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Ethics and Integrity are fundamental principles for achieving our purpose: we exist to improve life and transform the future. To reinforce this commitment, Vale has established an Ethics & Compliance Program with structured governance and clear rules and guidelines on how to overcome dilemmas and make the best decisions in a responsible and ethical way.
Launched in 2021, Vale’s Ethics & Compliance Program represents an evolution in the management of ethics and integrity matters, which have always been part of the company’s management system. To ensure transparency regarding this evolution, Vale voluntarily publishes an annual report detailing its processes, the results of communication and training initiatives, as well as key statistics from our Whistleblower Channel.
Launched in 2021, Vale’s Ethics & Compliance Program represents an evolution in the management of ethics and integrity matters, which have always been part of the company’s management system. To ensure transparency regarding this evolution, Vale voluntarily publishes an annual report detailing its processes, the results of communication and training initiatives, as well as key statistics from our Whistleblower Channel.
Our approach
Each day, Vale works to build a principles-based culture of ethics and integrity. Comprising seven elements (see the diagram below), our Ethics & Compliance Program takes a preventive stance by promoting ethical behaviour among all individuals working for Vale or acting on its behalf.
The seven elements of our Ethics & Compliance Program
How we prevent > detect > and correct misconduct
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Governance
Autonomy, independence and tone from the top: Vale's Ethics & Compliance Program governance is structured to ensure that the entire organization is committed to our ethical principles.
The Audit and Compliance Department is responsible for the Program. Reporting directly to the Board of Directors, and with further oversight from the Audit and Risks Committee, the department works in partnership with the Conduct and Integrity Committee.
This governance structure is designed to ensure impartiality and prevent conflicts of interest. Through periodic external audits, the Audit and Risks Committee assesses Program effectiveness every two years and contributes to its ongoing improvement.
Guidelines
Translating our values into ethical principles and clear rules: this is the main objective of the Guidelines of the Ethics & Compliance Program.
The Code of Conduct brings together the ethical principles and rules that guide the conduct of everyone who works at Vale. The document is available in eight languages and in accessible audiobooks for people with visual impairments. Its guidelines apply to Vale and its subsidiaries worldwide. We also encourage the adoption of these same principles in all companies in which we hold an equity interest (Equity Investments Management).
We also share our values and ethical principles with our suppliers and other third parties through our Principles of Conduct for Third Parties.
We also share our values and ethical principles with our suppliers and other third parties through our Principles of Conduct for Third Parties.
Act with integrity is one of our values. Our Ethics & Compliance Program guidelines also include anti-corruption rules. Vale’s Global Anti-Corruption Policy is our primary source of guidance on anti-corruption, reaffirming our commitment to doing business with integrity. Our Global Anti-Corruption Manual additionally provides practical guidance to employees. Our Global Anti-Corruption Manual additionally provides practical guidance to employees. Suppliers are required to comply with an Anti-Corruption Guide developed specifically for suppliers and other third parties.
In addition, the Program’s guidelines also includes a Conflict of Interest Management Policy, which applies to Vale employees, key management personnel, and shareholders. The document sets out criteria and guidance for the identification, disclosure, and handling of actual or potential conflict of interest situations, reinforcing the principle of “Decisions without conflicts of interest” as established in the Code of Conduct.
Main public documents that guide Vale’s ethical conduct and that of its third parties:
Communication & Training
Our ethical principles need to be communicated, understood and put into practice by everyone who works at Vale. This is the objective of the Communication & Training actions.
For each audience, a different approach. Customization is an essential part of our Communication & Training strategy. With global initiatives and specific actions for employees who are more exposed to risks, the Ethics & Compliance Program seeks to guide everyone on how to make decisions in an ethical and responsible way.
For each audience, a different approach. Customization is an essential part of our Communication & Training strategy. With global initiatives and specific actions for employees who are more exposed to risks, the Ethics & Compliance Program seeks to guide everyone on how to make decisions in an ethical and responsible way.
We provide annual updates on our training initiatives in our Ethics & Compliance Program Report.
Risk Analysis
Risk analysis is fundamental to the work of Vale’s Ethics & Compliance Program. Within this element, predictive and detective analyses related to corruption risks are conducted.
Predictive analyses are carried out annually, and whenever necessary, to assess the level of exposure of areas and processes to the risk of corruption. This ongoing assessment considers internal and external factors, such as Vale’s corporate strategy, the Transparency International Corruption Perceptions Index, and data generated by the Ethics & Compliance Program itself. This periodic analysis covers all company operations and administrative areas, enabling a risk-based approach with customized actions related to communication, training, monitoring and control, according to the level of exposure identified.
Detective analyses are carried out on a daily basis. Regional Corporate Integrity teams perform analyses and provide essential information to guide and support decision-making by the business areas. These analyses make it possible to identify potential vulnerabilities and implement preventive measures, ensuring that all our operations remain consistently aligned with the highest ethical and compliance standards.
Predictive analyses are carried out annually, and whenever necessary, to assess the level of exposure of areas and processes to the risk of corruption. This ongoing assessment considers internal and external factors, such as Vale’s corporate strategy, the Transparency International Corruption Perceptions Index, and data generated by the Ethics & Compliance Program itself. This periodic analysis covers all company operations and administrative areas, enabling a risk-based approach with customized actions related to communication, training, monitoring and control, according to the level of exposure identified.
Detective analyses are carried out on a daily basis. Regional Corporate Integrity teams perform analyses and provide essential information to guide and support decision-making by the business areas. These analyses make it possible to identify potential vulnerabilities and implement preventive measures, ensuring that all our operations remain consistently aligned with the highest ethical and compliance standards.
The role of each Line of Defense in our Ethics & Compliance Program
The 1st Line of Defense — which is directly responsible for our operations or administrative functions—works to implement effective prevention and mitigation controls and ensure that corrective action plans are adequately established and implemented to continuously improve our risk management processes.
Corporate Integrity works as a specialist 2nd Line of Defense in the management of Corruption Risk in our company. As part of this work, the Corporate Integrity area carries out a series of analyses on suppliers and third parties; external socio-environmental and institutional expenditures; conflicts of interest; gifts, travel and hospitality. We have a methodology for continuously assessing the risk of corruption, which allows our monitoring, communication and training actions to be customized according to the level of exposure to risk in each area.
Our Whistleblower Channel is part of the 3rd Line of Defense and is responsible for investigating allegations and providing impartial assurance, including on the effectiveness of risk management and prevention, internal controls and compliance functions.
Monitoring and Control
The element highlights how we monitor the company’s adherence to the guidelines of the Ethics & Compliance Program, including anti-corruption rules. The framework consists of 15 controls that enable the proper management of corruption risks. Of these, five are considered key controls¹, are part of Vale’s risk matrix, and are directly linked to the Program’s main risk analyses.
All identified non-compliances are addressed jointly with the first line of defense responsible for the process.
In addition, effectiveness testing² is conducted to assess the implemented controls. Processes are continuously monitored to ensure they remain aligned with the Program’s guidelines.
¹ Key controls are related to external socioenvironmental and institutional expenditures, suppliers, the hiring of public officials for internal positions, and Program training.
² Effectiveness tests are conducted in annual cycles distributed throughout the year.
All identified non-compliances are addressed jointly with the first line of defense responsible for the process.
In addition, effectiveness testing² is conducted to assess the implemented controls. Processes are continuously monitored to ensure they remain aligned with the Program’s guidelines.
¹ Key controls are related to external socioenvironmental and institutional expenditures, suppliers, the hiring of public officials for internal positions, and Program training.
² Effectiveness tests are conducted in annual cycles distributed throughout the year.
How we manage the risk anti-corruption:
15
controls are part of our control map and enable us to manage the risk of corruption
05
controls are considered key, are in Vale's risk matrix, and are related to the main risk analyses of the Ethics & Compliance Program
Whistleblower Channel
Vale´s Whistleblower Channel can be used by anyone, inside or outside the company, who wants to report a suspicion of violation of our Code of Conduct.
The Channel is an exclusive platform for registering allegations, operated by an independent company and structured to ensure:
The Channel is an exclusive platform for registering allegations, operated by an independent company and structured to ensure:
For detailed figures on our Whistleblower Channel and information on corrective action taken, see our Ethics & Compliance Program Annual Report.
Respect Channel
Vale employees and contractors in Brazil and Canada also have access to a support channel operated by an independent, specialized team. This channel is designed to listen, provide guidance, and offer support to anyone experiencing sexual harassment, moral harassment, or discrimination. When contacting the Support Channel, employees and contractors can choose whether or not to file a formal report, which would then be investigated by the Whistleblower Channel team.
Learn more about Vale’s Whistleblower Channel here.
Consequence Management
When misconduct is confirmed, we act with fairness and transparency, in accordance with our Misconduct Management Policy.
Vale's Whistleblower Channel operates independently and confidentially to ensure allegations are investigated fairly. Disciplinary measures and corrective actions are taken for any confirmed cases.
Misconduct can also be identified through different means – by leadership in day-to-day activities, through audit processes, regulatory bodies, or other sources. In all these scenarios, leadership plays a key role in ensuring appropriate consequences are applied.
Misconduct can also be identified through different means – by leadership in day-to-day activities, through audit processes, regulatory bodies, or other sources. In all these scenarios, leadership plays a key role in ensuring appropriate consequences are applied.
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