2015 Annual and CSR Report
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Our Company Business
Conduct

GRI Indicators

Operating openly, fairly and with integrity is the proper way to run our business and the right way to treat our stakeholders.

Hudbay employees and contractors are expected to uphold high standards of honesty and integrity. Our Code of Business Conduct and Ethics (the “Code”) 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, and the reporting of illegal and unethical behaviour. We recognize that bribery and corruption pose risks wherever we operate, and we want to be very clear about our standards and expectations.

On joining the Company, all board members and employees must sign a declaration confirming that they understand and will comply with 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 with the Code is also required from all employees above the manager level and those dealing with money or government officials.

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.

Hudbay’s Legal department is responsible for providing 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), to specific groups or across the organization as it deems appropriate. The focus on anti-bribery and anti-corruption was expanded in 2015 to include an online training component.

We encourage employees who become aware of a real or potential conflict or departure from the Code to bring it to the attention of a supervisor or department head. The Board has adopted a Whistleblower Policy for employees to report concerns regarding, among other things, violations of the Code or anti-bribery legislation or concerns related to financial statement disclosure issues, accounting, internal accounting controls or auditing matters. Hudbay has a third-party managed ethics hotline that allows individuals to report any concerns about inappropriate business conduct confidentially and anonymously by phone, website (http://www.clearviewconnects.com) or mail.

2015 PERFORMANCE HIGHLIGHTS

  • We strengthened our anti-corruption policies and procedures in multiple ways including:
    • Developing a Statement on Anti-Corruption, which is posted to our website;
    • Making a “How to Say No” video training series on bribery and corruption available to all employees through our corporate intranet;
    • Ensuring that select employees complete an online training program on anti-bribery and anti-corruption;
    • Revising all contract templates to prohibit bribery and corrupt activities;
    • Modifying the vendor onboarding process to ensure that employees consider a series of questions related to anti-bribery and anti-corruption and, in certain cases, obtain due diligence reports before engaging vendors; and
    • Broadening the scope of employees across the organization who receive anti-bribery and anti-corruption training.
  • Ethics and anti-corruption training:
    • 10 board members (100%) received ethics and anti-corruption training.
    • 360 employees were trained in anti-corruption policies, representing 21% of the workforce and 91% of those who were required to receive training because of their role.
  • The majority of complaints received through our third-party whistleblower reporting service involve operational matters and employee relations. Thirty-four incidents were reported in 2015, all of which were investigated and resolved with corrective action where necessary. While none of these incidents involved significant allegations of fraud or violations of our Code of Business Conduct and Ethics, there were issues related to business, health, safety and environmental practices; inappropriate behaviour or violation of a Company policy or procedure; and conflicts of interest.

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 by mail or email at chairman@hudbay.com.
  • 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 conflicts 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 +1 343 203-6735.
  • Canada’s National Contact Point (NCP) for the Organisation for Economic Co-operation and Development (OECD) provides a forum where multinational enterprises, Canadian businesses, 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 +1 343 203-2341.
  • The majority of complaints received through our third-party whistleblower reporting service involve operational matters and employee relations. Thirty-four incidents were reported in 2015, all of which were investigated and resolved with corrective action where necessary. While none of these incidents involved significant allegations of fraud or violations of our Code of Business Conduct and Ethics, there were issues related to business, health, safety and environmental practices; inappropriate behaviour or violation of a Company policy or procedure; and conflicts of interest.

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

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