Performance

2019 and recent highlights:

• Updated our Human Rights Policy and Environment, Health, Safety and Sustainability Policy to ensure that the commitments are aligned with OECD requirements and industry best practice;
• Completed a Conflict-Affected and High-Risk Areas (CAHRA) assessment of the Moa Joint Venture feed supplies, which concluded that the Moa Joint Venture does not source from, operate in or transit through any conflict-affected or high-risk areas;
• Developed and implemented a Third-Party Feed Policy to establish Moa Joint Venture commitments to responsible feed sourcing that are aligned with OECD requirements and industry best practice;
• Started to develop a Supplier Code of Conduct to identify expectations of Moa Joint Venture suppliers to provide responsibly sourced minerals that are aligned with OECD requirements and industry good practice;
• Became an upstream member of the Responsible Business Alliance/Responsible Minerals Initiative.

As part of several long-term supply agreements with some key cobalt customers, the Moa Joint Venture participates in regular due diligence assessments against customer responsible sourcing requirements.

For more information on our responsible sourcing alignment with international standards, plans and performance, please see our Responsible Production and Supply Report.

Human Rights

Management Approach

Understanding and expectations related to human rights in the mining and energy sectors began to evolve rapidly 15 to 20 years ago. The United Nations Guiding Principles on Business and Human Rights outlines the roles for state and business actors in the protection of human rights. It also identifies “access to remedy” for anyone with a human rights complaint as a critical element for business to maintain its social licence.

Although human rights issues do not currently represent a top risk at Sherritt, they are an inherent risk to all mining and energy production sites. To manage this risk, we are aligning with international best practices and expectations regarding human rights. We developed an enterprise-wide policy that commits to uphold the Universal Declaration of Human Rights, along with other international principles.

At Sherritt, remedies for complaints, up to and including potential human rights violations, are provided through the community grievance mechanisms in place at the site level. Grievance mechanisms are processes to receive, acknowledge, investigate and respond to community complaints. These are valuable early-warning systems that can resolve sources of friction between stakeholders and companies, and can, over time, build trust. We have incorporated best-practice guidance from a number of sources into our Grievance Mechanism Standard to ensure it is both practical and credible.

At the Fort Site, we have a long-established informal process for responding to complaints from external parties and are in the process of finalizing the implementation of Sherritt’s Grievance Mechanism Standard. In Cuba, there is a state-run system where citizens can file complaints against an entity, organization or enterprise whose activities they feel are adversely affecting their well-being. Commissions are established to investigate grievances and develop action plans to address them. Sherritt’s management team, or that of our Cuban partners, participates in the process to address any grievances related to our operations.

Our Human Rights Policy also articulates our commitment to the Convention on the Rights of the Child. Violation of children’s rights is a low risk in Canada and Cuba; however, it is an issue Sherritt takes extremely seriously and a risk that is carefully managed no matter the operating location.

Performance

Third-party Review

In 2018, the Fort Saskatchewan refinery underwent an external audit on its application of the Voluntary Principles on Security and Human Rights as well as UNICEF’s Child Rights and Security Checklist. Refer to this case study for more information on the Voluntary Principles. No third-party human rights audits took place at Sherritt’s operations in 2019. The next third-party audit is scheduled for 2020 at the Fort Saskatchewan Refinery.

Human Rights Grievances

There were no human rights–related grievances reported by external stakeholders at any of our operating sites in 2019. Note that employee and labour grievances are captured under Employee Relations and Stakeholder Engagement.

Business Conduct

Management Approach

Our Purpose and Our Promises describe our guiding principles and how we expect them to be lived every day as we carry out our business. Our Business Ethics Policy provides clear guidance to our workforce on what it means to act with integrity. It covers conflicts of interest, fraud and corruption, fair dealings, protection and proper use of the company’s assets, compliance with regulatory requirements, disclosure, confidentiality, and reporting mechanisms available to employees and contractors.

As a Canadian company, we are subject to the Canadian Corruption of Foreign Public Officials Act (CFPOA), as well as anti-corruption laws in Cuba. The CFPOA prohibits Canadian business interests from making or offering improper payment of any kind to a foreign public official – or anyone acting on his or her behalf – where the ultimate purpose is to obtain or retain a business advantage.

Our Anti-Corruption Policy prohibits violation of the CFPOA and other applicable anti-corruption laws. All divisions, groups and offices must undergo anti-corruption training and log all government meetings and payments. In Canada and Cuba, governmental and commercial corruption does not present a significant risk, based on the latest Corruption Perceptions Index (CPI).

We have also developed a process for meeting the public reporting obligations of Canada’s Extractive Sector Transparency Measures Act (ESTMA). Sherritt’s 2019 ESTMA – Annual Report is now available online. The report, which is a requirement of the Government of Canada, covers certain payments that Sherritt made to all levels of government in Canada and abroad in 2019. As Canada and Cuba are not signatories of the Extractive Industries Transparency Initiative (EITI), reference to it has been removed from this report.

Performance

Ethical Conduct

Sherritt has a Whistleblower Policy, which indicates that any person submitting a reportable concern may choose to do so anonymously and confidentially through the Whistleblower Hotline maintained by the Corporation’s designated external service provider. Reportable concerns may be submitted by any of the Corporation’s stakeholders, including employees, contractors, directors, officers, vendors and others.

In 2019, four reportable concerns were submitted through the Whistleblower system. Of the four reportable concerns, three were internally investigated and one is open pending the conclusion of an internal investigation. The concerns were mainly related to potential conflicts of interest and/or non-compliance with policies and procedures.

Upon commencing employment with Sherritt, all employees are required to review and sign off on their understanding and acceptance of our Business Ethics Policy.

Anti-Corruption

Sherritt’s Anti-Corruption Policy was last updated in 2018. In 2019, we rolled out an updated online anti-corruption training module as part of our existing onboarding program. One hundred percent of our eligible workforce was trained on the updated policy by the end of 2019. In Cuba, only expatriate employees and a small number of Cuban nationals who work directly for Sherritt were required to take the training, given the nature of our joint venture relationships and our agreement with the state-run agency that provides our operations with workers. In Canada, all salaried employees across all sites and divisions are required to take the training.

Additional commentary on transparency reporting can be found under Community Development.