Vale recognizes and understands the myriad human rights challenges inherent in our operations, given the nature of the mining industry and the locations where we operate. Our commitment to Human Rights spans across every phase of the mining life cycle—from mineral exploration to mine closure and across all businesses.
Furthermore, public policies that guarantee the Human Rights of communities are not always fully present in these very remote regions.
When commencing mining activities in areas with these characteristics, there is a risk of heightening the social and economic vulnerability of local communities. This requires the company to have a robust Human Rights management and a cross-disciplinary approach to address the complex and systemic issues involved.
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Our approach
Vale’s approach to Human Rights is aligned with the UN Guiding Principles on Business and Human Rights, the UN Global Compact principles, the Universal Declaration of Human Rights, the principles and guidelines issued by the International Council on Mining and Metals (ICMM), and the International Finance Corporation’s (IFC) Performance Standards. This approach meshes directly with our strategic pillars, our Integrity agenda, our Ethics & Compliance Program and our ongoing cultural transformation.
The Human-Rights governance at Vale is based on respect, awareness raising, and promotion of Human Rights. It includes efforts to prevent, manage and, where necessary, mitigate and remediate adverse impacts and violations within our activities and throughout the value chain. We also value and recognize the importance of engaging with stakeholders on critical issues to improve processes and advance this agenda across the company.
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Governance
Everyone at Vale must respect the Company´s Human Rights commitments, starting with the Board of Directors and extending to all employees. The Board of Directors—our highest governance body—has been assigned responsibility for acting as guardian of our Human Rights commitment, which is stated in the Company bylaws.
Human Rights topics are monitored by our Sustainability Committee—which advises the Board of Directors—and at the executive level by the Executive Committees for Compliance and Operational & Compliance Risks, in accordance with Vale's Risk Management Policy. These committees take a preventive approach and are responsible for assisting executive vice presidents in monitoring business risks and making related decisions.
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Policy commitment
Our practices are guided by a global Code of Conduct that applies to all Group subsidiaries and affiliates and includes a chapter on Human Rights. Another core policy document is our Human Rights Policy, issued in 2009 and last revised in 2023. The previous revision in 2019 was informed by a public consultation hosted on Vale's website in both Portuguese and English. The consultation was published on social media and communicated by email to stakeholders. The consultation engaged 382 respondents from different sectors and social groups, providing important inputs.
To make the contents of the Policy more tangible and engaging for employees, Vale has a Human Rights Guide (now in its 3rd edition) along with guidelines addressing critical Human Rights issues in the mining industry.
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This set of documents guides Vale’s approach to and stance on issues such as diversity; ensuring political freedom and freedom of association; raising awareness about workplace and sexual harassment; combating the sexual exploitation of children and adolescents; fighting discrimination; combating child and forced labor; combating human trafficking; corporate security practices; community engagement (including Indigenous Peoples and Traditional Communities); involuntary resettlement; Listening and Response Mechanism; and our Whistleblowing Channel.
All contractors and joint ventures operated by Vale are required to be familiar with and abide by our Human Rights Policy. This Policy and our Principles of Conduct for Third Parties require suppliers and partners to apply equivalent principles in their own operations and supply chains.
Training and dissemination of Human Rights content
Vale actively provides Human Rights training to employees. This mandatory training is offered in Portuguese, English, Spanish, Japanese, Bahasa, Malay, Arabic, and Brazilian Sign Language (Libras) across the various countries where Vale operates.
Vale’s Human Rights team also carries out in-person and remote capacity building and programs, such as programs addressing business and Human Rights which have been developed for the Board of Directors, leadership and their teams. There is also capacity building for the Corporate Security team, such as specific training aligned with the Voluntary Principles on Security and Human Rights.
For third parties, human rights training has been integrated into Onboardings since 2023. Since then, 100% of suppliers with workers mobilized by Vale have been trained. For suppliers with a higher human rights risk, specific training is provided.
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In addition, Vale provides a range of content covering critical topics for employees, suppliers, joint ventures, and customers, including:
• Indigenous Peoples´ culture and way of life
• Gender relations
• Forced labour and modern slavery
• Child labor
• Sexual exploitation of children and adolescents
• Collective bargaining and freedom of association
• Diversity and Inclusion
Human Rights and Decent Work
Human Rights Dialogues
Guide to preventing and combating sexual exploitation of children and adolescents
Guide for Prevention and Combat of Modern Slavery
Guide for Prevention and Combat of Child Labour
Managing Human Rights risks and impacts
Vale’s approach to managing risks, including Human Rights risks, follows the Three Lines of Defense model. Operational departments have primary and direct responsibility for identifying, monitoring and managing risks in an integrated manner (1st line).
The Human Rights department, as specialists, develop and maintain risk management, internal controls, and compliance processes. They identify and monitor new/emerging risks and ensure continuous improvement and compliance with our risk management framework and applicable laws, regulations and standards (2nd line). This department also provides training and guidance to our operations in identifying risks, and reports on risk management results to the Risk Committee and executive vice presidents.
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As a final line of defense (3rd line), the Internal Audit and Whistleblowing Channel, both independent from the Board of Directors, conduct assessments and inspections to test controls and investigate whistleblowing reports, respectively. The Audit function oversees the areas, including processes and the management of Human Rights risks.
Our approach to managing impacts is governed by our Global Human Rights Policy. At Vale, this process may be activated as a result of on-site inspections, grievance mechanisms reports, allegations, independent human rights due diligence findings, audit findings, Whistleblower Channel investigations, or due diligence preceding mergers, acquisitions, and joint ventures.
Human rights risks are included in Vale’s Global Integrated Risk Map, and all operations and critical projects assess and monitor Human Rights risks using a global risk management system. Human rights are also covered in risk and impact assessments for mineral exploration activities, mining operations, some non-operational departments, projects, and joint ventures.
In situations involving new circumstances, such as entering new countries or establishing new relationships, Vale conducts additional due diligence and risk assessment processes. For example, expansion into a new region with socioeconomic vulnerability may require specific measures to ensure the protection of human rights and risk mitigation.
In these assessments, potential risk causes are determined and grouped into Vale’s salient Human Rights issues: Failures/defects in the hiring process (recruitment / mobilization) of own employees or business partners working for Vale; Non-compliance with contractual commitments and labor and/or social security obligations; Absence or failure to monitor working conditions including facilities and accommodation; inappropriate behavior that characterizes discrimination and/or harassment; Vale’s direct or indirect connection with child labor and/or sexual exploitation of children or adolescents. Both preventive and mitigating measures are taken as part of our approach to risk management, and the effectiveness of controls is monitored through periodic testing.
Monitoring results inform continuous improvement efforts aimed at identifying, preventing, mitigating and addressing Human Rights risks and negative impacts, with a focus on people, including employees and contractors and members of local, Indigenous Peoples and Traditional Communities.
In assessing non-operational risks to which the company is exposed, the Social and Human Rights dimension is factored in determining the magnitude of impacts. Therefore, aspects related to salient human rights issues are considered in risk assessments in this category, in addition to financial, reputational, environmental, and health and safety aspects.
In addition to Human Rights risk assessments, Vale also carries out Human Rights due diligence on all its operations and critical projects.
The due diligence process is conducted by specialized, independent consultants and includes desktop reviews, on-site assessments, interviews, and focus groups, sometimes grouped by gender. Participants include both direct employees and contractors, community members, and representatives from government, academia, and civil society.
The results are shared with Vale's Human Rights area and with each assessed site and its leadership. Recommendations are translated into controls and corrective actions to improve risk management and remediate identified negative impacts. The Human Rights Management team monitors the entire process and oversees the implementation of controls and corrective actions.
Between 2019 and 2023, the first HRDD cycle was completed across 100% of our operations in Brazil (including active, curtailed, and decommissioned assets), and in our iron ore operation in Malaysia and Oman.
Our HRDD conducted in the first cycle identified challenges related to contractor working conditions, infrastructure and facility management, property security, workplace and sexual harassment, discrimination, and diversity and inclusion.
In 2024, the second cycle of HRDD was started in Oman and five other operations in Brazil’s Northern System (Serra Norte, Serra Sul (S11D), Serra Leste, Manganês do Azul and Carajás Railroad operations.
In comparison with the first cycle of HRDD, the findings of the work carried out to date revealed, among other results, that we have made progress in worker safety, with the provision of the “right to refuse”; in conducting training and campaigns on critical human rights issues; in contract management and supervision controls; and in disseminating the reporting channel and strengthening community relations.
We still face challenges related to the availability and conditions of facilities and infrastructure for workers, as well as issues related to ethical conduct and working conditions for migrant workers, which are being addressed action and mitigation plans, which are continuously monitored by the company.
Click here to learn more about Vale's Human Rights due diligence methodology.
During 2023, HRDD was conducted in 48 extreme or very high consequence Tailings Storage Facilities (TSF) globally as classified based on the criteria outlined in the Global Industry Standard on Tailings Management (GISTM). The main results of the Iron Ore Solutions TSF indicate potential and actual impacts relating to the right to information, the right to livelihoods, the right to housing, the right to life, and the effectiveness of grievance mechanisms.
Mergers and acquisitions, joint ventures and accommodations also undergo independent human rights due diligence using case-specific methodologies and procedures.
As part of our approach to assessing risks and impacts, Vale implements human rights management at its suppliers, a partnership between the Procurement and Human Rights teams, with a team dedicated exclusively to this management. This process spans the supplier’s entire journey within the company, from onboarding through contract management, including independent Human Rights due diligence, capacity building, and development of the supply chain.
Prior to bidding processes, all suppliers undergo a background check based on public information and document submissions providing details on health, safety, and the environment (HSE), Human Rights, compliance and integrity considerations.
In Brazil, all Vale suppliers are screened against the federal government’s Slave Labor Dirty List.
Supplier contracts include provisions requiring compliance with the Principles of Conduct for Third Parties, as well as adherence—through contractual clauses—to expected behavioral standards. These standards encompass the provision of decent working conditions; the prevention of child labor and the sexual exploitation of children and adolescents; the prevention and elimination of forced labor, modern slavery, and human trafficking; a zero-tolerance approach to discrimination and harassment; and the respect for freedom of association and collective bargaining rights. Vale’s standard contract template also includes anti-corruption and health, safety, and environmental (HSE) clauses.
When classifying our suppliers on Human Rights risks, we consider, among other aspects, the supplier’s industry and location. We mitigate these risks through training, self-assessment questionnaires, document inspections, and on-site inspections. When necessary, we request that suppliers develop an action plan to address identified weaknesses. When impacts or non-compliance with Human Rights are identified, the supplier may be asked to develop an action plan, which is monitored by Vale, or even have its contract terminated, depending on the severity of the issue.
In 2024, 490 suppliers in the Iron Ore Solutions segment in Brazil were classified as high risk regarding human rights due to their contract characteristics with Vale and their risk classification in the ESG Matrix, as part of the risk management measures of the Responsible Procurement Program. Among these suppliers, mitigation actions were implemented for 353, with human rights inspections being carried out for in 72 of them (in addition to 9 other suppliers that were not classified as high risk but were still subject to inspection). The results of the inspections pointed to the following challenges: tackling the sexual exploitation of children and adolescents, addressing the reliability of reporting channels, and improvement of working conditions and labour relations.
Starting from 2023, we expanded some human rights risk management measures to locations beyond Brazil: In Malaysia and Oman, 77 suppliers were classified as high risk regarding human rights, and mitigation actions were implemented for 48 of them—in addition to human rights inspections being carried out on 31 of these suppliers. Another four (not included among the high-risk suppliers) were also inspected due to their contract characteristics. The recommendations relate mainly to issues involving immigrant workers, sanitary facilities and accommodation, which are being addressed through action plans.
Vale contributes to the development of suppliers by offering training to improve their performance of human rights. We promote knowledge sharing to build a more responsible supply chain that is aware of salient human rights issues. In 2024, 399 suppliers responded to the Human Rights Management Self-Assessment Questionnaire and more than 730 suppliers were engaged in training, reaching 1,709 external professionals, including company leaders and contract managers. In addition, we encourage our suppliers to implement compliance programs, offer and publicize listening mechanisms, and follow the same guidelines with their value chains.
The UK Modern Slavery Act 2015 requires companies to publish an annual statement describing their management of critical issues related to slavery and human trafficking.
Vale and its subsidiaries oppose modern slavery and human trafficking in all their forms and expect their suppliers to actively combat modern slavery within their own value chains.
The following file is a report prepared in accordance with Canadian law on the Fighting Against Forced Labor and Child Labor in Supply Chains Act and the UK Modern Slavery Act, in which Vale Base Metals declares, on behalf of itself and its controlled subsidiaries, its commitments to safety, sustainability, and respect for human rights in its value chain.
Whistleblowing Channel and grievance mechanisms
Grievance mechanisms
No confidentiality agreement is required as a condition to participate in the grievance process, ensuring that anyone can freely access the channels.
Anyone can request information or report concerns regarding human rights impacts. The average time to resolve a community complaint is 30 days, however the mechanism requires that the channels respond to the complainant within 10 days.
Whistleblowing Channel
In 2024, 64% of the reports investigated and confirmed by the Whistleblowing Channel involved interpersonal relationships, including themes such as inappropriate behavior, mismanagement, bullying, sexual harassment, and discrimination. To learn more about the primary concerns raised through our whistleblowing channels, refer to our Annual Ethics & Compliance Report.
All employees and third parties are informed about the grievance mechanisms through human rights training. Vale also promotes its channels on its operations and neighboring communnities as well as in its website, social networks, ESG portal.
In addition to these channels, in 2022 Vale launched a new Support Channel, an initiative created as an improvement opportunity from the Reporting Channel, to offer more humanized assistance in cases of harassment and discrimination. This channel provides human-centric support and counseling delivered by independent specialists to employees or contractors who have experienced sexual harassment or discrimination. The channel can be accessed anonymously and confidentially.
Remediation
Vale’s commitment extends to addressing and remediating any Human Rights impacts we may cause, contribute to, or be directly associated with. These efforts are implemented either directly or in collaboration with partners. We also seek to engage stakeholders in designing and implementing remediation measures and in monitoring the agreed solutions.
Vale places a strong emphasis on precautionary measures to prevent recurrence, and has reevaluated all aspects of the business as part of our strategy to improve sustainability performance. Following the dam breaches in Mariana and Brumadinho, we conducted a comprehensive review spanning areas such as governance, Human Rights management, health and safety processes, operational excellence, operational risk assessment, and remediation.
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Stakeholder engagement
Engaging with stakeholders on salient Human Rights issues is important to inform better initiatives and joint solutions and to advance this agenda across Vale.
We tailor our approach to the unique characteristics of each stakeholder group and the most sensitive issues, using a thematic matrix to guide the focus of our initiatives (see the table below).
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Special attention is given to the security teams responsible for protecting the physical integrity of individuals, preserving our assets and information, and ensuring operational continuity. While these teams must have their rights respected, they often deal with conflict situations and must make their best efforts to seek peaceful solutions that respect Human Rights.
Our approach to managing security teams encompasses multiple aspects, from employee selection based on technical competence and emotional stability, through training on Human Rights and the proportional use of force when necessary, to seeking peaceful solutions and treating vulnerable individuals and groups with care. Vale is a signatory of and has implemented the Voluntary Principles on Security and Human Rights (VPSHR), and we maintain an open communication with communities and local authorities for conflict resolution.
Vale recognizes the importance of the role of Human Rights and Environmental Defenders and does not tolerate or contribute to threats, intimidation, or attacks. Grievance mechanism and reporting channel are available to report and address potential adverse impacts from our activities.
We actively engage in significant initiatives through strategic partnerships with organizations tackling salient Human Rights issues such as sexual exploitation of children and adolescents, modern slavery, artisanal and small-scale mining, and living wages. Through these partnerships, we also support the development of standards and procedures, share challenges and best practices, and anticipate and assess global trends.
Notable initiatives and partner institutions include: the Global Business Initiative on Human Rights (GBI); the Voluntary Principles on Security and Human Rights (VPSHR); Childhood Brazil; the Institute for the Brazilian National Pact to Eradicate Slave Labor (InPacto); the World Business Council for Sustainable Development (WBCSD); the Brazilian Business Council for Sustainable Development (CEBDS); BSR; and the International Council on Mining & Metals (ICMM).
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Commitments and targets
Vale has outlined a roadmap to foster continuous improvement in our Human Rights management processes by 2030. This roadmap covers our key operations stages and responsibilities, including:
Policy commitment and integration
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Disseminate our revised Global Human Rights Policy to all employees;
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Incorporate Human Rights content in existing standards;
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Provide Human Rights training to leaders and employees and contractors.
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Risk and impact assessment
- Maintenance of independent Human Rights due diligence on operations and projects;
- Straightening of value chain risk management beyond Brazil.
- Monitor controls and action plans for operations;
Monitoring and reporting
- Improve Human Rights reporting, including related key performance indicators;
- Monitoring action plans resulting from Human Rights assessments and independent due diligence;
- Track trends and developments in legal requirements and best practices in Human Rights.
Grievance mechanisms and Whistleblowing Channel
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Continue to improve reporting mechanisms based on lessons learned and inputs from stakeholder engagement;
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Implement reporting systems in all operations, ensuring core requirements are adapted to each site;
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Address all allegations including 100% of those identified by the Business and Human Rights Resource Center.
Remediation – beyond priority reparation processes
- Ensure that Human Rights impacts are effectively remediated and, where any of our operations have contributed to or are linked to impacts, ensure that the company is part of the solution.
Partnerships
- Continue our Living Wage program for employees, providing decent wages consistent with global benchmarks.
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