Values, policy and practice
Alumina Limited’s Values and Code of Conduct directs and guides the Board, management and employees in their daily activities. The code outlines ethical behaviour and ensures the rule and intent of all relevant governmental laws, regulatory and professional rules and guidelines are upheld.
The code is fundamental to our business policies and practices, including:
- Anti-Corruption and Money Laundering Policy, which prohibits any employee from engaging in any form of corruption or dishonest behaviour, whether through a direct or indirect business practice or any other means, including through agents or intermediaries.
- Human Rights Policy, which commits the organisation to advancing human rights within our internal and external business environment and avoiding human rights violations. This is through operating in a manner consistent with the Universal Declaration of Human Rights, the core conventions of the International Labour Organisation and other national laws and international human rights treaties, laws and norms.
- International Bussiness Conduct Policy, which details principles and procedures designed that Alumina Limited comply with the requirements of various national laws prohibiting corruption and bribery and proper conduct in dealing with government officials.
- Environment, Health and Safety Policy, which reflects Alumina Limited’s commitment to fulfilling its duty of care to provide a healthy and safe working environment for its employees, visitors and contractors. Alumina Limited also acknowledges the prominence of, and supports Alcoa’s Environment, Health and Safety policies and approach. Alcoa strongly pursue the long-standing goal of zero work-related injuries and illnesses at the AWAC facilities.
- Equal Opportunity and Non-discrimination Policy, which reflects Alumina Limited’s commitment to treat employees with respect and fairness and does not condone discrimination or harassment.
- Diversity Policy, which promotes the Company's goal of contributing positively to the success of the Company by promoting a high performance culture that draws on the diverse and relevant experience, skills, expertise, perspectives and the unique personal attributes of its Board members and employees.
Alumina Limited employees are required to annually complete training in the above Policies and practices and other relevant governance policies. Alumina Limited’s policies are developed specifically to meet the needs of our organisation and the environment in which we operate. Where appropriate, these policies align with Alcoa’s to ensure effective partnership in governing the AWAC joint venture.
In the field at AWAC operations, employees are subject to Alcoa's Anti-Corruption Policy. Alcoa's Anti-Corruption Policy reflects its strong commitment to conducting operations around the globe ethically and in compliance with all applicable laws. Alcoa's directors and management believe that the way to achieve results is as important as the results themselves. Vigilance in complying with anti-corruption and anti-bribery laws, including those based upon the OECD Convention, the U.S. Foreign Corrupt Practices Act, and other local anti-corruption laws, is critical for a global company.
The Anti-Corruption Policy includes:
- Anti-Corruption Policy;
- Due Diligence Review Porcess for Intermediaries;
- Gifts and Hospitality Procedure
- Charitable Contributions Policy and Procedure;
- in person and web-based trainings;
- investigations and 24/7 Reporting Line
- monitoring, audit and assessment.
Please use the link for more information on in field practice
Political donations and memberships
In line with our Code of Conduct and Anti-Corruption Policy, Alumina Limited does not donate to any political party or aligned interest group. In line with this practice, no political donations were made during 2014.
During 2014, Alumina Limited was a member of the following organisations:
Australian Aluminium Council
International Aluminium Institute
Business Council of Australia
and via AWAC/Alcoa
Australian Industry Greenhouse Network
Brazilian Aluminium Association
In 2015 there were no significant non-compliances or fines on environmental, human rights, labour or product grounds arising from either Alumina Limited’s activities or through AWAC’s worldwide operations. There was one major environmental incident that resulted in the accidental release of some caustic liquid into a river causing the death of 200 river fish. The incident was not reported in Alcoa’s financial statement as a significant spill as it did not result in a significant financial impact.
While the details of all non-compliances are investigated and reviewed, for reporting purposes ‘significant’ non-compliances are regarded as those incurring fines of $100,000 or more. This is in line with the U.S. Securities and Exchange Commission’s (SEC) guidelines.
Public and industry policy
Alumina Limited believes that transparent and open lobbying is important for furthering the interests of the alumina and aluminium sectors which are also a significant player in the Australia and global economies.
Alumina Limited consulted directly with Australian federal and state government agencies prior to the Federal Government finalisation of its emissions trading scheme and climate change legislation.
Alumina Limited contributes to the industry locally and internationally through memberships of the Australian Aluminium Council (AAC) as well as the International Aluminium Institute (IAI) a global forum of the world's aluminium producers. Alumina also has direct representation on the IAI Environment and Communications Committees and on the AAC Greenhouse Committee.
Business Conduct Policy
The Company’s operating and financial review, included in the Directors’ Report, refers to the settlements by Alcoa World Alumina LLC and Alcoa Inc respectively of investigations by the US Department of Justice and the US Securities and Exchange Commission in relation to legacy alumina contracts with Aluminium Bahrain BSC and antibribery provisions, internal controls and books and records provisions of the US Foreign Corrupt Practices Act and US Securities Exchange Act. The settlement included an acknowledgement of compliance efforts, including Alcoa Inc.’s comprehensive compliance reviews of anti-corruption policies and procedures and enhancements made to internal controls. Alumina Limited’s Anti-Corruption and Money Laundering Policy prohibits bribery and corruption in all business dealings. The Company’s International Business Conduct Policy provides principles and procedures on conducting business internationally and complying with the requirements of various laws, including prohibition of bribery and related conduct.
Alumina Limited has a Whistleblower Policy that encourages and offers protection for staff to report, in good faith, any behaviour, practice, or activity that they have reasonable grounds to believe involves:
• unethical or improper conduct
• financial malpractice, impropriety or fraud
• contravention or suspected contravention of legal or regulatory provisions
• auditing non-disclosure or manipulation of the internal or external audit process.
An independent Whistleblower hotline is available to employees who wish to make an anonymous or confidential complaint, or a formal complaint process can be initiated to designated officers within the Company. A copy of the Whistleblower Policy can be found on the Company’s website at www.aluminalimited.com/whistleblower-policyserious-complaints
Climate Change Legislation
In 2013 AWAC's alumina refinery in Spain was included in Phase 3 of the EU Emissions Trading Scheme in 2013.
The former Australian Federal Government legislated to introduce a cap and trade scheme (carbon trading scheme) in 2015. The current Australian Federal Government introduced their Direct Action Plan legislation consisting of an Emissions Reduction Fund and the Safeguard Mechanism as central to Government’s approach to climate change. The $2.55 billion fund is supporting Australian businesses, communities and landholders to undertake activities which reduce or avoid greenhouse gas emissions. The fund supports a variety of projects, including improving energy efficiency, capturing methane from landfills and storing carbon in forests and soils. There is an expectation that AWAC's Australian refineries and smelter may be included in climate measures in the next several years.
Energy costs and supply of electricity may be impacted by emerging mandatory renewable energy targets and/or energy taxes in Australia, Brazil, the US and potentially other regions in the world where AWAC has operating facilities.
The Australian Federal Government has imposed Renewable Energy Targets (RET) that have the potential to increase cost of production however, in June 2015 the Australian Government passed a regulation that provided a full exemption from RET for aluminium smelters and for alumina refineries. While this is a present outcome, it has the potential to change with a change of government or could be introduced at other AWAC operations in countries other than Australia.