corporate security, facilities/accommodation and human resources, as well as in the company's decision-making processes. In 2021, a total of 29 policies were revised;
Training in Human Rights became mandatory for all employees since 2021. There is also a training video in human rights for employees and contractors globally;
Holding webinars for Vale’s Board of Directors, Executive Vice Presidency and Vale leadership and their teams from various areas. To watch Professor John Ruggie's video narrating the article he wrote for Vale’s Walk magazine click here;
3rd edition of the Human Rights Guide;
Since 2020, 100% of Vale operations assess and register their risks of human rights violations, in Vale´s global risk management system which are monitored by the Human Rights area;
Commitment to respond to 100% of the allegations and controversies brought by the Business Human Rights Resource Centre (BHRRC) - in 2022 Vale responded to five allegations received;
Advancement in Human Rights management process for suppliers, in partnership with the Procurement area - from registration to the identification and management of contracts and critical suppliers, with the application of a questionnaire on the Human Rights management maturity, capacity building and engagement, and increase in desktop and in-person human rights inspections of suppliers in Brazil (external due diligence). Since 2019, more than 80 due diligence were carried out on suppliers and, in 2022, 129 suppliers participated in Human Rights training;
As one of the commitments in its Human Rights Roadmap, by the end of 2022, 76% of the company's operations underwent external human rights due diligence, equivalent to 100% of Vale´s active operations in Brazil;
Engagement with strategic stakeholders and partnerships in the promotion of salient issues at Vale and with our suppliers and partners. Issues such as Sexual Exploitation of Children and Adolescents, Modern Slavery, Artisanal and Small-Scale Mining, and Decent Wages, are addressed through strategic partnerships with Childhood Brasil, InPacto, Global Business Initiative on Human Rights (GBI), BSR, among others

Performance Evolution

Vale's Human Rights management and approach are committed to the UN's Guiding Principles on Business and Human Rights, following the proposed macroprocesses. Learn about each one of them and their contexts in the company:

Policy Commitment and Integration

Since 2009, Vale has a Human Rights Policy aligned with the "Protect, Respect and Remedy" framework established by the United Nations (UN), which underwent two revisions (2014 and 2019) to ensure alignment with the UN Guiding Principles for Business and Human Rights. Its latest revision, included public consultation on Vale's website (in Portuguese and English), postings in on social media, and email communications to different stakeholders. A total of 382 respondents from different sectors and social groups participated in the consultation, with important contributions.

In order to make the contents of its Policy more tangible and bring it closer to employees, Vale has a Human Rights Guide (3rd edition), in addition to specific documents to delve into Human Rights salient issues for in the extractive sector.

The policies guide the management of Human Rights and the positioning on issues such as:

Respect for diversity, political and union freedom;
Raise awareness about sexual harassment;
Combat child sexual exploitation;
Fight against discrimination;
Fight against child and forced labor and modern slavery;
Corporate security practices;
Relationship with communities, including indigenous peoples and traditional communities;
Involuntary resettlements;
Grievance Channels;
Artisanal and small-scale mining.

The formalization of other commitments related to the Human Rights theme includes the following policies and guidelines:

Vale's commitments are aligned with international standards of respect for human rights, including:

Universal Declaration of Human Rights;
UN Guiding Principles on Business and Human Rights;
Voluntary Principles on Security and Human Rights (VPSHR);
International Labor Organization (ILO) Core Conventions;
UN Declaration on the Rights of Indigenous Peoples;
United Nations Global Compact;
Principles of the International Council on Mining and Metals (ICMM);
Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises;
Sustainable Development Goals (SDGs);
International Finance Corporation (IFC) Performance Standards.

Modern Slavery Act Statement

The UK Modern Slavery Act, 2015, requires companies that need to abide by it to publish annual statements on the management of critical issues of slavery and human trafficking for each financial year of the organization.

In this document, you will find statements from Vale Canada and Vale Europe, controlled by VALE S.A., which are subject to the UK Modern Slavery Act. The terms of the declarations include the declarants' commitments to safety, sustainability and respect for human rights in their value chain. Vale and the companies are opposed to modern slavery and human trafficking in all its forms and expects their suppliers to also combat modern slavery in their own supplier and subcontractor networks.

To access the companies' annual statements, click below:

Vale Canada

Vale EU

Integration

Human Rights management is present in all phases of the lifecycle of Vale's enterprises, from mineral exploration to mine closure and in all business lines.

Regarding integration there are three main fronts:

Inclusion of the Human Rights lens in the policies and processes related to the topic such as Risk, Procurement, Corporate Security, Human Resources;
Integration of the results of risk assessments and external due diligence in new controls to be adopted by operations through new processes;
Close partnership with the Procurement area, since Vale's contracts with suppliers have clauses for commitment to respect Human Rights, in addition to the obligation to respect Vale's Global Human Rights Policy and the Principles of Conduct for Third Parties.

Training

As a natural consequence of the Global Human Rights Policy, since 2009 Vale conducts training and dissemination of Human Rights content for its employees. The knowledge has been internalized through in-person and remote training of leaders, directors, executive managers, managers, specialists and supervisors and staff (analysts) by the Human Rights team. The training courses are available in Portuguese, English, Spanish, Japanese, Bahasa, French, Arabic and in brazilian sign language in the several countries where Vale operates.

In 2021, the Human Rights training became mandatory for all Vale employees.

Vale also discloses - to employees, suppliers, joint ventures and customers - content related to critical human rights issues, such as:

Culture and reality of indigenous peoples;
Gender relations;
Forced and child labor;
Children sexual exploitation;
Diversity and inclusion;
Collective bargaining and freedom of association.

Risk and Impact Assessment

Consists of assessing potential risks and impacts of mineral research activities, operations, projects, and joint ventures and on an ongoing basis focused on identifying, preventing, mitigating, and treating risks and negative impacts on human rights with a focus on people - employees and/or contractors and community members - including indigenous peoples and traditional communities.

The identification of risks promotes the elaboration and implementation of action plans with preventive and mitigating controls complementary to those already adopted, in order to reduce the risk exposure for people and for the company. Risk mitigation also takes place through a continuous process of engagement with communities and through partnerships with Childhood Brasil and InPacto with preventive and mitigating actions.

Human Rights impact management is regulated by the Global Human Rights Policy. At Vale, this process may occur as a result of direct verification, of complaints in the company's grievance mechanisms, as a response to allegations, by external Human Rights due diligence, by the Audit process or Whistleblower channel, and in new ventures (mergers and acquisitions and joint ventures).

To follow the main processes in progress, access the link of the Controversies page.

The due diligence process in operations and projects and joint ventures follows a set schedule and can also generate action plans for its mitigation or remediation which are monitored and provide feedback to the company's policies and processes.

Human Rights external Due Diligence methodology at Vale enterprises

In addition to Human Rights risk assessments, Vale also carries out verification or due diligence processes as part of its Human Rights management. The due diligence includes the in-depth assessment of risks and impacts on Human Rights, primarily in all company operations and critical projects; the integration of the results into the company's corrective actions; the monitoring of such actions, and communication of the treatment of the risks and impacts identified.

Human rights salient issues assessed include forced labor, child labor, child sexual exploitation, human trafficking, freedom of association, discrimination, sexual harassment, among others. Among the groups vulnerable to human rights violations considered in the due diligence process are: employees and contractors, women, children, local communities, including indigenous peoples and traditional communities, and public authorities.

The due diligence process is part of Vale's Human Rights Roadmap (2020) and is being carried out in all critical operations and projects within 3 to 5 years, corresponding to approximately 15 due diligence per year.

Due diligence is prioritized according to territorial clusters, allowing the process to be optimized by recognizing similar inherent risks and logistical gains.

The process is carried out by a specialized and independent company which verifies documents and conditions in loco and conducts interviews and focus groups with employees and contractors, grouped by gender, community members and Government representatives, academia, and civil society. The results of the evaluation are then shared with Vale's Human Rights area and with each operation or project evaluated. The recommendations are transformed into controls and corrective actions for the risk management enhancement and remediation of the negative impacts identified. The Human Rights Area monitors the entire due diligence execution process and the controls and corrective actions implementation.

Between 2019 and 2020, external pilot due diligence were conducted in four operations, two of which were international. In 2021, with the revised methodology, 14 due diligence were conducted in operations and projects in the North Corridor in Brazil. In 2022, another 22 due diligences were carried out in projects in the Southeast and South Corridor, thus closing the cycle of external HRDD in active operations in Brazil.

In overall terms, the due diligence process comprises the following steps:

Alignment with the enterprise's Directors/Executive Managers
Collection and analysis of requested documents
Individual interviews with Managers
Field visit, in loco interviews and focus groups
Analysis, consolidation and feedback
Recommendations’ improvement and final report
Development of corrective actions and risk controls by the enterprise
Monitoring of the action plan related to the recommendations

It is important to highlight that M&A of new projects and joint ventures also go through an external verification/due diligence process. Vale's critical suppliers and lodgings also go through due diligence process, but with specific methodologies and procedures. In 2020, 127 of Vale´s workers´ lodges in the States of Para, Maranhão, and Minas Gerais, in Brazil, underwent HRDD, action plans were monitored in 2021.

Joint Ventures Not Operated (NOJVs)

In 2022, engagement on ESG practices began with the main operational joint ventures not operated (NOJVs) by Vale, where maturity assessments of practices and multidisciplinary benchmark forums were carried out with Vale and the companies. In the Social aspect, for example, a human rights risk violation assessment was carried out in the companies in which Vale has a stake greater than 10%. Given the nature of the business and the sector in which the assessed NOJVs operate, Vale considers that the existence of human rights risks is inherent to all these companies.

The NOJVs responded regarding the Human Rights management practices in their activities, of which 36% indicated to have mitigating measures address violation of human rights risks.

Monitoring and Reporting

Risk action plans are monitored on a monthly basis and internal reporting of the Human Rights management performance at Vale follows the company's risk management governance. The external reporting is done annually in the Integrated Report and quarterly through the ESG Portal. Vale also answers several questionnaires from institutions focused on sustainability and ESG content.

Regarding community engagement and reporting, periodic meetings are held and the agenda is defined together, reflecting their priorities.

Since 2020, 100% of operations have their risks assessed and recorded in Vale's risk management system and the action plans of the enterprises are monitored along with the other business risks.

Grievance mechanisms and Whistleblower channel

Macroprocess for the global management of demands, the grievance mechanism can be used by any rightsholder to communicate/interact with the company. They require some kind of response or action from the company.

Vale currently has the following grievance channels with global coverage: Contact Us, Community Relations Personnel (RC) and the Whistleblower Channel. And local channels in certain areas of operation, such as the RC Online, the Reparation Call Center, and Hello Railway.

The relationship teams also communicate directly with their stakeholders, in local language, allowing for stronger dialogue and engagement, as well as greater promptness and efficiency in the potential conflict mitigation and resolution processes. 

The grievance process, as well as internal salient issues that may impact or violate Human Rights, are addressed at different levels according to their complexity. When the issue cannot be resolved locally, it is submitted to higher levels, including regional, business, national management committees, and even the Executive Vice Presidency or the Board of Directors and its committees.

In 2020 and 2021, Vale trained various grievance channels of operations in Brazil, Indonesia (in addition to Mozambique and Malawi, which were sold at the end of 2021) to adhere to international standards for the operation of the mechanism, advanced in implementing stakeholder satisfaction surveys for grievance channels in Brazil. The online RC (www.vale.com/rconline) was also established - a support tool system that can be accessed, via computer or cell phone, by the community, to record complaints, facilitating accessibility, the recording of demands, and allowing for greater efficiency in the grievance process and response.

The main grievances received in 2022 ere related to, road and highway accessibility, dust, and weeding and pruning.

Numbers from Vale's channels in 2022:

11,085 registered community demands, globally;
99.4% were responded to and 84.2% were addressed/treated;
The time limit to contact the stakeholders is 10 days, from the date of the demand;
The average time for treatment and finalization of the demand is approximately 90 days.

Additionally, Vale has a Whistleblower Channel as part of its Ethics & Compliance Program. The Channel can be accessed by anyone, inside or outside Vale, who wishes to report a case of suspicion or ethical misconduct. The Whistleblower Channel numbers from 2022 are:

6,736 registrations (65% of the complaints were anonymous);
6,600 closed registrations (46.6% of the investigated complaints were confirmed);
2,941 corrective actions established, including 171 terminations of employment.

For more information, please see the Compliance and Integrity Program 2022.

These grievance mechanisms and Whistleblower channel (which may be anonymous), however, do not prevent access to other judicial or non-judicial mechanisms.

Remediation

The remediation macroprocess is initiated as a result of the identification of impacts generated by Vale's activities during the risk and impact assessment process or by the due diligence process or by complaints and reports filed.

Vale is committed to the remediation of adverse human rights impacts that it has caused or contributed to and collaborates with other relevant initiatives for human rights in the territories where it operates. The company does this directly and/or through partners, seeking to involve stakeholders in the preparation and implementation of remediation actions, and is committed to the principle of non-repetition.

Brumadinho

On January 25, 2019, Dam I at Córrego do Feijão mine, in Brumadinho (MG), ruptured, significantly impacting communities in the Brumadinho region and the Paraopeba river. In this tragedy, 270 lives were lost, which include two pregnant women, their unborn babies, and 4 missing victims. 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 repair the damage caused to families, community infrastructure, and the environment.

In February 2021, Vale, the State of Minas Gerais, the Public Defender's Office of the State of Minas Gerais and the Federal and State Public Prosecutors’ Offices entered into the Global Settlement for Integral Reparation of Brumadinho with an economic value of R$ 37.7 billion, which includes socio-economic and socio-environmental reparation projects. On the socioeconomic side, the agreement includes on demand projects and income transfer programs for the affected communities and projects for Brumadinho and the municipalities of the Paraopeba Basin.

An important aspect of the reparation process was the expansion of grievance spaces in the communities, social organizations, and neighborhood associations. The participatory construction of projects together with the communities seeks to listen to them and incorporate their expectations co-designing various reparation initiatives that have been structured and implemented in the territory.

Family Reference Program

The grievance and engagement process with communities takes place through initiatives such as the Family Reference Program, which aims to ensure psychosocial support to people and families affected by dam rupture and evacuations. In Brumadinho, the program brings together a team of 17 professionals who act as:

Reference (RF) - 15 regular and systematic follow-up agents, responsible for building a relationship for support, guidance, and psychosocial rehabilitation of the families of fatal victims or those who have been removed.
Volante Reference (RV) - 2 agents for specific services, responsible for the reception, guidance, and intersectorial interaction of affected people and families, based on demands presented through the Vale's grievance channels (RCs, PAs, PIs, PAIA, SRD, among others).
Intersectoral Articulation - It establishes spaces for intersectoral integration with managers and technical staff who work in governmental bodies in order to build a space for dialogue and allow for a shared management of the monitoring of affected people and families.

In Brumadinho, up until June 2022, approximately 70,000 psychosocial consultations were carried out and 600 families were systematically monitored.

Communication with affected communities

Presently, the Community Relations team is composed of 11 professionals who work in Brumadinho.

The dialogue takes place through field visits, meetings, and forums with the communities, in person and virtually, following all Covid-19 prevention protocols, and aims to bring transparency to the actions and explain how the reparation and compensation processes take place in the territories.

The process of active listening in the communities also occurs through daily interaction, whether by teams of professionals dedicated exclusively to the relationship with the communities, or by technicians in water and agriculture, construction, and housing.

The agendas are discussed in meetings with representatives of the impacted communities, prosecutors and other public authorities, and with the families of the victims and representatives of the Fire Department on a regular basis.

Relationship with local communities

Vale also maintains constant dialogue with:

Association of Families of Victims and Affected People by the Tragedy of the Dam I rupture at Córrego do Feijão mine, in Brumadinho – Avabrum - Official representative of the 270 victims’ families recognized by the Public Prosecutor's Office. Regular meetings are held with Vale's Special Department for Reparation and Development, including its Officer. During these meetings, Avabrum presents the family members' wishes. One of the requests, for example, was for a space for families to come together. The plan for space use and activities were defined jointly with Avabrum, creating the Living Together Center for the victims' families, through partnership with Vale and inaugurated in February 2021. The purpose is for family members to get together for exchanges, mutual help, to establish or strengthen relationship in workshops focused on the re-signification of pain, such as art therapy, and other complementary and integrative practices, such as yoga, acupuncture and massage therapy. The place also offers a playground area with monitors for children over the age of 3, making it possible for their guardians to participate in the activities.

Indigenous people

Two senior anthropologists are responsible for the relationship with the Pataxó and Pataxó Hã Hã Hãe, in São Joaquim de Bicas (MG). The performance follows the guidelines of the Brazilian National Indigenous Foundation (Funai) and the dialogue with them occurs through:

Meetings in the village;
Psychosocial care;
Dedicated consultancy to oversee the Emergency Health Care Plan;
Leaders' access to the Community Relations (RC) analyst's phone
Monitoring of emergency payments;
Monitoring the execution of the Term of Preliminary Agreement (TAP);
Regular visits;
Monitoring of the demands presented.

Traditional communities

Two senior anthropologists are responsible for the relationship with the Quilombola Communities of Marinhos, Sapé, Ribeirão and Rodrigues, in Brumadinho. The performance follows the guidelines of Fundação Cultural Palmares. The interaction is based on:

Meetings in the territory, with leaders or with the communities in general;
Psychosocial accompaniment to the victims' families;
Individualized assistance to the families of the victims;
Monitoring emergency payments.

For a complete overview of all the work fronts related to Brumadinho, access the Reparation page.

Mariana

On November 5, 2015, tailings containment structure of the Fundão dam at the Germano site in Mariana (MG), operated by Samarco, collapsed. Nineteen lives were lost, and the body of one of the victims is still missing. Of the confirmed fatalities, 13 were professionals from Samarco contractors, four were local residents and one person was visiting Bento Rodrigues at the time.

For a complete overview of all the work fronts related to the remediation process in Mariana, access the Renova Foundation's website or the Renova Foundation's Reparation page.

Stakeholders engagement and Salient issues management

This section illustrates that, besides following the management processes, the integration of Human Rights needs to consider the engagement with stakeholders and salient issues.

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 employees (employees and contractors) have a double role when the subject is Human Rights: they are, at the same time, subjects and agents.

Subjects because they need to have their rights respected, and agents because they themselves also need to respect the rights of colleagues, family members, and people in the communities where they operate.

For more information on human resources regulations, working conditions, benefits, freedom of association, collective bargaining, and Vale´s commitment to providing a living wage to its employees, see the People chapter in the 2022 Integrated Report.

For Vale, the health and safety of its employees, communities and employees in its production chain is fundamental. The tragedy of the Dam I rupture at the Córrego do Feijão Mine in Brumadinho led the company to completely review its health and safety strategy. For example, processes such as hazard identification and risk assessment related to activities and services of a catastrophic nature.

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 activity, among others. The company's governance was also revised, establishing an Vice Presidency, with its own budget, to act as a second line of defense.

Security teams

The security teams are a group that deserves special attention in relation to the respect for human rights because 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 their rights must be respected, they deal with conflict situations and, when faced with 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, as well as the increase of the effectiveness of the actions and the reduction of the incidence of critical occurrences in the operational areas.

Vale is a signatory to and applies the Voluntary Principles on Security and Human Rights (VPSHR) and provides information through the report we submit to the VPSHR and participate in its annual forums.

In the assessments of potential risks to security requirements, those related to potential human rights violations are included. The management of security teams considers the following aspects:

Select employees and closely follow their activities, considering previous experience, technical capacity and emotional stability;
To constantly train the professionals to perform their activities following the principles of human rights and 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 according to the United Nations Basic Principles on the Use of Force and Firearms by Law Enforcement Officers;
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 recommended by the Voluntary Principles on Security and Human Rights (VPSHR), Vale is committed to collaborate with public security providers and to communicate its Global Human Rights Policy to demonstrate its commitment to respect the human rights of its managers and employees and all members of the communities where it operates. In Brazil, agreements have been made with law enforcement agencies for cooperation and support between the parties.

Vale repudiates misuse of power and inhumane treatment, in order to ensure non-discrimination and privacy. In addition, as part of its control over potential impacts, Vale encourages its own employees, third parties, community members, suppliers and other stakeholders to report incidents related to security and human rights.

Suppliers, clients and partners

Vale establishes relationships with entities that are aligned with its principles and values and that respect the Global Human Rights Policy, the Sustainability Policy, the Code of Conduct, the Principles of Conduct for Third Parties, the HSE Guide for Vale Suppliers, the anti-corruption guide for suppliers and third parties, and the Guide for the Mobilization of Service Providers. About Human Rights management in the supply chain, read the Risk section on this page.

Learn more in the Suppliers page of the Governance section.

Communities, indigenous peoples and traditional communities

Vale's activities, in general, require interactions with communities, indigenous peoples and traditional communities. The company engages with them, paying special attention to women, children and adolescents, as well as other groups that may be more vulnerable.

In addition to following guidelines throughout its operations and projects for establishing relations with potentially impacted indigenous people, Vale complies with international commitments and applies international references, such as the International Council on Mining and Metals (ICMM) declaration, Convention 169 of the International Labor Organization (ILO), and the United Nations Declaration on the Rights of Indigenous People.

In Brazil, to support the relationship with these traditional people and communities, the Stakeholders, Demands and Issues System (SDI) is used:

Voluntary social investment;
Impact diagnosis and studies,
Impact mitigation and grievance management programs and projects.

In addition to complying with international commitments and apply international references related to indigenous people, the company incorporates the indigenous and traditional communities' themes transversally in the diverse processes of internal risk analysis and enterprise feasibillity, effectively considering the rights and interests of these communities in decision-making. In this sense, Vale has relationship plans for all the indigenous peoples and traditional communities that live in the areas of influence of its activities.

In Canada, we maintain relationships with Peoples in the regions of Ontario, Manitoba, Newfoundland and Labrador. In Newfoundland and Labrador, Vale partners with government and other stakeholders through the Labrador Aboriginal Training Partnership to develop skills and training opportunities for hiring.

The program has already helped more than 2,000 participants with job opportunities at the Voisey's Bay mine - where the Job Readiness Training program was also implemented, aimed at qualifying aboriginal people who want to enter the labor market.

Learn more about Vale's relationship with indigenous people in the Indigenous People and Traditional Communities page of the ESG Portal.

In relation to community safety - the concept of "accidents with communities" was revised, including simplification of the system for recording accidents, and reinforcement of corrective actions and training in operations. Vale participates annually in the ICMM report, which registers safety events related to member companies and reports through the official channels of the sectorial federal agencies - for example the National Land Transport Agency.

In terms of community relations, numerous initiatives are carried out to raise awareness and by Vale's Accident Prevention and Investigation Commissions.

Accidents on railways operated by Vale. The rate of these occurrences has been decreasing over the last few years and is improved when compared to the sector's average. Even so, it is still necessary to maintain the awareness-raising work in the neighboring communities, especially along the railways.

At Carajás Railway (EFC) and Vitória-Minas Railway (EFVM), themes related to mobility and risky conduct have prompted Vale's projects to reduce impacts on communities, as well as having internal norms and documents for such occurrences. When accidents do occur, they are monitored by Vale's Accident Prevention and Investigation Commissions.

Human Rights Defenders

Vale recognizes the importance of the Human Rights Defenders role and does not tolerate or contribute to threats, intimidation or attacks against Human Rights Defenders.

Besides recognizing its importance, Vale also

Respects freedom of speech and demonstrations when they are peaceful and do not impact local legislation in force;
Uses as reference Resolution 53/144, of the UN General Assembly, which deals with the role of human rights defenders;
Seeks engagement to deal with common challenges, through constant and proactive dialogue.

States and Society

In relation to States and society, Vale recognizes the importance of its collaboration and partnership with governments and civil society, through social responsibility actions, and contributions to respect and promotion of human rights.

In this sense, Vale has been contributing since 2020 with public authorities to support actions toward combating COVID-19.

Follow the Comapny engagement and actions here.

Governance

Commitments to human rights must be respected by all the company professionals, regardless of their position or function. Starting with the Board of Directors and unfolding to all employees. This commitment is reflected in company main documents such as, in the Bylaws, where it is stated the Board of Directors' responsibility to act as a guardian of the commitments related to the respect for human rights.

The Human Rights theme is transversal at Vale and is inserted in processes of different areas of the company.

The normative documents on Human Rights, in particular the Human Rights Policy and the Code of Conduct, are global and follow a process of preparation and approval that involves not only areas such as Legal, Sustainability, Human Resources, Health and Safety, Risk Management, Community Relations, Procurement and Corporate Security, but also the Vice Presidents and the Vale’s Board of Directors.

Human rights issues are also dealt with in the Risk Management Committee, which has its own governance and is responsible for addressing the most critical risks that have already been analyzed in the operational areas.

Find out more about Vale’s Governance here .

Risks Management

Vale's risk management governance is based on the concept of lines of defense - and considers all topics related to Human Rights in the company's activities, through risk identification, preparation and implementation of preventive and mitigating controls. These assessments are made by operations, by the Human Rights area, through internal or external due diligence, and by Audit.

From 2019 onwards, with the company's governance and risk management review , the Human Rights area started to act as a second line of defense and the related topics are dealt with in the Executive Committees for Operational Risks and Compliance Risks.

First line of defense - the enterprises have the primary responsibility and directly manage the risks, in an integrated manner (identification, evaluation, treatment, prevention, and monitoring).
Second line of defense - the specialist corporate areas are responsible for developing and maintaining risk management, internal controls and compliance; and for identifying and monitoring new/emerging risks, ensuring continuous improvement and compliance with the risk management model, laws, regulations and standards.
Third line of defense - the Internal Audit and the Whistleblower channel are totally independent from management. They carry out evaluations and inspections, and perform control tests and investigate complaints, providing impartial assurance - including on the effectiveness of management and risk prevention, internal controls and compliance.

Human Rights Risk Assessments

Since 2020, 100% of Vale's operations enter their risks into the company's global risk management system and work on action plans to address risk situations. In addition to providing training and advice to the operations, the Human Rights area, part of the 2nd Line of Defense Specialist in the theme, monitors the actions plans' status throughout the year and make quarterly reports to the Risk Committee and the Executive Vice Presidency.

Using the Bowtie method, the risk situations are analyzed into a list of causes of the risk of Human Rights Violations, grouped within four critical Human Rights themes as per below.

Risks assessed

It is important to emphasize that in the case of the Human Rights risk assessment, like the environmental assessments, the focus is on the risk that the company's activities pose to Human Rights with respect to its directs employees and/or contractors, employees in the supply chain, and members of the communities - including indigenous peoples and traditional communities.

The integration of the results of these evaluations is considered in the company's management in a permanent process of continuous improvement focused on identifying, preventing, mitigating and treating risks and negative impacts on human rights. Controls are monitored in order to analyze their effectiveness both in Vale's activities and in its relations with suppliers and business partners.

The risk themes assessed are:

Degrading Work Conditions and Modern Slavery: impact on employees, contractors and/or suppliers due to disrespect for the rights of immigrant workers, excessive working hours, infrastructure and accommodation conditions, illegal wage deductions, document retention, illegal withholding of compensation, vacation and/or leave, as well as restriction of mobility outside the operational area after work shift.
Child Labor and Child Sexual Exploitation: impact on children and adolescents resulting from hiring workers under the age of 18 (or below the age required by law) for activities that involve risks to their health and safety or resulting from exploitation of children and adolescents in the vicinity of Vale operations by its employees, contractors and/or suppliers.
Human Rights Violations in Labor Relations: impacts on employees, contractors, and suppliers, resulting from inappropriate conduct, discrimination and harassment, inadequate ergonomic working conditions or infrastructure necessary to perform the work (including PPE, places for meals and rest, restrooms, among others); the absence or failure of grievance mechanisms, the absence of training, inadequate compensation; impediment to free association and collective bargaining and/or the failure to monitor certain labor or social security obligations.
Large-Scale Human Rights Violations: impacts on people and the environment due to major accidents such as explosion and/or fire in operational structures; leakage or breach of dams, ore, oil and/or gas pipelines; railroad, air, bus / automobile, and ship accidents.

Evaluating and monitoring suppliers

Vale selects suppliers taking into consideration objective, technical and economic criteria in accordance with legislation and internal regulations - Principles of Conduct for Third Parties, Sustainability Policy, Vale’s HSE Guide for Suppliers, anti-corruption guide for suppliers and contractors, Global Human Rights Policy and Guide for Mobilizing Service Providers.

The relevant Human Rights violation risks identified by Vale in the relationship with contractors and suppliers include:

Modern slavery - degrading working conditions, working hours above what is permitted by law, debt bondage, physical and emotional coercion, document retention, among others;
Child labor;
Child sexual exploitation;
Human trafficking;
Discrimination and harassment.

In order to detect these and other risks in contractors and suppliers, Vale has a robust management process for its suppliers. The main stages are:

Certification and registration

Risk analyses are performed globally in 100% of the new registered suppliers through a background check and the submission of documents, such as a self-declaration form, presenting details of qualification in Health, Safety and Environment (HSE), Human Rights and Integrity.
In Brazil, a consultation to the “Dirty List” of slave labor is done, crossing the information with 100% of the supplier base.
In addition, the company encourages suppliers to implement compliance programs and follow the same guidelines in their production chains.

Selection, Quotation and Contracting

Suppliers commit to expected behavior standards in accordance with Vale's policies, and undertake, through contractual clauses, to

Provide decent working conditions;
Combat child labor and sexual exploitation;
Combat forced labor or modern slavery;
Not tolerate discrimination; and
Respect freedom of association and collective bargaining.

Vale's standard contracts also contemplate anti-corruption and HSE clauses.

Contracts and Supplier Management

In 2020 Vale improved the process for managing Human Rights within its suppliers and established a process for assessing the criticality of the contract and the vulnerability of the supplier's Human Rights management. Suppliers that are at high risk from the point of view of Human Rights, undergo a desktop analysis, field visits, if necessary, and preparation of a report to identify weaknesses linked to the supplier's activity in relation to Vale.

This work resulted in the Human Rights due diligence (documental and on site) of over 80 suppliers up until 2022. An action plan is was required for some of them to address the risks identified, which are being periodically monitored.

There is continuous monitoring of updates to the Dirty List of Slave Labor and if any of Vale's suppliers are included in this list, an internal process is opened to assess the case and establish an action plan;
Center for Evaluation of Third-Party Contracts (NACT): monitors suppliers in Brazil regarding labor and health and safety issues. It will be expanded to all suppliers in 2021;
Contractor Management System (SGC): monitors the occupational health and safety aspects and risks pertinent to the entire life cycle of the applicable contracts: administration, third-party mobilization, mobilization of equipment and vehicles, daily work report, SPS control, among other functionalities that support managers and inspectors in their activities.
Supplier Performance Index (IDF): monitors the performance of suppliers in Brazil and Mozambique, based on technical criteria of health and safety, environmental protection, respect for labor rights and continuous improvement through an action plan. It underwent, revision and was improved in 2020. Among the criteria for evaluation of contract renewal or not are the results of the IDF, but also the performance of contractors verified in audits /due diligence of HSE and Human Rights and Human Rights allegations.

Supplier Development - Training to improve performance

Vale seeks to ensure quality, transparency, and continuous improvement in its relationship with its suppliers by fostering sustainable and competitive businesses.
Promotes knowledge sharing to build a more responsible and human rights conscious supply chain. With this objective, in 2022, 129 suppliers were engaged in training and participation in webinars on Human Rights themes.

If there is an impact or violation of human rights, appropriate measures are taken. Suppliers that present a higher degree of risk are engaged in different ways, including monitoring action plans to deal with deviations, meetings on Human Rights, and sharing of good practices. Furthermore, in Brazil, in each edition of the Dirty List, the entire supplier base is verified and if a company or person is identified on the list, the contract is suspended.

What is the Dirty List ?

Brazilian public transparency mechanism created in 2003, which discloses the names of individuals or companies that have been caught using slave labor. Currently, the rules governing the composition of the "Dirty List" are described in Ordinance n°4 of 11/05/2016 (signed jointly by two ministries), and its list is published by the Secretariat of Labor Inspection, linked to the Ministry of Economy.

Goals and Deadlines

The expected outcomes for 2023 are:

Review of internal norms related to Human Rights;
Continuation of leadership and employee training on Human Rights;
Control monitoring and carrying out verifications and due diligence in operational areas by the Human Rights area, part of the second line of defense specialist;
Perform external human rights due diligence focused on halted mines and mines under decommissioning in Brazil, as well as one Vale operation outside Brazil;
Monitoring of 100% of the action plans of operations that conducted Human Rights assessments or external due diligence;
Continuation of the 'Living Wage' Program by renewing the partnership with the international organization for the monitoring and evaluation of the compensation of own employees at a living wage level according to global benchmarks.

Perspectives

The main action fronts mapped are the remediation of the impacts caused in Brumadinho and in Mariana, and the treatment of allegations and impacts.

Vale has a Human Rights roadmap (2020) to improve all macroprocesses adopted by the company in Human Rights management by 2025, including:

Policy commitment and integration

Disseminate Global Human Rights Policy to all employees and leaders;
Insert Human Rights content in company’s existing norms;
Train leaders and employees (training in Human Rights is mandatory for all Vale employees).

Risk and Impact Assessment

Monitor controls and 100% of operations action plans;
Maintain the external due diligence front in Human Rights for operations and projects;
Strengthen the risk management of the supply chain beyond Brazil.

Monitoring and reporting

Improve the process of recording and reporting information related to Human Rights management, including the development of indicators;
Continuous improvement in reporting on Human Rights issues;
Monitor trends and changes in legal requirements and seek best practices in Human Rights management with a focus on continuous improvement of policies and management processes.

Grievance Mechanisms

Continue to improve the 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, including those mapped by the Business and Human Rights Resource Centre.

Remediation - beyond the priority remediation processes

Ensuring that human rights impacts caused by the company are effectively remediated and, in the event that Vale's activities contribute or are related to impacts, have the company be part of the solutions.

Volunteer Actions - Partnerships

Vale participates in key initiatives with institutions that work in Human Rights and maintain engagement with stakeholders on critical Human Rights issues to achieve better proposals and solutions. In addition to contributing to the advancement of the agenda at Vale across the board. This participation includes contributing to the development of standards and procedures and sharing challenges and best practices.

Among the initiatives and institutions are:

Global Business Initiative on Human Rights (GBI)

International Council on Mining & Metals – ICMM)

Voluntary Principles on Security and Human Rights (VP)

Brazilian Business Council for Sustainable Development (CEBDS)

Business for Social Responsibility (BSR)

World Business Council for Sustainable Development – WBCSD

In 2019, the WBCSD launched the CEO Guide on Human Rights, endorsed by executives from large companies, including Vale. The 'call to action' demonstrates the leadership of these CEOs on human rights issues, positioning them with respect to embedding human rights in the corporate culture, expectations on their suppliers and business partners to respect human rights, and the promotion of cross-sector collaboration on the topic.

Since 2019, Vale maintains partnerships with Childhood Brazil and InPACTO - Instituto Pacto Nacional pela Erradicação do Trabalho Escravo (National Pact Institute for the Eradication of Slave Labor), whose projects, and initiatives, are being developed throughout 2021-2022. These partnerships reinforce Vale's commitment to and mobilization in defense of the rights of children and adolescents, with a focus on preventing and combating sexual exploitation of children, and on combating modern slavery and child labor in its value chain.

Childhood Brasil

Vale and Childhood Brasil are partners in the implementation of the Na Mão Certa (In the Right Direction) Program. Launched in 2006, the program aims to combat sexual exploitation of children and adolescents on Brazilian highways. The main strategy adopted is to make truck drivers aware of the issue, so that they act as agents for the protection of the rights of children and adolescents. The state of Pará was the pilot for implementation of the project, since there is a large circulation of trucks in Vale's service. By joining the program, Vale has adhered to the Business Pact Against Sexual Exploitation of Children and Adolescents on Brazilian Roadways.

InPACTO – National Pact Institute for the Eradication of Slave Labor

Through its association with InPacto, Vale has contributed to the development of tools to identify vulnerabilities in the locations of origin of suppliers and service providers, with the aim of contributing to the elimination of modern slavery, as well as child labor. The Slave Labor Vulnerability Index is a geographic information system that allows the crossing of social indicators, generating an index of how vulnerable each municipality may be to occurrences of slave labor. In 2021-2022, Vale and associated companies will use this tool to better control contracts with third parties in vulnerable municipalities.

Institutional engagement

Vale remains committed to the principles of the UN Global Compact and the Ethos Institute for Business and Social Responsibility, although due to the rupture of Dam I at the Córrego do Feijão mine, in Brumadinho, it has been temporarily suspended from the Ethos Institute and has had to leave the Global Pact.

Nevertheless, the company remains engaged in order to identify gaps and continuously improve its Human Rights management.