Ethics, Compliance and Tax Transparency - ESG
Ethics, Compliance and Tax Transparency
Vale believes that everything starts with ethics and integrity. These principles permeate all of our values.
To reaffirm its commitment to ethics, Vale integrates into its strategy an ethics and compliance approach.
Vale's Ethics & Compliance Program has clear governance, guidelines and rules on how to overcome dilemmas and make the best decisions in a responsible and ethical way.
Ethics & Compliance History at Vale
Ethics & Compliance Program
Every day, Vale seeks to build a culture of ethics and integrity based on principles. This journey is guided by the Ethics & Compliance Program.
Composed of six pillars, the global program adopts a preventive posture by promoting ethical conduct among all who work at Vale or act on its behalf.
The Audit and Compliance Department is responsible for Vale's Ethics & Compliance Program. The department works in partnership with the Conduct & Integrity Committee, is supervised by the Audit Committee and has direct reporting to Vale's Board of Directors.
This structure guarantees the autonomy and independence required for the Audit and Compliance Department to conduct the areas of Internal Audit, Whistleblower Channel and Corporate Integrity, the latter being the 'guardian' of Vale's Ethics & Compliance Program.
Vale has zero tolerance for corruption and bribery. In addition to the Code of Conduct, the Ethics & Compliance Program presents anti-corruption rules and guidelines.
The Global Anti-Corruption Policy is the main document governing the subject and reinforces Vale's commitment to doing business with integrity.
Employees can also count on the Global Anti-Corruption Manual for practical guidance. All suppliers and contractors must follow the guidelines of the guide entitled Fighting Against Corruption, developed especially for third parties.
Vale complies with the laws and regulations to which it is subject, including, but not limited to, Law 12,846/13 – Brazilian Anti-Corruption Law, the FCPA, U.S. Foreign Corrupt Practices Act and the UK Bribery Act.
Vale takes responsibility for engaging and empowering all its employees to participate in the Ethics & Compliance Program. The goal is to guide people on how to behave correctly, to overcome dilemmas and always make the best decisions in an ethical and responsible manner.
Communications, movies, videos and training are just some of the program vehicles. Among the initiatives that make up the annual program planning, the following stand out:
To effectively measure and monitor Vale's potential risks and strengthen governance practices, Vale has a Risk Management Policy.
To manage risks related to ethics and compliance, we ensure an integrated risk management governance flow based on the concept of Lines of Defense.
The First Line of Defense, which is composed of professionals responsible for an operational or administrative area, acts to implement and execute effective prevention and mitigation controls, ensure adequate definition and execution of action plans and establish corrective actions to continuously improve risk management.
Corporate Integrity acts as the Second Line of Defense, as a specialist in managing ethics and compliance risks. It is responsible for defining minimum methodologies, technical standards and management, as well as mandatory risk indicators that must be adopted by the First Line of Defense.
The Whistleblower Channel is part of Vale’s Third Line of Defense and is responsible for investigating complaints, providing exemption assurance, and reporting on the effectiveness of risk management and prevention, internal controls and compliance.
Click here to find out more about Risk Management at Vale.
Anyone, inside or outside of Vale, who wants to report a case of suspicion or ethical misconduct, should use Vale’s Whistleblower Channel. This channel is an exclusive tool for this purpose, operated by an independent company, and structured to ensure there is:
Complaints Assessment Flow
How complaints are assessed by the Whistleblower Channel:
In 2022, Vale’s Whistleblower Channel received 6,736 reports and 6,600 investigations were closed. All confirmed violations triggered correction plans. In this year, 2,941 corrective actions were established, including 171 terminations of employment.
As a general rule, these plans contain measures to promote process improvements, training initiatives and feedback to employees. Depending on the seriousness of the allegations, employees involved may be subject to administrative measures, such as warnings, suspensions or terminations. Suppliers involved in serious violations of the Code of Conduct are also subject to punitive measures, such as fines or contract termination.
Allegations in 2022 - accurate and confirmed reports
- Inadequate personnel management
- Inappropriate behavior
- Moral or sexual harassment
Health and Safety
- Accident concealment
- Falsification of diplomas
- Fraud in contracts management
- Fraud in the hiring process
- Supplier Relations
- Relations with Government or Communities
- Customer Relations
Conflicts of Interest
- Hiring relatives
- Improper benefit through suppliers
- Hiring companies from relatives or friends
- Environmental infractions
Vale’s Whistleblower Channel can be accessed through different platforms:
Access the form at the Whistleblower Channel page, available here on Vale’s website.
Calls are free of charge and there is a specific number for each country.
Brazil: 0800 821 5000 or +55 21 3485-3000 (Vale internal phone)
Other countries, collect call to +55 21 3485-3000
Conduct Office webpage.
Vale’s Whistleblower Channel
P.O. Box 521 - ZIP Code 06320-291
Carapicuíba – São Paulo - Brazil
Vale’s Whistleblower Channel acts with independence and confidentiality to ensure a fair investigation of the facts. Fair investigation allows us to manage consequences for confirmed cases.
However, it is not only through the Whistleblower Channel that consequences can be managed. They can also be managed when misconduct is identified during routine management. Consequence management is another way to correct eventual ethical misconduct.
Disciplinary measures for confirmed misconduct are conducted fairly, according to local legislation and the proper terms of collective bargaining agreements.
Find out more about this in Vale's Code of Conduct.
To learn more about Vale’s Ethics & Compliance Program initiatives and results, check out our report 2022.
Tax Transparency Report 2021
The report is designed to share information about the taxes we pay and contributions we make to the places where we work. This is an ongoing, albeit small, part of our 'New pact with society' to engage with our stakeholders.
Building on the first publication in 2020, this year we have taken important steps to align to GRI 207, considered a benchmark in the disclosure of information on tax practices.
This report details the taxes and royalties paid in Brazil, where most of our operations are located, and those paid globally to all government levels and by project. We highlight the jurisdictions in which we have our mining operations, as our tax contribution plays a key role in supporting the communities, people and governments of the regions where we operate.
In 2021, Vale paid US$9.3 billion in taxes and royalties, of which US$8.3 billion (89%) was paid in Brazil. We believe this is a fair and proportionate reflection of the value created and we are proud to share this with society.