Business Conduct
Honesty, integrity, transparency and compliance with the law are essential for building trust and supporting our ability to grow.
Our Code of Business Conduct and Ethics (the “Code”) states our commitment on matters related to compliance with laws and regulations, conflicts of interest, government payments, confidential information, protection and proper use of Hudbay assets, and the reporting of illegal and unethical behaviour. The Code applies to all directors, officers and employees.
On joining the Company, board members and employees 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. Formal annual confirmation of compliance with the Code, the Confidentiality and Insider Trading Policy and our Statement on Anti-Corruption is also required from all directors, officers, and employees with a Hudbay email address.
Personnel who report concerns about unethical or illegal behaviour are protected by our Whistleblower Policy, which expressly prohibits discrimination, harassment and retaliation against anyone reporting conduct they believe is in violation of our Code or any laws.
Our Code includes a prohibition against making any political contributions on Hudbay’s behalf without prior written approval of our Chief Executive Officer.
Our Supplier Code of Conduct and Ethics, which we implemented in 2017, sets out minimum standards of conduct expected of suppliers who wish to do business with Hudbay. Suppliers with a major contract will be asked to read, accept and comply with the Supplier Code of Conduct as a condition to doing business with Hudbay.
Compliance Training
Our Legal department is responsible for providing compliance training on the Code 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 the Company deems appropriate.
On an annual basis, all Board directors, officers and employees with a Hudbay email address must certify that they have read and understood our Code. For 2017, we conducted an online campaign that asked individuals to certify by e-signature their adherence to key compliance policies, and to complete a training program in respect of such policies. 100% of individuals required to certify and participate in training (representing 55% of our workforce) completed the requirement. For individuals who failed to comply, the Company suspended their email access until they completed the courses.
Other courses in 2017 included anti-bribery and anti-corruption refresher training for the Board.
Risks, Issues or Complaints
Based on an assessment of corruption risks at our three business units and our corporate office, we identified that violation of the CFPOA and the FCPA constitutes a significant risk in Peru, due to difficulties in monitoring the compliance of contractors and agents (and potentially employees as the Company grows), as well as the increased enforcement of anti-corruption legislation.
No incidents of corruption were reported in 2017, and no incidents of corruption involving employees, business partners or legal cases were brought against the Company. Through our third-party whistleblower reporting service, 17 incidents were reported in 2017, 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, some allegations were brought forward related to business, health, safety and environmental practices; inappropriate behaviour or violation of company policies or procedures; and conflicts of interest.