Sherritt recognizes the importance of having strong accountability mechanisms and governance structures in place and transparently reporting on the effectiveness of our policies and outcomes of our activities. Sherritt continues to engage third-party expertise to provide assurance related to our sustainability policies and results.

Corporate Governance

Sherritt has an independent chairperson and three subcommittees of the Board of Directors that oversee matters related to environment, social and governance. The Reserves, Operations and Capital (ROC) Committee is the primary Board committee charged with setting and monitoring implementation of ESG priorities and approving policies and actions identified by the ESG sustainability steering committees and working groups for managing the company's ESG risks and opportunities. A copy of the ROC Committee's mandate is publicly available here.

Operationally, accountability for the Sustainability Framework is the responsibility of the CEO and the ESG Steering Group, which is composed of all executives and division heads. The ESG Steering Group identifies priorities for the ESG Working Group, which delivers on these across the organization and reports back to the Steering Group on outcomes as appropriate. ESG responsibilities are a part of all department and division mandates.

A graphic outlining the reporting structure for Sherritt’s sustainability governance: Top row: independent chairperson; second row: Reserves, Operations and Capital Committee – Human Resources Committee – Audit Committee; third row: CEO; fourth row: ESG Steering Group, which includes the following roles: Chief Commercial Officer, Chief Human Resources Officer, Chief Financial Officer, VP of Sustainability, SVP of Mining and Metals, SVP of Oil & Gas and Power, SVP – General Counsel and Corporate Security, VP of Technologies; fifth row: ESG Working Group, which includes the following departments: Legal, Human resources, Operations, Supply Chain Management, Finance, Marketing, Sustainability

Grievance Mechanism

Sherritt has a Whistleblower Policy and grievance mechanism that allows any person anywhere in the value chain to submit a reportable concern anonymously and confidentially through the system 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.

Sherritt maintains mechanisms to facilitate the receipt, retention and treatment of reportable concerns and grievances. These are reported to the Board of Directors. The mechanisms are intended to cover theft, fraud and allegations of any kind of unethical behaviour. If you have a reportable concern or grievance against Sherritt or any of its subsidiaries, you can report your issue anonymously and confidentially through the following channels maintained by the Corporation’s designated external service provider:

For concerns related to the Fort Site in Fort Saskatchewan, Alberta, please call 1-780-992-7000.

Business Conduct

Our Business Ethics Policy and Anti-Corruption Policy provide clear guidance to our workforce on what it means to act with integrity. These policies cover 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. These policies are not available publicly but may be provided upon request.

As a Canadian corporation, we are subject to the Canadian Corruption of Foreign Public Officials Act (CFPOA), as well as anti-corruption laws in all jurisdictions in which we operate. 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 undergo mandatory anti-corruption training and are required to log all government meeting, gifts, and business courtesies.

Sherritt complies with the Extractive Sector Transparency Measures Act (ESTMA) in Canada and supports the implementation of the Extractive Industry Transparency Initiative abroad. On an annual basis, Sherritt produces and discloses an ESTMA report which transparently itemizes regulatory payments made to governments in Canada and Cuba. These reports have been made publicly available and are found here.

In Canada and Cuba, governmental and commercial corruption does not present a significant risk, based on the latest Corruption Perceptions Index. Sherritt does not have any operations in countries that rank outside of the top 70 on the Corruption Perceptions Index.