In 2016, Sherritt continued training Sherritt employees on the updated Anti-Corruption Policy and, by the end of the year, 100% of our entire eligible workforce received anti-corruption training, and 65% of Ambatovy employees received refresher training.
Based on feedback from the 2012 training, which consisted of group presentations followed by a question-and-answer session, Sherritt used a more nuanced platform that took into account the different cultural and situational pressures facing its workforce. An interactive training module that summarizes the key points of Sherritt’s policy, together with questions regarding how to correctly respond to situations where the potential for corruption or fraud exists, was completed by all of Sherritt’s employees based in North America, as well as expatriate employees located elsewhere.
It was agreed, however, that the language and examples used in the general anti-corruption training might not be accessible for employees and contractors unfamiliar with a North American or European work environment. To address this issue at our operation in Madagascar, Ambatovy’s Head of Learning and Development prepared a Malagasy-language interactive web-based training tool, featuring video vignettes of culturally relevant situations. The Ambatovy training required employees to watch each vignette and guide a fictional employee to respond correctly to circumstances where the potential for corruption or fraud existed. The vignettes included such situations as an employee being pressured by a friend to secure a job, and a vendor offering a gift to an employee if that person “overlooked” the fact that the vendor had not passed a safety audit. The vignettes were developed to resemble a well-liked style of Malagasy theatre and used well-known Malagasy actors.
Expatriates at Ambatovy were also required to complete this additional training, so that both national and expatriate workers would have a common starting point for further conversations about corruption and how employees should respond to difficult situations. Employees and contractors who took part in the training had positive feedback and tended to respond correctly to the content-based questions. After incorporating feedback obtained during the training, a revised policy was drafted in 2016 and finalized in early 2017.
