2014 Annual and CSR Report Switch to Spanish Language
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Business Conduct

Hudbay employees and contractors are expected to conduct themselves and do business to the highest standard of honesty and integrity. Our Code of Business Conduct and Ethics and related policies set out principles for directors, officers and employees on matters like compliance with law, conflicts of interest, confidential information, protection and proper use of Hudbay assets, fair dealing, rules and regulations and the reporting of illegal and unethical behaviour.

On joining Hudbay, all board members and employees must sign a declaration confirming that they understand and will observe the Code. The Board requires every director and executive officer to disclose any direct or indirect conflict of interest, and to confirm compliance with the Code annually. Formal, annual confirmation of compliance is also required from all employees above the manager level and those whose duties include the transfer of funds. The compliance process was expanded in 2015 to include an online training component.

Employees and contractors working at Constancia are also expected to abide by a Code of Conduct and Social Protocol based on the corporate Code and local community commitments. A plain language booklet and a video inform all workers at the site about the obligations under the Constancia Code.

Because fraud and corruption are potential risks in our industry, we conduct compliance training on the Code of Business Conduct and Ethics and related policies, and on the Canadian Corruption of Foreign Public Officials Act (CFPOA) and the US Foreign Corrupt Practices Act (FCPA). Hudbay’s Legal department is responsible for providing training to specific groups or more broadly across the organization as it deems appropriate. Failure to sign annual confirmations or take the required training is taken into account in performance appraisals and pay decisions.

We insist that personnel bring to the attention of their supervisor or department head any knowledge of a potential conflict with, or departure from, the Code of Business Conduct and Ethics. A multilingual toll-free hotline is in place to allow for anonymous reporting of suspected violations.

2014 Performance

  • 57% of our employees received anti-corruption training in 2014, either in the form of a quiz, classroom training or a formal review and sign-off. Included in this 57% are 100% of new hires and those required to have training by our internal policy.  Additionally, 100% of our Board has received anti-corruption training at some point, and 80% received an update to that training in 2014.
  • The majority of complaints received through our third-party whistleblower reporting service involve operational matters and employee relations. None of these incidents involved significant allegations of fraud or violations of our Code of Business Conduct and Ethics. Three incidents were reported in 2014, all of which were investigated and resolved with corrective action where necessary.
  • An employee in Peru violated Hudbay’s Code of Business Conduct and Ethics, and Timely Disclosure, Confidentiality and Insider Trading Policy, and was dismissed.

To report an issue

There are a number of avenues available to people who wish to make inquiries on ethical and lawful behaviour, and on matters related to organizational integrity, as well as to register a concern about Hudbay’s activities:

  • Contact our Board of Directors through our website.
  • To make a confidential report to the Chair of Hudbay’s Audit Committee about a perceived violation of the Company’s internal and accounting controls, auditing matters or violations of the Company’s Code of Business Conduct and Ethics, call 1 877 457-7318 or visit www.clearviewconnects.com. Reports are handled under our Whistleblower Policy and the Chair of the Audit Committee is responsible for ensuring that they are appropriately investigated.
  • The Office of the Extractive Sector Corporate Social Responsibility (CSR) Counsellor is a resource available for constructively resolving conflict between project-affected communities and Canadian extractive sector companies outside of Canada. The CSR Counsellor can be reached by email at csr-counsellor@international.gc.ca or by telephone at 416 973-2064.
  • Canada’s National Contact Point (NCP) for the Organisation for Economic Co-operation and Development (OECD) provides a forum where multinational enterprises, Canadian business, non-governmental organizations and labour organizations can voice their views and concerns. Canada’s NCP can be reached by email at ncp.pcn@international.gc.ca or by telephone at 343 203-2341.

We also have grievance processes set up at our projects and operating sites to address community concerns. See Community Relations for details.