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.
- Human Rights Policy.
- International Bussiness Conduct Policy.
- Environment, Health and Safety Policy.
- Equal Opportunity and Non-discrimination Policy.
- Diversity Policy.
Alumina Limited has a series of policies that drive the manner in which it conducts business. These include an Anti-Corruption and Money Laundering Policy and an International Business Conduct Policy that 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.
All of Alumina Limited’s policies are available for review in the Governance section of the Company web site.
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.
The AWAC business operates in various regions in the world and interacts with customers around the globe. Alcoa has policies and procedures in place for AWAC employees to adhere to in their dealings third parties. 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.
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 2017.
During 2017, 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 2017 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.
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
Alumina Limited has developed Anti-Corruption and Money Laundering Policies that prohibit bribery and corruption in all business dealings.
Australian Climate Change Legislation
In 2017, AWAC's alumina refinery in Spain was operating under Phase 3 of the European Union’s (EU) Emissions Trading Scheme.
Since the inclusion in the EU Emissions Trading Scheme, relatively modest payments have been incurred for purchasing allowances under the scheme. It is anticipated the Phase 4 of the EU Trading Scheme, covering the period 2021 – 2030, will directly impact both carbon and energy pricing.
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 committed to the Paris climate change conference with a target to reduce emissions to 26-28 per cent on 2005 levels by 2030. The current Government has as its deliverer, its Direct Action policies and at its core, the Emissions Reduction Fund and Renewable Energy Target, energy efficiency improvements, phasing out very potent synthetic greenhouse gases, and direct support for investment in low emissions technologies and practices. The Renewable Energy Targets (RET) had 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.