2025 Ethics and Compliance Report
Energising today Advancing tomorrowIntroduction
Our business at a glance
Governance and structure
Our Programme
Key risks
Our business partners
Additional information
Headquarters Marketing Industrial
One of the world's largest natural resource companies
6
continents
>30
countries
>140k
employees and contractors
For further information, see glencore.com/en/ who-we-are/purpose-and-values/
Our global operations …delivered through two business segments
Industrial activities
Our industrial business spans the metals and energy markets, producing multiple commodities from around 40 industrial assets
Marketing activities
We source, market and distribute over 60 commodities that advance everyday life
…supported by our ValuesSafety
We never compromise on safety. We look out for one another and stop work if it's not safe
Responsibility
We take responsibility for
our actions. We talk and listen to others to understand what they expect from us. We work
to improve our commercial, social
and environmental performance
Simplicity
We work efficiently and focus
on what's important. We avoid unnecessary complexity and look for simple, pragmatic solutions
Integrity
We have the courage to do what's right, even when it's hard. We do what we say and treat each other fairly and with respect
Openness
We're honest and straightforward when we communicate. We push ourselves to improve by sharing information and encouraging dialogue and feedback
Entrepreneurialism
We encourage new ideas and quickly adapt to change. We're always looking for new opportunities to create value and find better and safer ways of working
Introduction
Our business at a glance continued
Governance and structure
Our Programme
Key risks
Our business partners
Additional information
Our PurposeOur people
Communities
Investors, banks, financial analysts and the media
Governments and regulators
Suppliers and customers
Unions
NGOs
and civil society groups
Industrial business
Marketing business
Responsible and ethical business practices
Responsibly sourcing the commodities that advance everyday life
…influences our strategic priorities …which we deliver through our business model …while engaging with our stakeholders and creating valueEffective capital management
Strong operational and commercial performance
Introduction
Governance and structure
Our Programme
Key risks
Our business partners
Additional information
Chairman and Chief Executive Officer's introduction
Dear stakeholders,
We are pleased to present to you our 2025 Ethics and Compliance Report. We recognise that ethical conduct is crucial to our operations. It protects the integrity of our business, safeguards the interests of our employees and partners, and underpins the value we deliver to our customers, shareholders and the communities where we operate.
Our Ethics and Compliance Programme is designed to deliver this Group-wide commitment and supports responsible and ethical decision-making at every level of the business.
Last year, we announced that the US Department of Justice (DOJ) ended our two monitorships approximately one year early, following an assessment of the facts and circumstances of our case. This was an important milestone for the Group and is the culmination of extensive efforts over the last number of years to develop and implement the Programme and make cultural, governance and control enhancements.
During the monitorships, we undertook
significant work to constructively engage
The Board and senior management are focused on ensuring we uphold responsible business practices and maintain an effective compliance programme. We remain committed to continuous improvement and ensuring that our Programme is fit
for purpose, particularly given the complex geopolitical environment in which we are currently operating.
Through continued engagement, communications and targeted training, we continue to promote awareness across different levels of the organisation. We also place continued emphasis on fostering a
culture where our employees feel empowered to act with integrity and to speak up when they have concerns.
We are grateful to our colleagues and stakeholders for their constructive efforts during this past year and we look forward to your continued engagement on these important topics.
Kalidas Madhavpeddi
Chairman
Gary Nagle
Chief Executive Officer
with the monitors and to further enhance
our Programme.
In May 2025, following her dedicated efforts as Head of the Monitorship Liaison team, Nicola Leigh took over as our Head of Compliance.
Kalidas Madhavpeddi Chairman
Gary Nagle
Chief Executive Officer
Introduction
Governance and structure
Our Programme
Key risks
Our business partners
Additional information
Shaun Teichner
General Counsel
Nicola Leigh
Head of Compliance
We are committed to maintaining a robust, risk-based Programme that is tailored to our business
General Counsel and Head of Compliance annual overview
In 2025, we focused on ensuring that our Programme is operating efficiently and consistently and that it is appropriately tailored to our business needs. At the beginning of the year, our work was primarily focused on the monitorship process and completion of the second review period. Following the conclusion of the monitorships in March 2025, we concentrated our efforts on positioning
our Programme for continued maturity and long-term sustainability. We have engaged actively with the Board and senior leadership throughout the organisation regarding our vision for the Programme and post monitorship priorities.
At the same time, while we believe we now have a mature programme, we recognise that it will not remain effective if it is static and that continuous improvement is required to support ongoing risk mitigation. The compliance landscape is also very dynamic, particularly in the current complex geopolitical environment, and an effective compliance programme needs to evolve
in response to ongoing developments.
We have therefore used the monitors' observations, and our own continued analysis, to identify areas of improvement and assess ongoing effectiveness. There are many aspects of the Programme that have been in place for a number of years and we have been able to analyse and assess how the Programme is operating in practice.
Through these continuing efforts, we have identified several opportunities to enhance our existing processes and have continued to implement targeted improvements
and refinements.
Organisational structure
In 2025, we reviewed the operating model and team structure across our corporate compliance and regional compliance teams and strategically realigned certain areas to enhance oversight and increase consistency in approach. We believe that these changes make our teams more efficient and focused and will allow us to better support our business with tailored advice.
Leveraging technology
In both our marketing and industrial businesses we are making significant additional investments in systems that are aimed at improving consistency and efficiency, enhancing data quality, oversight and improving our overall control environment.
We have substantially completed the implementation of our trade and e-comms surveillance systems in our marketing departments which are designed to detect and alert us of potential market manipulation. We have also automated our vessel-related compliance processes by implementing a business-accessible list of approved vessels across the Group and automating ongoing sanctions screening.
Our teams continue to explore further ways to leverage technology, automation and build out systems controls where appropriate. This includes ongoing work enhancing existing platforms and migrating to new platforms for certain of our processes and controls, for example in relation to know your counterparty (KYC) and third party due diligence and management (TPDDM).
Risk assessments
Our risk assessments are designed to identify, record and evaluate compliance risks faced by our marketing and industrial businesses. In 2025, we initiated a comprehensive redesign of our compliance risk assessment
Introduction
General Counsel and Head of Compliance annual overview continued
Governance and structure
Our Programme
Key risks
Our business partners
Additional information
process at both Group and local levels to help ensure that our Programme is appropriately designed and tailored to respond to the compliance risks across our operations. As part of the redesign,
we refined our risk categorisation to better reflect the nature of our compliance risks and support a more consistent and comparable approach to risk assessments across the Group. We also enhanced our processes to guide regional teams through structured and consistent assessments
to determine the underlying activities that drive compliance risks, likelihood of
occurrence and the potential consequences of these risks. Regional teams must then evaluate the effectiveness of the controls
in place to mitigate the risks identified and implement appropriate corrective action if any critical controls are determined to not be operating effectively. This approach
is designed to enhance consistency, transparency and responsiveness and ultimately helps us to proactively assess the effectiveness of our controls on a continuous basis.
Compliance policy architecture The development, implementation and review of our Group policies, standards, procedures and guidelines remains an important element of our Programme. Last year, we initiated a comprehensive review of our Compliance documents to identify opportunities for improvement.
Key updates were made to a number of documents and processes. These updates reflect our efforts to clarify requirements for a more efficient and consistent application across the business. For example, we implemented certain updates to our Travel, Gifts and Entertainment Standard to provide clearer guidance on home-country restrictions and simplify processes related
to employee expenses and pre-approvals. We also reviewed our third party payment processes in marketing and industrial assets.
As part of this work, we conducted a risk assessment to evaluate the requirements in both documents, established more centralised approval processes and simplified onboarding documentation.
These changes seek to refine processes while maintaining a focus on mitigating the underlying risks.
During 2025, we also advanced our KYC and TPDDM processes, which are critical controls in our Programme. This review confirmed that our requirements remain largely fit
for purpose, reflecting the maturity of our Programme, but also identified areas that could benefit from further refinement. For example, we introduced a new Community Investment Due Diligence and Management Procedure (CIDDM Procedure). This had previously been captured as part of our Third Party Due Diligence Management Procedure, however we separated this into
a standalone document to cater for the nuances around community investments and enable us to adopt a more risk-based, proportionate approach to the compliance due diligence of community investments.
Monitoring
We also began a redesign of our monitoring activities, transitioning to a more proactive, continuous compliance monitoring model, intended to enhance early issue identification, improve real-time support and use data more comprehensively. Key features of this model include a refocused monitoring team, the reallocation of traditional audit testing
to our Group Internal Audit and Assurance function (GIAA), enhanced collaboration with regional compliance to support more timely and informed follow-up, and redesigned, streamlined processes to provide clearer task allocation.
As part of this transition, we are piloting the redesigned model within selected SAP environments from Q2 2026, under which the Risk Assessment and Monitoring team
develops risk indicators and dashboards, Regional Compliance performs risk-based follow-ups, and outcomes are centrally recorded, providing a scalable framework to progressively expand monitoring across systems and business areas.
In addition to this monitoring work, GIAA has
continued to conduct reviews of elements of the Programme, with two such reviews occurring in 2025. One review focused on
the local implementation of our Programme, with a detailed assessment at five different locations. The other review focused on
the Group Market Conduct Surveillance Programme, with a detailed assessment conducted at nine different offices in scope of our trade and communications surveillance requirements.
Speaking openly and raising concerns We continue to focus on speaking openly and raising concerns as a key element to support an open culture where employees feel comfortable raising concerns. This is integral to the successful implementation of our Programme. We have continued to promote the Raising Concerns Programme
(RCP) and the various reporting channels we offer through a number of different means, including a refresh of RCP materials and posters, as well as the launch of a new Speaking Openly Hub on our intranet,
which provides more details and guidance on what concerns to raise and how they should be raised. These materials are designed to encourage engagement and include real life examples and insights into how investigations are conducted.
We have also continued to invest in systems
to support the RCP such as upgrading our Group reporting platform, leading to a more seamless experience for reporters,
and improving the quality of information we receive to ensure appropriate action can be taken. Furthermore, we have advanced our capabilities in terms of analysing RCP data
to help us identify trends and highlight potential risks by leveraging Power BI and making relevant dashboards available to key stakeholders.
Further, we have increased Group oversight for concerns raised locally by implementing quarterly sample testing of concerns raised and increasing engagement with the departments and other local stakeholders.
These enhancements enable us to determine where additional focus or better controls may be required within our Programme.
Looking forward
Overall, we are proud of the progress that we have made this year and remain firmly committed to maintaining our Programme and ensuring that our people, systems and processes operate effectively. The progress outlined in this report reflects the continued effort across our organisation to embed responsible practices and to learn from our experiences and challenges we have faced.
We are confident that the actions we are taking position us to effectively manage our risks and build long-term trust with our stakeholders. We thank our teams for their ongoing dedication as we continue to advance our Programme.
Shaun Teichner Nicola Leigh
General Counsel Head of Compliance
Introduction
Governance and structure
Our Programme
Key risks
Our business partners
Additional information
Under the process set out in our Joint Ventures, Mergers and Acquisitions, and Disposals Procedure we reviewed and approved1
17
new joint ventures
2
M&A transactions
9
disposals
Approved and active third parties that we continue to monitor in our third-party due diligence programme
Ethics and compliance at a glance
438
in our marketing business
1,611
in our industrial business
Rejected third parties2
0
in our marketing business
2
in our industrial business
New conflicts of interest declarations received
1,690
for 1,540 of these, a management action plan
was created or they were in the process of being reviewed and signed off.
Know your counterparty approved for
4,776
marketing counterparties
12,096
industrial asset counterparties
Know your counterparty rejected for2
15
marketing counterparties
21
industrial asset counterparties
Raising Concerns Programme
697
reports were recorded through the Raising
Concerns Programme, the majority of which
were HR-related concerns.
798
reports were closed, 311 of which were
protected concerns within the scope of the
Programme and capable of investigation.
Of the 311 protected concerns investigated, 45% were either substantiated or partially substantiated, and 97% of protected concerns substantiated or partially substantiated resulted in at least one recommendation for remedial action.3
Of the substantiated concerns related to business integrity, the majority related to conflicts of interest. Refer to page 29 for further detail.
Number of Code of Conduct e-learnings completed
40,000+
Further internal approvals may be required following approval by Compliance, figures therefore may not correspond to the number of transactions implemented.
This reflects rejections for compliance reasons following completion of the onboarding process. It does not reflect rejections where, following engagement between Compliance and the business, the onboarding
process was not completed.
Examples of remedial actions include improvements to policies and procedures, safety measures, implementation of IT systems and controls, vendor blocklisting, dismissals and warnings. Remedial actions may be
recommended even in cases where the protected concern is not substantiated or partially substantiated.
14
15
10
11
12
Tone at the top: our leadership Governance
Our Compliance team Support from Group corporate functions
Group Internal Audit and Assurance
Governance and structure
Introduction
Our
Governance and structure
Programme Key risks
Our business partners
Additional information
2025 Glencore Ethics and Compliance Report 9
Governance and structure
IntroductionOur Programme
Key risks
Our business partners
Additional information
Our commitment to ethics and compliance starts at the top with our Board of Directors and senior management.
Board engagement
Our Board bears ultimate responsibility for the implementation of a compliance programme that reflects our Values and strategic direction, is proportionate to our risk profile, appropriately resourced and effective in practice.
Our Board also plays a critical role in overseeing and assessing our culture of ethics and compliance and ensuring policies, practices and behaviours are consistent with our Values.
All new Non-Executive Directors receive an onboarding with the Head of Compliance, covering our Programme, compliance risks and the Board's oversight role for ethics, compliance and culture.
Key activities and responsibilities of the Board include:
Tone at the top:
our leadership
receiving quarterly updates on whistleblowing and investigation processes
as well as material investigations;
participating in annual training, which covers topics such as the Board's role,
our key compliance risks and developments in ethics and compliance requirements and expectations; and
promoting and enhancing our culture
of ethics and compliance.
The Board's Ethics, Compliance and Culture (ECC) Committee comprises
four independent Non-Executive Directors and is chaired by Cynthia Carroll. The ECC Committee receives quarterly updates on the Programme, including with regard to risk assessments and compliance resources.
The Board has designated workforce engagement directors who conduct engagement around key ethics and compliance topics and collect feedback on our Programme. Non-Executive Directors also play an important role in promoting a culture of integrity and have an opportunity to collect feedback during their site visits.
A typical visit to an industrial asset includes a tour of the facility and discussions with local management as to challenges and opportunities. It also includes a session with a cross-section of workers without management present to encourage the workers and Non-Executive Directors to freely and openly ask questions of each
other. In addition to meeting with the local CEO, the Board members have private meetings with other members of the local management team and other key stakeholders such as the local CFO,
external audit partner, a team member from internal audit and assurance and the health, safety, environment, social performance and human rights (HSEC&HR), human resources and legal and compliance leads.
In 2025, the Board undertook site visits to EVR in Canada, as well as to our oil,
ferroalloys and coal assets in South Africa.
Senior management
Our senior management team also plays a key role in outlining our expectations with regard to ethics and integrity across the Group.
Individual members of senior management work to embed ethical considerations into decision-making processes and day-to-day activities. Together with the Board, they are collectively responsible for ensuring that the initiatives of our Programme are effectively cascaded across all levels of the organisation.
Senior leaders promote ongoing changes to our Programme by actively supporting their implementation led by different teams and overseeing initiatives within their respective areas of responsibility.
"Workforce engagement is key to achieving our overall strategy and maintaining a strong culture."
Cynthia Carroll
Chair of the ECC Committee
Introduction
Our
Programme Key risks
Our business Additional partners information
Governance and structure
Governance
Compliance governance by the Board and management
Board
Board oversight is provided through the Board directly, in respect of whistleblowing and investigation processes, and through the
ECC Committee and Audit Committee.
Leadership commitment to ethics and compliance is critical and we seek to embed it and reinforce it at all levels of management.
ECC Committee
Responsible for overseeing the Programme and approving key ethics, compliance and culture-related matters within the Group. Comprises at least two members, all of whom must be Non-Executive Directors appointed by the Board. The committee currently comprises Cynthia Carroll (Chair), Gill Marcus, Liz Hewitt and María Margarita Zuleta.
The Head of Compliance has a dotted reporting line to the ECC Committee, meets regularly with the Chair of the ECC Committee and is afforded the opportunity to meet with the ECC Committee without the rest of the management team being present.
Audit Committee
Reviews Glencore's financial and risk management systems. Comprises at least three Non-Executive Directors, all of whom shall be independent and at least one of whom shall have
the appropriate professional qualifications and recent and relevant financial experience. The Committee currently comprises Liz Hewitt (Chair), Martin Gilbert and Gill Marcus.
RCIC
BAC
ESG Committee
Management
Our Programme governance is supported by three management-level committees, namely the Environmental, Social and Governance Committee (ESG) Committee, the Business Approval Committee (BAC), which is a sub-committee of the ESG Committee, and the Raising Concerns and Investigations Committee (RCIC).
Refer to our Corporate governance
section in the 2025 Annual Report beginning on page 85 for further information.
Reviews and considers various ESG matters, programmes and projects implemented across the Group. It also reviews and approves Group policies and key standards and procedures.
Comprises Glencore's CEO, CFO, COO, General Counsel, Head of Compliance, Head of Corporate Affairs, Head of Human Resources, Head of HSEC&HR and Head of Sustainability. It also includes other senior members
of department management representing marketing and industrial assets across different commodities.
Determines and sets guidance and criteria and reviews business relationships, transactions and counterparties that may give rise to ethical or reputational concerns.
Comprises Glencore's CEO, CFO, General Counsel, Head of Corporate Affairs, Head of Sustainability, Head of Compliance and, where applicable, heads of departments and corporate functions involved in the matter being considered by the BAC.
Oversees the operation of our Raising Concerns Programme and the conduct of investigations, and is
tasked with ensuring recommendations and sanctions are applied consistently across the Group.
Comprises Glencore's CEO, CFO, General Counsel, COO, Head of Human Resources and Head of Compliance.
Governance and structure
IntroductionOur Programme
Key risks
Our business partners
Additional information
Our Compliance team
Our Compliance team designs, develops and monitors the effectiveness of our Programme.
The team is made up of full-time corporate,
regional and local teams.
Regional and local team members are assigned to cover different assets and offices across our global network. Some team members cover assets and offices across multiple departments, while others may cover a single complex industrial asset, which may itself comprise multiple industrial sites.
We also have a network of local compliance contacts that support the Compliance function with compliance messaging.
Local compliance contacts are appointed in lower risk jurisdictions or smaller offices or assets, where a full-time local or regional compliance person on the ground is not required. A list of compliance contacts is published on the office or industrial asset's local intranet site, or communicated via other means, such as email announcements. Compliance contacts receive tailored training regarding their role.
Compliance leadership
•
General Counsel
Reports to the CEO
Attends Board meetings and its Audit,
ECC and HSEC Committee meetings
Chairs the ESG Committee and the
RCIC and is a member of the BAC
Oversees the Raising Concerns
Programme and associated
investigations and updates the Board on these matters, together with the Head of Human Resources and the Head of Compliance
Head of Compliance
•
Reports to the General Counsel
Has a dotted reporting line to the ECC Committee and attends meetings of
the ECC and Audit Committee, as well as the updates to the Board on the Raising Concerns Programme and associated investigations
Member of the ESG Committee, the
RCIC and the BAC
Oversees Group Compliance and
manages our Programme
Informs the Board and senior
management on our Programme's
progress and obtains their support
for key Compliance policies, standards
and procedures
Corporate Compliance
Compliance team management
Local Compliance
Group Compliance
Regional Compliance
Corporate Compliance
Compliance leadership
Head of Compliance
General Counsel
Responsible for designing, monitoring and continuously improving our Programme
Based at our headquarters in Baar, Switzerland, in our principal marketing
offices in London, New York, Beijing and Singapore, as well as certain other offices in our global network
Includes subject matter experts (SMEs)
for each of our key compliance risks and
teams covering the Programme's
different elements
Provides guidance and advice to regional
and local compliance teams and the
business on implementing our Programme consistently across the business
Regional Compliance
Responsible for the effective implementation and management of
the Programme at offices and industrial assets directly or indirectly controlled or operated by Glencore across all regions in which we operate
Provides guidance and advice to local
compliance teams and the business in
the regions, with support and guidance
from the Corporate Compliance team
Local Compliance
Consists of local compliance officers,
full-time employees who drive the
on-the-ground implementation of
our Programme
Local compliance contacts further act
as an on-the-ground point of contact
across our global network
Governance and structure
Our Compliance team continued
Group Compliance
Full time local compliance
Argentina
South Africa
Chile
Australia
Brazil
Democratic Republic of the Congo
Peru
Singapore
Colombia
India
UAE
China
Spain
USA
Kazakhstan
Switzerland
UK
Canada
Russia
Our Compliance team spans our global footprint
The geographic coverage of our Compliance function has been determined based on:
the risks presented by various businesses and geographies around the world; and
the level and nature of business activity
in a particular country of operation.
As part of our commitment to
embedding and evolving our Programme, we continuously assess corporate, regional and local resourcing and make adjustments as necessary, particularly in response to changes in our risk footprint and the growth of our business. In 2025, we concluded a number of key projects and strategically realigned the Compliance team in certain areas to optimise resource deployment.
We believe that this will help us maintain a robust, centralised and consistent approach to compliance while allowing our regional and local teams to deliver targeted, on-the-ground support.
IntroductionOur Programme
Key risks
Our business partners
Additional information
Governance and structure
IntroductionOur Programme
Key risks
Our business partners
Additional information
Support from Group corporate functions
Collaborates with Compliance on responsible sourcing
helps to identify potential risks and ensure Group-wide systems and controls are in place
Sustainability
Advises Compliance on legal issues relevant to different
requirements, with screening levels aligned to the seniority
and inherent risk of the role
Legal
Human Resources
Inputs into various incentive and discipline approaches
which emphasise the importance of a commitment to
Promotes a strong culture of accountability by working
our Values, Code and our Programme
Oversees consistent reference and background-checking
initiatives by jointly sharing platforms and using screening tools, sharing data on counterparties and helping to align KYC and supply chain due diligence processes across
the Group
to attract, motivate and retain a dedicated workforce
IT
Provides access to a wide range of IT tools and systems and
Works in close collaboration with Compliance on a variety
aspects of the Programme
Shares responsibility with Compliance for developing,
Finance
Includes the Raising Concerns and Investigations team,
communications across the Group, including in the form of employee-focused campaigns related to policies, speaking openly and other compliance initiatives
of initiatives and implementation processes
which manages our whistleblowing and investigations
processes, including the Raising Concerns Programme
HSEC&HR
Collaborates with Compliance on human rights risks as
Engages with Compliance on due diligence processes
well as security issues at our industrial assets
for our direct social contribution partners and any further
necessary checks or processes for the implementation of social contribution projects, in accordance with our internal procedures
Corporate Affairs
implementing and overseeing certain important Group standards that mitigate both financial and compliance risks
Promotes the Programme through external and employee
Compliance must operate with sufficient resources and independence to credibly
implement the Programme
across the Group. Compliance
cannot, however, operate in a vacuum.
Compliance collaborates closely with other Group corporate functions, including Corporate Affairs, Human Resources, Legal, HSEC&HR, Sustainability, Finance, Information Technology (IT) and Group Internal Audit
and Assurance (GIAA).
Each corporate function, as a compliance stakeholder, plays a key role in the Programme's success. The heads of these corporate functions are responsible for supporting the implementation of
the Programme and the compliance
activities within their respective areas.
This collaborative approach fosters a shared sense of ownership and accountability, helping to embed
compliance throughout the organisation.
Governance and structure
IntroductionOur Programme
Key risks
Our business partners
Additional information
Group Internal Audit and Assurance
GIAA's mandate is to provide the Board and senior management with independent and objective assurance over the effectiveness of governance, risk management and control processes. This includes assessing the implementation and embeddedness of relevant aspects of the Programme across the Group.
GIAA audits specific elements of the Programme and undertakes broader assessments of compliance risks across the organisation. Some audit scopes include a range of compliance controls and processes at a particular office or industrial asset while others may focus on a particular control or process across the Group. GIAA does not rely on, but coordinates with, Group Compliance in its audit and assurance activities.
Each year, the GIAA audit plan is developed through top-down discussions with senior management and Group Compliance
to obtain their input on high-risk areas, including compliance risks, together with bottom-up independent risk assessments of the audit and assurance universe, which is GIAA's view of Glencore's risks across
the organisation. This process includes an assessment of ethics and compliance
risks and informs the inclusion of relevant Programme elements in the audit plan. The audit plan is presented to and approved by the Board.
Following each engagement, GIAA prepares a written report containing the audit results and findings. The GIAA reports related to the Programme are reported to the Head of Compliance, as well as to senior management. GIAA also presents a summary of its audit engagement results at the quarterly Audit Committee meetings. Relevant topics regarding the Programme are also presented to the ECC Committee.
In 2025, audits related to compliance included
During 2025, GIAA performed 20 audit engagements that included coverage of compliance-related risks. These comprised:
2
audits focused on specific elements of
the Programme, covering multiple sites
3
targeted reviews to verify the remediation of previously identified compliance-related findings
15
audit assessments of compliance-related risks within business activities
an assessment of:
the Group Market Conduct Surveillance
Programme; and
the local implementation of
the Programme.
The audit of the Group Market Conduct Surveillance Programme assessed the effectiveness of surveillance system rule sets designed to identify potential market abuse. The review covered 12 trade surveillance rule sets applied across 169 order books, together with 23 electronic communications surveillance rule sets used across the marketing offices in scope. The audit
also examined 60 trade alerts and 45 communications alerts generated during the audit period to assess how alerts were reviewed, escalated and resolved.
The audit of the local implementation of the Programme covered 118 relevant controls, together with a review of 70 newly onboarded counterparties and 185 transactions across the locations in
scope of this audit.
GIAA also performed three targeted reviews to verify closure of previously identified compliance findings. In addition to these specific compliance audits, GIAA may also review compliance controls in other audits, which may lead to additional observations, opportunities for improvements and findings.
Governance and structure
Group Internal Audit and Assurance continued
IntroductionOur Programme
Key risks
Our business partners
Additional information
GIAA planning process overview:
Required audits - legal, regulatory
Carry forward and proposed audits
Risk assessment
Audit and assurance universe
Bottom up
Critical planning inputs
Top-down
Top-down themes
Key stakeholder input
Industry hot topics and external insight
Business strategy and priorities
Why is the top-down process important?
The top-down planning process enables GIAA to:
link the audit plan to the strategic direction and priorities of Glencore;
obtain input from key stakeholders to inform the audit plan; and
consider how external factors may impact the audit plan including market hot topics,
industry events and emerging risks.
Draft GIAA audit plan
Stakeholder engagement including Audit Committee approval
Final GIAA audit plan
Why is the bottom-up process important?
The bottom-up planning process enables GIAA to:
link the audit plan with the outcomes of our assurance universe, independent risk
assessment and coverage cycles; and
identify assurance coverage required by industry standards, regulations, legislation
and/or policies.
Introduction
Governance and structure
Our Programme
Key risks
Our business partners
Additional information
18
19
The Glencore Ethics and Compliance Programme Risk assessments
Policies, standards, procedures and guidelines Training and awareness
Advice Monitoring Speaking openly
and raising concerns
Discipline and incentives
Our Programme20
23
25
26
27
30
2025 Glencore Ethics and Compliance Report 17
The Glencore Ethics and Compliance Programme
Our Programme includes various elements related to risk assessments, policies, standards, procedures and guidelines, training and
Key elements of our ProgrammeGovernance Introduction and structure
Key risks
Our business Additional partners information
Our Programme
Ensuring an appropriate system for discipline and incentives
Coordinating objective and consistent
a
n
B
o
a
r
d
o
v
e
r
s
i
g
h
t
Discipline and incentives
See page 30
n
c
e
Risk assessments See page 19
Policies,
d
g
o
v
e
r
n
a
Identifying, assessing and evaluating compliance risks and controls
Establishing approaches and
awareness, advice, monitoring, speaking
openly and raising concerns, investigations, and discipline and incentives.
Dedicated compliance IT systems and data analytics as well as various controls embedded in business systems support our Programme.
The key elements of our Programme establish a risk-based approach to ethics and compliance to address the challenges
presented by our diverse business operations. Together, the elements create a feedback loop, designed to ensure that compliance risks are identified and addressed across
internal investigations, whilst maintaining confidentiality
and protecting against retaliation
Providing safe
Investigations
See page 28
Speaking openly and raising concerns
See page 27
Values Safety Integrity Responsibility Openness Simplicity
Entrepreneurialism
standards,
procedures and guidelines See page 20
Training and awareness See page 23
requirements to mitigate compliance risks and reflect ethical and legal expectations and requirements
Training and raising
our business on an ongoing basis.
Our Programme has been designed with the support of external counsel and other advisors, having regard to the guidance from relevant authorities such as the US Department of Justice, the UK Ministry of Justice and the State Secretariat for Economic Affairs of Switzerland.
channels to raise concerns regarding potential misconduct, including via our Raising Concerns Programme
Assessing the effectiveness of the Programme implementation and identifying opportunities for improvement
Monitoring
See page 26
Advice
See page 25
awareness on ethics and compliance risks
Providing advice and guidance to employees on ethics and compliance matters
IntroductionGovernance and structure
Our Programme
Key risks
Our business partners
Additional information
Risk assessments
As part of our efforts to ensure our Programme is appropriately designed and tailored to our business, and that resources are adequately allocated, we identify, record and evaluate compliance risks faced by our marketing and industrial businesses.
The Corporate Compliance Risk Assessment and Monitoring team conducts an annual Group compliance risk assessment which reviews current compliance risks in a number of different areas taking into account the nature of our business and
the geographies in which we operate. We document these risks in the Group Compliance Risk Register to ensure they
are up to date and relevant, and we assess
whether new risks need to be added. The Group compliance risk assessment process also identifies whether existing
policies, standards, procedures, guidelines and training, as well as compliance resources and skillsets, effectively address current or any newly identified risk(s).
The Group Compliance Risk Register
is reviewed and updated on an annual
basis to determine whether the risks remain appropriate and whether there have been any changes in the activities of the Group
or the industry that might impact our view of the risks and how they may arise.
In addition to the Group compliance
risk assessment, we assess our identified compliance risks in each of our offices and industrial assets across the Group. Regional compliance officers (RCOs), with the assistance and support of local compliance, conduct these local risk assessments using the Compliance Risk Register as a basis to evaluate the inherent risks that exist, assess the overall effectiveness of the controls in place to mitigate those risks, evaluate residual risks, and implement planned controls in the event that existing controls require improvement. In 2025, we completed 78 local risk assessments.
Update to the Group's compliance risk assessment processIn 2025, we initiated a comprehensive redesign of our compliance risk assessment process at both Group and local levels
to help ensure that our Programme is appropriately designed and tailored to respond to the compliance risks across our business.
Historically, our Compliance Risk Register
comprised numerous different areas of compliance risks as well as business activities that could present a risk to our business. We have now refined our risk categorisation to focus on the risks themselves rather than the business
activities that can contribute to these risks.
Our updated Compliance Risk Register includes a comprehensive set of 15 compliance risks, each supported by a precise risk statement to better reflect the nature of our compliance risks and support a more consistent and comparable approach to risk assessments across the Group. The business activities, which include matters such as entering into a joint venture, lobbying and procurement, inform our updated approach to assessing these risks and are captured through responses to our newly introduced smart questionnaires. The update to our Compliance Risk Register allows us to capture a consistent and dynamic inventory of risk-driving activities that can be updated at any time. If a new activity emerges in our business, regional and local teams can promptly assess its potential relevance and impact.
The smart questionnaires are supported
by algorithmic models to guide regional teams through a structured and consistent assessment which helps to determine:
whether a risk applies to a particular office or industrial asset based on its activities;
the likelihood of occurrence, considering external benchmarks (e.g., the Corruption
Perception Index), relevant business
activities and past occurrences; and
the potential consequences of the risk.
Once inherent risk assessments are completed, regional teams are required to evaluate the effectiveness of the controls that are designed to mitigate the risks identified. Critical controls, such as those outlined in the Third Party Due Diligence and Management Procedure and KYC requirements, are essential to managing compliance risk. If the regional team
determines that a critical control is not operating effectively, the team is required to design and implement an appropriate corrective action.
The new categorisation approach and smart questionnaires were successfully integrated into our compliance management system, with the redesigned Local Compliance Risk Assessment process commencing in April 2026. This enables regional compliance teams to apply these enhanced tools to conduct their local risk assessments
going forward.
In 2026, as part of the risk assessment redesign, we will also launch a centralised management action plan (MAP) module to help centralise tracking of remediation
actions and consolidate actions arising from Glencore's combined assurance activities and risk assessments into a central repository.
This will support RCOs by replacing regional action plans and other tools, and is designed to reduce administrative burden, increase efficiency and strengthen follow up processes.
This strengthened risk assessment framework helps ensure that our Programme remains robust, forward-looking and fit for the complexities of our business and the use
of an algorithmic model allows for new activities within our business to have their compliance risk assessed promptly. It is designed to enhance consistency, transparency and responsiveness and ultimately helps us to proactively manage
our compliance risks on a continuous basis.
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Policies, standards, procedures and guidelines
Our Group policy architecture encompasses our Purpose, Values, Code and a suite of policies, standards, procedures and guidelines on various key matters and risks. These are issued in accordance with the Group policy framework.
Our Purpose is to responsibly source the commodities that advance everyday life. This is reflected in our Values - Safety, Integrity, Responsibility, Openness, Simplicity and Entrepreneurialism.
Group policy architectureValues, Purpose and Code
Group policies establish high-level, Group-wide commitments, principles, approaches
and requirements on topics relevant to the Group.
Group standards outline what requirements must be met for a particular topic. They contain detailed requirements that support the principles set out in the Code or a policy. A standard does not set out the step-by-step process of how the specific requirements should be met.
Where there is a need for a unified approach across our business, Group procedures
outline how Group-level requirements must be implemented.
Group guidelines provide detailed guidance, additional advisory information and best practice examples, but do not prescribe mandatory requirements.
Group guidelines
Group procedures
Group standards
Group policies
Our Code seeks to ensure that our Values are reflected in Glencore's daily activities and culture. In our Code, we lay out our commitments and expectations on a range of topics, including how we treat our people, operate safely and responsibly, act with integrity, and protect our assets and information. Our Group policies support
the delivery of our Values and Code, which together detail the behaviour and
performance expectations for all employees working at our offices and industrial assets where we have operational control. Through our Group standards, procedures and guidelines, we seek to establish and implement consistent standards and processes across our business to support responsible and ethical business practices.
Our employees, directors and officers,
as well as contractors under Glencore's direct supervision, working for a Glencore office or industrial asset directly or indirectly controlled or operated by Glencore worldwide, must comply with requirements outlined in our policy architecture, as well as applicable laws and regulations.
New Glencore employees who have access to a work computer must confirm they have read, understood and will abide by our Code and key Group Compliance policies, standards, procedures and guidelines relevant to their role.
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Policies, standards, procedures and guidelines continued
Additionally, all Glencore employees are required to annually confirm they have read, understood and will comply with Glencore's Values, our Code and key Group policies.
Corporate Compliance is responsible for developing, reviewing and rolling out documents within the Group compliance suite in accordance with the requirements of our Group policy architecture.
Given the different structure and organisation between our marketing and industrial activities, Corporate Compliance issues different types of documents for the different parts of the business. In doing
so, the different levels of risk, which are generally higher for marketing activities, are also taken into account.
For activities which are run in a more centralised manner using similar systems and
Our offices and industrial assets are responsible for implementing Group Compliance policies, standards, procedures and guidelines. When required, they are also responsible for developing and implementing local procedures to address local risks and requirements. Due to the diverse nature of our business, we have a number of local procedures that outline how our different offices and assets implement these requirements to meet Group policies
and standards.
Some offices or industrial assets may determine that a local variation of a Group Compliance document is required to include stricter requirements or additional obligations.
For any requested deviations from a Group
Compliance policy, standard, procedure
Developing and reviewing our policies, standards, procedures and guidelinesThe annual Group Compliance risk assessment process analyses whether
the risks identified and listed in the Group Compliance Risk Register are appropriately addressed by our Group Compliance policies, standards, procedures or guidelines, and whether there is a need to introduce new documents or amend existing ones.
In addition, existing Group Compliance documents are subject to periodic reviews in line with our policy governance three-year review cycle. Certain documents may be subject to more frequent reviews if
deemed appropriate.
Any new Group Compliance document or
a material amendment to existing Group Compliance documents, must be approved by the Head of Compliance before being submitted for approval to the ESG Committee, where required. The Board approves all of our Group policies.
Group Compliance standards, procedures
and guidelines are generally translated
as needed, depending on the scope, the nature of the document and the language capabilities of the intended audience.
processes, or in circumstances where there is a major compliance risk that requires a consistent Group-wide approach across
all of our activities, Corporate Compliance generally issues Group Compliance procedures that set out a more detailed process and specific steps that need to be taken. Corporate Compliance may also issue Group Compliance standards which set out minimum requirements but provide some flexibility to develop and implement tailored local procedures.
or other minimum requirement, an office
or industrial asset must document the deviation request and obtain approval from the Head of Compliance.
Documents outlining our internal compliance processes and the operations of the Compliance team are accessible on our Compliance intranet page and ensure that both new and current Compliance employees have a road map for the implementation of various aspects
of our Programme.
Our policies are publicly available
on our website: glencore.com/who-we-are/policies
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Policies, standards, procedures and guidelines continued
Policies
Standards
Guidelines
The Group policy governance suite supporting the Programme includes the following policies, standards, procedures and guidelines.
Anti-Corruption and Bribery | Anti-Money Laundering | Competition Law Policy | Conflict of Interest | Fraud |
Information Governance | Market Conduct | Raising Concerns and Whistleblowing Policy | Sanctions | |
Communications and Device | Data Protection | Know Your Counterparty - Industrial Assets | Protected Concerns Management and Investigation Standard | Travel, Gifts and Entertainment |
Procedures | Anti-Boycott (US/Non-US Entities) | Benchmarks and Price Reporting Agencies | Benchmark Trading Rationales | Community Investment Due Diligence and Management Procedure | Conflict of Interest Management | Corporate Protected Concerns Management and Investigation Procedure | |
Joint Ventures, Mergers and Acquisitions and Disposals | Know Your Counterparty - Marketing | Mandatory Compliance Training Escalation and Discipline | Ongoing Screening | Personal Account Dealing | Position Limits | ||
Russia Transactions | Sanctions Insulation | Third Party Due Diligence and Management | Third Party Payment -Industrial Assets | Third Party Payment -Marketing | Uncleared Derivatives and Investment Advice | Vessel | |
Benchmarks and Price Reporting Agencies | Commodity Department Protected Concern Management Guideline | Competition Law: Dealing with Competition Law in Merger and Acquisition Transactions | Competition Law Guideline: Dealing with Competitors | |
Competition Law Guideline: Dealing with Suppliers, Customers and Agents | Competition Law Guideline: Human Resources and Employment Considerations | Data Protection | Fronting/Sleeving | |
Inside Information | LME Lending Rules | Market Manipulation | Payments and In-Kind Assistance to Public Officials, Government Institutions and State-Owned Entities | Sanctions |
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Training and awareness provides a practical understanding of how compliance risks materialise across the organisation and encourages active engagement on compliance topics.
TrainingTraining
and awareness
We have a comprehensive approach to training which focuses on effective planning and delivery of materials to the right audience.
We track training completions, escalate non-completions and assess the overall effectiveness of different training initiatives.
In addition to the training available to
our broader workforce, we provide further training and development opportunities for members of the Compliance team
to increase their understanding of key compliance risks and important trends and developments. We encourage and fund participation in relevant conferences, lectures and webinars, where appropriate,
and members of Group Compliance receive
ad-hoc, targeted training in their areas of expertise and on relevant areas of the business. We also leverage external law firms and other professional advisers to provide ongoing knowledge sharing.
Each year, we develop a Compliance training and awareness planner (T&A planner). The T&A planner sets training and awareness priorities based on output from a range of sources, including the annual Group risk assessment and local risk assessments, advice which the business has sought from Compliance during the year, the results
of post-training knowledge checks and training feedback surveys, internal audit findings, Raising Concerns reports and other lessons learned and relevant best practices. It also includes training and/or awareness materials on any new or materially updated policies, standards, procedures or guidelines. The T&A planner includes annual mandatory training for our high risk employees on certain topics.
Each office and industrial asset is required to develop its own local training plan, based on the T&A planner, reflecting that office
Code of Conduct training40,000+
99% completion rate
1%
9%
10%
10%
23%
1%
16%
40%
90%
Covers: Glencore's expectations on how to do business safely, responsibly, ethically and legally.
Breakdown by organisation type
Industrial asset Marketing office Corporate office
Breakdown by region
Africa Asia Australia
Europe and FSU
Latin America
North America
Note: audience includes employees and contractors who either a) have regular access to a work computer or b) are given access to a work computer for purposes of training completion.
or industrial asset's local risk assessment, lessons learned, local legal or regulatory changes or any other local circumstances. Training materials are made available to regional and local teams, with the expectation that the materials will be customised at a local level to include specific examples relevant to the local audience.
We recognise that each training session must be tailored to its specific audience to be effective. We have a process for assigning training to employees, based on their compliance risk rating which will depend on their function or role. We regularly seek to measure the effectiveness of our compliance training and awareness activities for example by asking employees to complete short post-training or awareness feedback surveys.
All networked employees have access to
e-learning materials which cover the Code and conflicts of interest. We also develop materials to be used to train front-line employees on how to declare a conflict of interest. We raise awareness among our employees on fraud in various trainings, including our annual Code of Conduct
e-learning and in-person trainings.
We actively monitor mandatory compliance training non-completions and take them seriously. Compliance escalates non-completions of trainings. Employees who repeatedly, without an extenuating circumstance, fail to attend training may
be subject to disciplinary action. Compliance training non-completions are also taken into consideration when assessing an employee's end-of-year performance.
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Training and awareness continued
AwarenessWe supplement our compliance training with awareness initiatives and communications throughout the year. This allows us to communicate compliance updates in an accessible manner and equip our employees with useful tools to remain abreast of relevant guidance and the latest developments in the Programme.
While tone from the top is key, we understand that most employees interact with middle management. The compliance teams work with middle management to help them deliver appropriate messaging on ethics
and compliance risks applicable to their businesses. This can include compliance messaging during townhalls and other employee engagement activities and introducing or co-presenting compliance trainings.
2025 highlightsDeal lifecycle training
In 2025, we delivered an integrated, scenario-based training to around 500 of our high-risk employees in key marketing offices, highlighting red flags across the
different stages of the deal lifecycle and how to mitigate and escalate them. This training covered various compliance risks including bribery and corruption, conflict of interest and sanctions and was designed to reflect the reality of how compliance risks arise and evolve in the commodity trading business. We delivered a similar training highlighting red flags across different compliance risks applicable to different industrial assets to around 1,500 of our high-risk employees
in multiple jurisdictions.
In addition, our high-risk marketing employees also received training covering our market conduct framework, including recent enforcement trends and lessons learned. This training was tailored to address both paper and physical trading, using
real-life scenarios to explain different
types of market manipulation.
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Advice
Advice is a key element of our Programme, as the Compliance team provides the business with valuable guidance to navigate complex compliance matters and to act in accordance with our Code and policies.
Our compliance officers are professionals with compliance, legal and audit backgrounds, who have expertise in areas relating to our key compliance risks. Due to the fast-paced nature of our business, they are required to respond quickly and effectively. They guide the business on changes in laws and regulations and advise on conducting business in compliance with these evolving requirements as well as our policies, standards, procedures and guidelines.
Members of the business and other colleagues can contact regional or local compliance as well as the Corporate Compliance team with their queries. These teams have a broad range of expertise and knowledge of our business, which enables them to provide comprehensive advice on key compliance risks within our business. This strengthens the synergy and cooperation between the Compliance function and the business, enabling a collaborative partnership to
help ensure we act with integrity and in accordance with our policies, standards, procedures and the law.
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We continuously monitor the implementation of our Programme to assess its effectiveness and ensure it
remains effectively implemented across our business. Monitoring helps us to identify opportunities for improvement and to adapt
to changes in our operations, the environments in which we operate, and applicable laws and regulations.
Evolving our approach to compliance monitoringMonitoring
Historically, the Risk Assessment and Monitoring team was established to assess the implementation of our Programme, measure its effectiveness and identify opportunities for improvement. Monitoring was performed through a combination of site reviews and desktop reviews.
Site reviews involved visits to our offices and industrial assets to assess the effective implementation of our Programme.
Desktop reviews included Corporate Compliance thematic reviews and data analytics projects. Corporate Compliance reviews assessed the design and operating effectiveness of centralised Compliance processes, systems and controls. Data analytics projects included analysis of Group systems and platforms accessible centrally by the Risk Assessment and Monitoring team, focusing on business transactions, parties and processes with an elevated compliance risk. The purpose of this monitoring was to identify activities that may violate Group requirements and
assess the effectiveness of, and adherence to, existing or new compliance processes and controls.
These projects involved the development and use of risk indicators aimed at monitoring compliance risks. Risk indicators were modelled through interactions with commodity departments and other relevant corporate functions. These indicators enabled the Risk Assessment and Monitoring team to identify and sample transactions flagged as high-risk from a compliance perspective.
These transactions were then subject to targeted review of underlying documentation, with testing results and observations
summarised in compliance monitoring reports and used to inform the discussion on opportunities for improvement.
The two complementary types of indicators used are key risk indicators (KRIs) and trigger alerts (TAs). KRIs highlight transactions that may present elevated compliance risk and help detect outliers, trends and emerging risks. Examples of KRIs include:
unusual commercial margins;
payments involving non-contractual
third parties;
transactions containing sensitive keywords; and
travel or entertainment expenses involving public officials.
TAs are more targeted indicators that
flag specific transactions that may require clarification or additional context. A TA does not imply wrongdoing, rather, it signals that a transaction may require further review.
Examples of TAs include:
cash on hand payments above
defined thresholds;
payments made before due diligence
is completed;
vendors or customers onboarded after invoices are issued; and
donations or sponsorships above country-specific limits.
In 2025, we initiated a redesign of our monitoring activities to better reflect the maturity of the Programme. This includes transitioning to a continuous compliance monitoring model to enhance early issue identification, improve real-time support and undertake a more comprehensive use of data.
Key features of the evolving model include:
a refocused monitoring team combining
compliance expertise, data analytics and
risk assessment capabilities;
a reallocation of traditional audit testing,
including the Corporate Compliance
thematic reviews from the Risk Assessment and Monitoring team to Group Internal Audit and Assurance (GIAA);
enhanced collaboration with regional
compliance, supporting a more timely
and informed follow-up; and
redesigned and streamlined processes enabling clearer task allocation.
In connection with the update of our model, we have also enhanced our use of risk indicators across the Group's financial
and trading systems and platforms.
The updated continuous monitoring
model will be piloted within selected
SAP environments. Under the new model the Risk Assessment and Monitoring team will continue to develop and maintain the trigger alerts and dashboards. The Regional Compliance teams will review the output applying their knowledge of the local businesses to prioritise areas of follow up focusing on unusual, high risk or unexpected transactions. Any outcome will be recorded centrally to support consistency, tracking and follow up actions.
When identified, follow-up areas include potential control gaps, additional controls may be designed and implemented to strengthen our Programme. The model
is designed to be scalable and will be progressively expanded across systems and business areas.
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Speaking openly and raising concerns
A critical element of an effective compliance programme is having a culture in which our people feel comfortable raising concerns, knowing they will be properly addressed or investigated, and that appropriate action will be taken.
We expect our employees and contractors to speak openly and require them to report any concerns regarding breaches of our Code, our policies, or the law, whether those relate to themselves or others. We also expect them to report any breaches of requirements in procedures. We encourage our employees and contractors to first raise
concerns with their managers or supervisors as they are usually best equipped to resolve concerns quickly and effectively.
However, we recognise that for some concerns they may not always feel comfortable speaking with a manager or supervisor. Therefore, we offer a number of formal channels for whistleblowers to raise concerns. Whistleblowers have the option of reaching out to whistleblowing contacts, who are nominated by Glencore offices and industrial assets. Whistleblowing contacts are regularly trained on the requirements of their role, and must affirmatively
confirm they understand their role and responsibilities.
Group Raising Concerns Programme channelsIf a concern remains unresolved or a whistleblower is uncomfortable using local channels, concerns can also be reported via the Group Raising Concerns Programme (RCP) channels, our corporate whistleblowing programme managed from our headquarters in Baar, Switzerland, by the Raising Concerns and Investigations (RCI) team.
These channels allow whistleblowers to raise concerns anonymously in a variety of languages, by internet, voicemail or phone
(for most of the countries where we operate). Contact details are available on the platform's website and on posters at our offices and industrial assets.
Raising Concerns and Whistleblowing FrameworkWe have a comprehensive suite of documents which establish a framework
for managing concerns raised, including our Raising Concerns and Whistleblowing Policy. This policy explains the process for reporting, escalating, investigating and remedying concerns, and makes clear that retaliation
is absolutely prohibited, regardless of whether the reported concern is ultimately substantiated.
All concerns are taken seriously and handled promptly, using an objective, fact-based rationale.
Protected Concerns Management and Investigation Standard and ProceduresOur Protected Concerns Management and Investigation Standard sets out the minimum requirements applicable to the classification, tracking and reporting of concerns received through local reporting channels or the Group RCP channels in
a manner consistent with our Raising Concerns and Whistleblowing Policy.
This intake process is critical and we have sought to ensure that we have a nuanced, sophisticated and consistent process, which is run by experienced professionals with senior oversight.
Classification takes into account factors
such as:
the seniority of those involved in the alleged breach;
the potential consequences of the
breach; and
whether the conduct is ongoing, systemic or deliberate.
In certain cases, a single factor may be sufficient to support the classification of a concern, but in other instances a combination of factors may be relevant.
The classification of the concern determines how it will be managed and investigated.
Concerns classified as low and medium are generally investigated by the relevant commodity department with oversight by the RCI team, whilst concerns classified as high are handled directly by the RCI team.
The minimum requirements of the Protected Concerns Management and Investigation Standard are implemented through procedures both at the corporate
In 2025, we continued to focus on speaking openly and raising concerns as a key element to support an open culture where employees feel comfortable raising concerns.
level, for the intake process of reports raised via the Group RCP channels and investigations by corporate teams, and at the local level, for the intake process of
reports raised via local reporting channels and investigations conducted locally. If a concern is received at the local level and classified as high, it is required to be reported to the corporate RCI team as soon as possible (ideally within 24 hours). Local concerns administrators who run the assessment process for locally raised concerns are trained by the RCI team.
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Speaking openly and raising concerns continued
Corporate oversight and pattern analysisThe RCI team, through a case management system, carefully tracks concerns raised through the Group RCP channels, or otherwise escalated to them, to confirm whether they have been investigated and closed out within the RCP case management system, including any related remediation. The RCI team also conducts sample-based review and assurance activities on concerns raised through local whistleblowing channels which are also tracked through a
centralised case management system.
We seek to analyse the data arising from the RCP in order to identify any potential trends and areas where specific focus will be
required. We look at the number, nature and severity of the concerns raised, as well as the department and geography. We carefully monitor the time taken to review and classify reports received, close investigations, as well as substantiation rates. We further periodically assess the robustness of our whistleblowing programme using external benchmarks and third party data.
We provide quarterly updates on the RCP to management through the ESG Committee and the RCIC. The Board also receives quarterly updates.
In 2025, we continued to invest in systems to support the RCP, such as upgrading our Group reporting platform, leading to a more seamless experience for reporters and improving the quality of information
we receive to ensure appropriate action can be taken. Furthermore, we have advanced our capabilities in terms of analysing data to help us identify trends and highlight potential risks by leveraging Power BI and making relevant dashboards available to key stakeholders. We have also increased Group oversight for concerns raised locally by implementing quarterly sample testing and increasing engagement with the departments and other local stakeholders.
Promoting a culture of speaking openlyWe continue to actively promote our various reporting channels, including the Group RCP channels. Our ongoing global focus on 'speaking openly' reinforces our commitment to an open culture where employees feel comfortable raising concerns - something that is integral to the successful implementation of our Code.
High-severity concerns
The following are illustrative examples of compliance-related
allegations or concerns that would typically be classified as high severity and investigated by, or under the oversight of, the RCI team.
We use a wide range of materials to promote awareness, including posters, videos and talking points for managers. All of these materials have been refreshed in 2025
and we have published a new Speaking Openly Hub on our intranet providing more guidance on what to raise where and more information on the investigation process and our commitment to non-retaliation. We also share data on the concerns received and anonymised case studies to illustrate how our RCP works in practice.
InvestigationsOur Protected Concerns Management and Investigation Standard seeks to ensure that investigations are performed consistently and effectively. It also sets out the importance of protecting the confidentiality of information relating to an investigation. The standard is implemented through procedures, both at the corporate level
for investigations conducted by corporate teams (including the RCI, Human Resources and GIAA teams) and the local level for investigations conducted locally. The standard includes a template investigation procedure for locally led investigations.
The standard permits modification of the template to account for local nuances, as long as these revisions remain consistent with the requirements of our Raising Concerns and Whistleblowing Policy.
The RCI team provides training to case owners and lead investigators on how to
conduct investigations into concerns in a manner that is consistent with our standard and procedures. It is essential that investigators are trained on the
requirements and investigation skills before embarking on any investigation, and that they follow the necessary steps during their investigations. Throughout 2025, the RCI team continued to run a combination of scheduled trainings, as well as ad-hoc trainings for newly appointed investigators.
Bribing a public official, whether through cash payments or other means, such as gifts or entertainment, contributions to political parties or charitable donations | Trades, orders or behaviour that may constitute insider trading, market abuse or market manipulation, including attempts, whether successful or not | Violating competition laws | Violating sanctions laws | Participating in money laundering |
Using inside information to deal in Glencore/other publicly traded securities | Participating in a billing or payroll scheme or skimming or stealing Glencore cash or property, particularly where the amount is significant, or the scheme involves senior employees | Manipulating company accounts so that assets or liabilities appear overstated or understated | Committing sexual assault, regardless of seniority | Engaging in unlawful discrimination, workplace harassment, or bullying by senior employees |
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Speaking openly and raising concerns continued
Raising Concerns Programme data Locally raised concerns dataIn 2025, the Raising Concerns Programme recorded
697
reports (excluding SPAM)
Type of report
Accounting, auditing and financial reporting Business integrity Human resources
4
176
330
HSEC&HR 93
Misuse or 22
misappropriation
of corporate assets Other 72
(2024: 735)
Raised anonymously
71%
Raised via
Web 575
Phone 80
Email/other1 42
1. Other includes direct contact with senior management, Legal or Compliance or locally raised concerns escalated to the Group
(2024: 73%)
Reports closed during 2025
798
with 311 reports that were assessed as falling within the scope of the RCP, i.e., constituting protected concerns, and closed following
an investigation as either substantiated, partially substantiated or not substantiated (2024: 353). These 311 reports related to 248 distinct protected concerns as the same protected concern may be raised in multiple reports. The remainder of the 487 reports were closed as outside the scope of the RCP, an issue for management action, a work-related grievance, or as not capable of investigation based on the available information.
45% of the 248 protected concerns were either substantiated or partially substantiated (2024: 48%). Of these reports, 48 related to business integrity concerns and were split across the following categories:
Type of report (business integrity) | ||
Conflict of interest 20 Business partner 8 misconduct: employment conditions | ||
Business partner 6 misconduct: integrity | ||
Receipt of kickbacks 4 Fraud 2 | ||
Other 8 | ||
77% of the 798 reports closed were received in 2025, with these reports taking an average of
28
days to close.
In 2025, 97% of protected concerns substantiated or partially substantiated resulted in at least one recommendation for remedial action. Examples of remedial actions include improvements to policies and procedures, safety measures, implementation or enhancements of controls, additional training, action with regard to contractors or disciplinary action in relation to employees (e.g., termination or warning). At least one disciplinary outcome was present in 44% of protected concerns investigated and closed as substantiated or partially substantiated.
Disciplinary action is not taken in all cases where concerns are substantiated as the concerns may not relate to employee misconduct or the relevant employee(s) may have already left the company.
For 2025,
183
reports raised through local whistleblowing
channels were assessed as protected concerns and recorded in our central database, and
274
such protected concerns were closed
following investigation.
Follow the link to our Raising Concerns
and Whistleblowing Policy.
Note: Reports closed during the year may include concerns raised in prior periods.
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Discipline and incentives
We expect all employees to
uphold our Values, adhere to
our Code of Conduct and comply with the requirements set out
in our policies and procedures, regardless of their role or location. Non-compliance with these expectations may lead to disciplinary action, including dismissal.
Measuring and incentivising the behaviour of our most senior leadersOur senior leaders play a critical role in shaping the cultural tone of the organisation, with their behaviour serving as a key driver of our compliance culture. The performance of the senior leaders in our corporate functions, marketing departments and industrial assets is assessed through a comprehensive annual review process.
The review specifically considers their behaviour, including their contribution to our commitment to acting responsibly
and with integrity, and is taken into account
in determining compensation outcomes.
Their compensation may be higher or lower based on an assessment of their behaviour, with strong leadership in support of our Programme being grounds for higher compensation.
The partnership between Human Resources and Compliance is a key feature of our Programme and we regularly collaborate
to produce policies, procedures and other materials for the business. For example, the Mandatory Compliance Training Escalation and Discipline Procedure is a joint procedure, created and managed by both departments. This procedure sets out a mandatory compliance training roll-out, reminder, escalation and disciplinary process designed to ensure employees are abiding by their training requirements.
Creating clarity and consistency of disciplinary outcomes across the organisationDisciplinary expectations are governed through our Group standards and outline our approach to managing conduct across the organisation. While we seek to establish a consistent global approach to discipline, these standards reinforce departmental ownership and accountability while supporting alignment with local
legislative requirements.
We continue to clarify expectations across the organisation and take appropriate action where concerns are substantiated. Our approach is intended to ensure issues are resolved at the appropriate level while serious matters, including sexual harassment, serious misconduct or business integrity breaches, are escalated to senior management. This approach underpins
our strong focus on compliance and
associated behaviours.
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32
33
35
36
37
39
39
40
41
Introduction
Anti-corruption and bribery Conflicts of interest
Fraud
Sanctions and trade controls Anti-money laundering Competition law
Market conduct
Data protection
Key risks
Key risks
2025 Glencore Ethics and Compliance Report 31
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Key risks
Introduction
Our Programme addresses the following key topics:
Anti-corruption and bribery
Glencore is exposed to a wide range of compliance risks across its operations, including in relation to corruption and bribery, conflicts of interest, fraud, sanctions and trade controls, money laundering, competition law, market conduct and
Conflicts of interest
Fraud
data protection. To address these risks, the Programme includes a set of policies, standards, procedures and guidelines,
as well as internal Compliance manuals.
Several other policies, standards and procedures which support our Programme are issued by corporate functions other than Group Compliance.
Our policies are publicly available on our website: https://www.glencore.com/ who-we-are/policies.
Sanctions and trade controls
Anti-money laundering
Competition law
Market conduct
Data protection
IntroductionGovernance and structure
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Our Anti-Corruption and Bribery Policy is clear: the offering, providing, authorising, requesting or accepting of bribes is unacceptable, and
we do not engage in corruption or bribery, including making facilitation payments. We assess corruption risk within our businesses and work to address these risks through policies, standards, procedures and guidelines on various topics.
Political contributions
Anti-corruption and bribery
We do not contribute any of our funds or resources to any political campaign, political party, political candidate or any politically affiliated organisation.
Political engagement
Although we do not directly participate in party politics, we do engage in policy debate on subjects of legitimate concern to our business, employees, customers, end users and the communities in which we operate. All officers, employees and persons who lobby on our behalf must comply with all relevant Glencore policy and procedural requirements and all applicable legislation (including, but not limited to, the laws and regulations relating to registration and reporting).
Political Engagement Policy
This policy, issued by Group Corporate Affairs, sets out our approach and general requirements in connection with our engagement in the political process, and our commitment to operate transparently and in line with our Values and our Code.
Political Engagement Procedure
This procedure, issued by Group Corporate Affairs, sets out the specific steps we take
to ensure we comply with the requirements
in our Political Engagement Policy.
Sponsorships and charitable contributions
We never make a sponsorship or charitable contribution in order to disguise a bribe, or to gain an improper business advantage.
We take measures to ensure that when we make sponsorships or charitable contributions we conduct risk-based due diligence and, when required, monitor the
use of our funds or resources to ensure that
is appropriate.
Community investments
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We apply a risk-based approach to performing compliance due diligence on community investments. In 2025, we transitioned the coverage of community investments from the Third Party Due Diligence and Management Procedure
into a dedicated standalone procedure to better align with the complexity of such investments and to cater for varying risk profiles. The new procedure sets out proportionate compliance due diligence and management requirements for community investments that enable us to identify and effectively mitigate the specific risks identified with individual community investments.
Travel, gifts and entertainment
We only provide and accept occasional, reasonable, appropriate and lawful travel, gifts and entertainment that satisfy the general principles of our Anti-Corruption and Bribery Policy and are not given
or received with the intent or prospect of influencing the recipient's decision-making or other conduct.
We have requirements for the pre-approval
of travel, gifts and entertainment based on localised thresholds, and additional requirements regarding public officials.
Specifically, when providing travel, gifts and entertainment to public officials, employees are not permitted to exceed locally-defined thresholds and employees must obtain
pre-approval for anything in excess of such thresholds from the relevant line manager or supervisor and Compliance.
Travel, Gifts and Entertainment Standard
In 2025, we updated our Travel, Gifts and Entertainment Standard to clarify requirements and streamline certain
processes. Our Travel, Gifts and Entertainment
Standard requires offices and industrial assets to establish a local travel, gifts and entertainment procedure. The purpose of the standard is to:
set out the requirements for providing and
accepting travel, gifts and entertainment
to include in the local procedures; and
provide guidance on the application and interpretation of these requirements.
We use an AI-driven expense audit tool which is integrated with our expense management system to analyse expense report data and flag high-risk events for review and approval. For example, the tool analyses attendees listed as receiving travel, gifts or entertainment against publicly available sources and watchlists, as well
as internal data, to determine whether an attendee is a public official. Any positive matches require compliance review and approval, to ensure the spend is within the applicable threshold.
We monitor the frequency of travel, gifts and entertainment given to public officials
through a purpose-built Power BI dashboard, which retrieves data directly from our expense management system. The dashboard is dynamic, allowing Compliance to generate insights into employee expense activity over selected time periods. It also enables tracking of how frequently specific public officials are entertained, regardless of which employee is providing the entertainment. In addition, the dashboard flags inconsistencies where an individual is classified as a public official in one expense report but not in another.
IntroductionGovernance and structure
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Additional information
Key risks
Anti-corruption and bribery continued
Interactions with public officials
Dealings with public officials bring a higher risk of bribery and corruption, particularly in high-risk jurisdictions, so we are especially careful in our interactions with them.
Employees must report requests for inappropriate or illegal payments, favours, or unusual or suspicious requests by a public official to Compliance immediately.
Payments and In-Kind Assistance to Public Officials, Government Institutions and State-Owned Entities Guideline
In certain jurisdictions in which we
operate, we are requested by public officials, government institutions or state-owned entities, to make payments and provide
in-kind assistance, in particular with respect to ongoing arrangements. For example, in certain countries we are required to make payments to public security forces who are dedicated to securing our operations. This guideline helps us navigate our response
to these types of requests and sets out the steps that Compliance employees should follow to ensure that we manage the corruption risks associated with these payments and assistance.
External engagements Anti-corruption organisations We are a member of the Partnering
Against Corruption Initiative (PACI) whose members collaborate on collective action and share leading practice in organisational compliance. PACI has a commitment
of zero tolerance to bribery and requires its members to implement practical and effective anti-corruption programmes.
Local communities
We recognise that as a large multinational company we have a significant influence in the regions where we operate, both through the employees and contractors that we employ, and through our substantial procurement spend and support for
local communities. We therefore believe it is important that we support local anti-corruption and bribery efforts, by clearly communicating our commitment to responsible and ethical business practices and articulating the standards that we expect from our suppliers.
Transparency
We recognise the importance of having high standards of corporate governance and transparency and we seek to maintain
long-term, open, transparent and constructive relationships and dialogue with our
key stakeholders.
Follow the link to our Anti-Corruption
and Bribery Policy.
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Conflicts of interest
Our Conflict of Interest Policy requires that we always act in Glencore's best interests and that we try to avoid actual, potential or perceived conflicts of interest. We take steps to manage conflicts and reduce the risk they present.
Conflict of Interest Management Procedure
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Our Conflict of Interest Management Procedure sets out the required steps to ensure that conflicts of interest are recorded and appropriately managed in a timely manner.
Compliance reviews the declaration to confirm whether a conflict exists and, if so, its type. If needed, Compliance requests additional information and
assigns the declaration to the declarer's
supervisor or manager.
Together with Compliance, the supervisor or manager develops a management action plan (MAP) to manage and mitigate the
conflict. Compliance approves the MAP if it is sufficiently robust, or recommends changes where necessary. Once approved, the declarer and their supervisor or line manager are responsible for adhering to the MAP.
Employee onboarding
Human resources requires all candidates, at the outset of the recruitment process, to declare any actual or potential conflicts.
Declarations are flagged to Compliance for review and further instructions. Additionally, the recruitment or secondment of current or former public officials is subject to Compliance's prior review and approval.
Conflict of interest declarations by type in 2025
800
Working with a relative or close personal relation 479
200
Relationship with political, judicial,
administrative or government function Personal or business relationship Outside employment
Outside activity
Gifts, items of value or entertainment Current or proposed legal proceedings Controlling interest,
ownership, shareholding and/or directorship
Any other private interest
61
600
400
784
117
116
15
3
53
62
0
In 2025 we had
1,690
(2024: 2,392)
new conflict of interest declarations,
of which 150 were classified as not posing
an actual, potential or perceived conflict.
For the remaining
1,540
Conflict of interest declarations by region in 2025
Asia 10
Australia 627
Europe and FSU 86
South America 432
North America 119
Africa 416
(2024: 2,216)
appropriate MAPs were created or were in the process of being reviewed and signed off.
Follow the link to our Conflict
of Interest Policy.
IntroductionGovernance and structure
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Fraud
Our Fraud Policy sets out our approach to prohibiting and preventing fraud, informs employees of the types of activities that are considered fraudulent, and sets out employees' obligations to prevent and report fraud.
We are committed to not engaging in fraudulent behaviour or knowingly assisting or facilitating any third party to commit fraud.
Due to the broad nature of the activities that
can constitute fraud, the risk is managed by various corporate functions across the Group, including Legal and Finance, which implement relevant controls in their areas in order to mitigate the risk of fraud.
During 2025, we validated that our fraud risk management framework included reasonable procedures to prevent fraud in compliance with the Economic Crime and Corporate Transparency Act 2023.
Risk of fraud in fronting and sleeving arrangements
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'Fronting and sleeving' refers to arrangements whereby a party is inserted as an intermediate trading counterparty in a trading chain or structure. This could involve inserting a third party into a transaction in which Glencore is the ultimate supplier
or customer. Alternatively, it could be an arrangement where Glencore acts in such a capacity, sitting between two trading counterparties.
As per our Fraud Policy and Fronting
and Sleeving Guideline, we have a general prohibition against dishonest and deceptive fronting or sleeving arrangements that are designed, intended to conceal, or have
the effect of concealing Glencore's (or any other party's) involvement in a transaction or trading structure, even if such arrangement is legal, as it is contrary
to our Code and Fraud Policy.
Our Fronting and Sleeving Guideline is particularly relevant to Glencore personnel in our offices who are engaged in market facing activities. It highlights the compliance risks associated with these types of arrangements and provides guidance
on how to assess potential fronting or sleeving transactions and when employees must seek Compliance approval to ensure compliance with our Code and Fraud Policy.
Follow the link to our Fraud Policy.
IntroductionGovernance and structure
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Sanctions and trade controls
Our Sanctions Policy sets out our commitment to complying with all applicable sanctions and restrictive measures and we
generally adhere to United States, European Union, United Nations and Swiss sanctions throughout our business, whether or not we are legally required to do so.
We do not participate in transactions designed or intended to evade or facilitate
a breach of applicable sanctions or restrictive measures, and we do not:
conduct business in, or involving any,
embargoed territory or sanctions targets;
conduct business that would violate
any applicable anti-boycott laws, export
controls, trade embargoes or any other
sanctions or restrictive measures;
conduct business with sectorally
sanctioned entities, which is prohibited
by or inconsistent with sanctions; or
engage in any sanctionable activity that could result in the designation of Glencore
as a sanctions target.
We only allow deviations from these requirements in exceptional circumstances with prior approval from Compliance and Group management and, under all circumstances, these deviations must
Key risks
be compliant with applicable laws.
To manage our sanctions risk exposure in our day-to-day activities and help ensure compliance, we implement a variety of controls and processes. Our sanctions
risk mitigation framework covers a variety of topics and outlines the key steps and controls required to manage sanctions risks in our day-to-day activities.
Sanctions risk requirements are built into the lifecycle of our business interactions. The extent of our controls is designed to be proportionate to the level of risk incurred in connection with different types of transactions and counterparties.
We conduct screening before onboarding and during the continued relationship with a counterparty. Screening is performed on a continuous basis rather than being treated as a one-time requirement, so that we can respond quickly if a counterparty's status or risk profile changes. We assess transactions up front, and conduct appropriate due diligence on our counterparties and vessels, using a risk-based approach, to determine whether they are a sanctions target, subject to sectoral sanctions, or otherwise attract sanctions risk, and continue to review
them as the business activity progresses.
We also regularly monitor updates from relevant sanctions authorities and use internal escalation requirements to ensure sanctions risks are handled in a timely manner. In parallel, we promptly review any ongoing transactions and relationships recorded in our internal reference data or
watchlists that may be impacted by relevant
Governance Introduction and structure
Our Programme
Our business Additional partners information
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Sanctions and trade controls continued
sanctions updates. Operational controls are embedded in our trading systems and workflows so that higher-risk activities, whether relating to certain counterparties,
sensitive locations or restricted products, are automatically flagged or blocked and, where appropriate, routed for additional review.
Additionally, higher scrutiny is conducted on transactions entailing a heightened sanctions risk, and payments are screened against internal and external watchlists and
Sanctions continuous monitoring controls and processes
Transactional due diligence performed on transactions with inherently higher sanctions risks (e.g., Russia, Persian Gulf)
Counterparty due diligence is conducted in line with the party's risk profile and screening outcome
checked by Compliance before approval
to mitigate the likelihood of unnecessary blocks at the processing level. Overall, these measures combine preventative controls with detective controls, supporting us to identify and halt prohibited activity before it takes place.
We continually assess ways to improve and
Daily monitoring of
Transaction due diligence
Sanctions update monitoring and list
Counterparty onboarding process
Vessels process
All vessels, whether chartered
streamline these processes. For example, in 2025 we automated our vessel-related compliance processes by implementing a business-accessible list of approved vessels
across the Group. If a vessel is not on the list,
approval can be requested via a ticketing
regulatory sanctions updates
•
(including EU, OFAC, SECO, UK, UN)
•
Sanctions horizon scanning Initiating Response Plans,
including maintaining internal watchlists
maintenance
System controls
and key processes
or nominated, undergo
screening during onboarding and are tracked throughout their trade lifecycle
system that automatically screens the vessel and escalates to Compliance and/or Responsible Sourcing if any red flags are identified. Where no red flags are identified, the vessel is automatically approved.
Following approval, the vessel is subject to ongoing screening, a profile is created in our master database to enable use in trading systems, and the vessel is added to the approved list. Rejected vessels are automatically removed from ongoing screening, the master database and
the approved list.
Follow the link to our Sanctions Policy.
Preventive control on outbound
•
•
payments
•
Direct integration of official sources (e.g., Swiss, EU, UK, US sanctions lists)
Employee expense
system controls
Payment screening Ongoing screening
Trading system control (counterparty & location)
•
Implementation of system blocks or transaction monitoring
•
in trading systems requiring compliance approval
Monitoring the use of locations (e.g., for delivery, discharge or loading of goods) that are considered higher risk from a sanctions perspective
Overnight screening using application programming interfaces (APIs) from different lists and tools
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Our Anti-Money Laundering Policy sets out our approach to ensuring that we comply with all applicable laws and regulations to prevent money laundering and the facilitation
of tax evasion, and appropriately
manage the related risks.
Particularly:
we are aware of the risk of third
parties exploiting us to engage in
money laundering;
we do not knowingly assist, support,
participate in or permit money laundering
or terrorist financing;
we do not accept money or other assets if we know or suspect that they derive from
any kind of criminal activity;
we do not knowingly deal with criminals,
suspected criminals or the proceeds of crime;
we do not facilitate the acquisition,
ownership or control of criminal
proceeds or other assets deriving from criminal activity, nor do we assist others in concealing criminal proceeds or assets; and
we do not tolerate tax evasion of any
kind and we do not knowingly or wilfully
facilitate tax evasion.
Furthermore, our Tax Policy sets out our approach to taxation and to the
management and control of our tax affairs. It also sets out the general framework within which Glencore operates when considering tax-related issues.
To manage our money laundering risk exposure and ensure compliance, we implement a number of controls and processes including, but not restricted to, payments to and from third parties.
Third party payment procedures - marketing and industrial assets
In 2025, we reviewed and updated our Third Party Payment Procedure - Marketing and converted the Third Party Payment Standard - Industrial Assets into a procedure. These two procedures are tailored to the risk profiles of the respective business segments and set out the steps on how to:
perform due diligence on non-contractual parties who want to make or receive
payments instead of our contractual counterparty;
identify red flags in third party payment
structures; and
document acceptable payments to
non-contractual counterparties, and under
the marketing procedure, acceptable
payments from non-contractual parties.
Our Competition Law Policy sets out our approach to competing vigorously, but fairly and legally.
We do not engage in collusion and we don't agree with our competitors, formally or informally, to:
fix prices;
limit production or supply;
allocate customers or markets;
rig bids; and
collectively boycott customers or suppliers.
To help employees apply our Competition Law Policy in practice, we also provide guidelines to address common competition law risks and outline practical guidance:
Dealing with Competitors Guideline:
this guideline provides detailed
guidance on the key competition law risks employees need to be aware of when dealing with our competitors;
Key risks
Competition law
Anti-money laundering
Dealing with Suppliers, Customers and
Agents Guideline: this guideline provides
detailed guidance on the key competition law risks we need to be aware of when dealing with suppliers, customers
and agents;
Dealing with Competition Law in Merger and Acquisition Transactions Guideline:
this guideline provides detailed guidance on the key competition law risks we need to be aware of when involved in merger and acquisition (M&A) transactions; and
Human Resources and Employment
Considerations Guideline: this guideline
provides detailed guidance on key competition law risks in the human resources environment, in particular with respect to agreements between companies that compete for talent.
Risks related to competition law are overseen by the Group Legal team, with support from Compliance.
Follow the link to our Anti-Money
Laundering Policy.
Follow the link to our
Competition Law Policy.
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Our market conduct compliance framework is centred on our Market Conduct Policy, which articulates our expectations of our employees with respect to market conduct issues.
Follow the link to our
Market Conduct Policy.
Glencore operates in different jurisdictions and trades on both regulated markets and over the counter, in both commodity derivatives and physical commodities.
Market conduct
We are committed to complying with all applicable laws, regulations and rules
related to Glencore's activities and behaviour in the physical and commodity derivative or related financial markets.
Trading in specific markets, regardless of where we are located, means we are
subject to the rules of that market and the regulatory authorities who oversee it. We adhere to global market conduct regulations such as the Market Abuse Regulation, the Markets in Financial Instruments Directive 2014 (MIFID II), the Commodity Exchange Act, and the Financial Market
Infrastructure Act.
In addition, different trading venues (such as the London Metal Exchange,
Chicago Mercantile Exchange, ICE Futures Europe and US) have their own rules with which we must also comply (e.g., position limits and prohibitions on wash trades).
In addition to our Market Conduct Policy, we have multiple procedures which are particularly relevant to employees in our offices who are engaged in market-facing activities. These procedures include:
our Personal Account Dealing Procedure,
which sets out the requirements
applicable to personal trading in
physical commodities or derivatives;
our Benchmark Trading Rationale
Procedure, which sets out the rules
relating to documenting the rationale related to trading decisions when active in benchmark windows;
position limit procedures for specific oil derivatives and related contracts that
Key risks
establish a framework to ensure we consistently adhere to the rules and regulations set forth by trading venues and relevant authorities, including exchange-imposed position limits; and
benchmark and price reporting
desk procedures, which set out the
list of trained individuals approved to communicate with price reporting agencies and define the restrictions on such communications.
We additionally have three main underlying guidelines, which are also particularly relevant to employees in our offices who are engaged in market-facing activities:
our Market Manipulation Guideline, which provides guidance and examples
regarding different types of market manipulation as outlined in the Market Conduct Policy;
our Inside Information Guideline,
which provides detailed guidance on how
to comply with prohibitions on engaging in insider dealing in commodities; and
our Benchmarks and Price Reporting
Agencies Guideline, which sets out the
steps we take regarding our interactions with price reporting agencies in order to manage the risk of benchmark manipulation.
Market Conduct Surveillance Programme
Our Market Conduct Surveillance Programme aims to detect potential areas of market abuse and includes both trade and e-communications surveillance which leverage advanced data analytics and AI to monitor marketing activity in near real time. In 2025, we continued to significantly invest in and develop our Market Conduct Surveillance Programme. Significant progress was made in addressing identified areas of improvement in trade surveillance and we expanded coverage to include additional exchanges related to Glencore's natural gas and power businesses. The communications surveillance programme was also enhanced and expanded, now covering 15 languages across all of Glencore's principal marketing offices globally. Further enhancements were made to our governance framework, calibration approach, surveillance metrics and quality assurance processes. We also focused on building a data governance framework to improve the completeness and accuracy
of Glencore's surveillance programme.
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Glencore plc published this content on May 07, 2026, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on May 07, 2026 at 06:30 UTC.
