Compliance

Our success is based on a solid reputation built over the years as a loyal and reliable business partner.  Keeping a commitment to ethical business practices, we look after our image and fulfill our goals together with our employees and partners.

Tthe Compliance Program covers a variety of internal policies, procedures, guidelines, training and monitoring that all of our employees, directors, officers and members of the Board of Directors must comply with.

What do we address?

We seek to maintain a culture of ethical behavior and compliance across the Group, instead of executing only the minimum required by laws and regulations. We will not knowingly help any third party to break the law or participate in any criminal, fraudulent or corrupt practice.

To support this, we have implemented a Group compliance program that includes a variety of policies, procedures, guidelines, training and monitoring that our employees, directors, officers and members of the Board of Directors (as well as contractors) must comply with.

To learn more about the Compliance Program, click here.

 

Code of Conduct

All people working for ALE Group, regardless of their location or function, must comply with ALE Code of Conduct and its policies. The Code seeks to ensure that the aspirations contained in Our Values are reflected in our daily actions and decisions and in the company’s culture.

The Code of Conduct has several supporting documents; among them, some Corporate Policies that are part of the ALE Corporate Practices structure, which apply to all company operations.

To access the Code of Conduct, click here.

 

Global Competition Law Policy

In accordance with our Code of Conduct, we are committed to fair competition within the scope of our operations and do not engage in practices contrary to the principles of fair market competition.

Anti-competitive practices are obstacles to the healthy functioning of markets, obstruct fair competition and, ultimately, harm consumers.

This Policy explains how competition law applies to ALE’s business activities and determines what our obligations are in terms of compliance.

It emphasizes the serious consequences arising from a possible violation of law and the behavior that ALE employees must adopt to ensure that we can compete successfully in the market, respecting competition law wherever it may be. You must be aware of the competition right in place to minimize the risk of violating the law. For the authorities, ignorance of the legal structure does not represent a valid argument of defense.

To access the Global Competition Law Policy and its respective Guides, click here.

Our values

Our Declaration of Values is the most fundamental element of ALE’s Corporate Practice (PCA). Our Values define our purpose, our priorities and the fundamental principles by which we conduct our business.

To access Our Values, click here.

For the English version, click here.

Global Anti-Corruption Policy

One of the objectives of this Policy is to ensure that all of our employees and, when necessary, parties with whom we do business, are aware of and comply with applicable laws and regulations regarding bribes and other forms of corruption.

To access the Global Anti-Corruption Policy, click here.

For the English version, click here.

Human Rights Policy

With this Policy, we provide guidance and a deeper understanding of our fundamental commitment to respect human rights, in accordance with the United Nations Universal Declaration of Human Rights. As stipulated in our Code of Conduct, we defend the dignity, fundamental freedoms and human rights of our employees, subcontractors and the communities in which we live and work, as well as all people affected by our activities.
We seek to ensure that impacts related to human rights are integrated into internal risk assessment processes.

To access the Human Rights Policy, click here

For the English version, click here

Reporting Suspicions

If one of our employees or third parties encounters a situation that appears to violate our Code of Conduct and the policy structure, an individual must immediately report it to the supervisor, coordinator or manager. Alternatively, suspicions can be reported to the manager of the Human Resources and Legal sectors, to the director or to your local compliance contact, whose details are available in the Compliance section of ALE Intranet or on the notice boards.

If a communication remains unsolved through local channels, it can be sent to the Glencore Group’s RaisingConcerns program, at www.glencore.com/raising-concerns. In places with low levels of internet access, we have phone numbers, which are posted to our employees through bulletin boards. Those who call or use the online form can choose to report their suspicions anonymously. No one who works for ALE will suffer retaliation, punishment or any other disciplinary action for reporting a suspicious in good faith. All reports through these “Suspicious Reporting” channels are reviewed and evaluated immediately.