Diving Into Glencore Compliance Report

Commodities trading giant Glencore published an in-depth look at its ethics and compliance function this week, part of the company’s penance for a corporate corruption scandal it settled in 2022. Anyone wanting a glimpse into how global businesses might structure their compliance operations, especially when recovering from a misconduct scandal, look no further. 

As you might recall, Glencore pleaded guilty, agreed to two independent compliance monitors, and paid more than $1 billion to U.S., British, and Brazilian authorities for long-running bribery and market manipulation schemes in the 2010s. The accusations against Glencore read like a bingo card of bad practices: sham agreements with intermediaries, inflated prices on invoices, poor controls over cash, cryptic email messages, and so forth; all of it executed either by or with the knowledge of senior Glencore executives at the time.

Well, fast-forward to three years later. Glencore brought in new leadership and spent gobs of money building a stronger compliance program. The Justice Department just ended those two monitorships early, amid a larger retreat from using compliance monitors as part of corporate misconduct settlements. And now the company has released a full-color, 114-page report explaining all its compliance program improvements; chock full of statistics about risk assessments performed, conflicts of interest disclosed, employees and third parties trained, and more. 

So what’s news in that report? 

Most notably, Glencore is reshuffling its compliance leadership. Previous head of compliance Daniel Silver has left the company, presumably because the company’s monitorships have ended. Succeeding him as head of compliance is Nicola Leigh, who had been head of Glencore’s monitorship liaison team; she formally takes over as head of compliance on May 1. 

Glencore has also wrapped up several lingering investigations from Swiss, Dutch, and Jersey regulators, all of them with only nominal penalties. 

Statistics, Frameworks, and Codes

The guts of Glencore’s report starts on Page 10, with a full-page graphic showing all the ethics and compliance stuff the company did in 2024. See Figure 1, below.

 

 

That’s all great, but a compliance program that’s busy isn’t necessarily the same as a compliance program that’s effective. So instead let’s review some of the steps that Glencore took in 2024 to move its corporate culture in a more ethically aware and rigorous direction.

First, the company launched a new Code of Conduct, based on six core values::

• Safety
• Integrity
• Responsibility
• Openness
• Simplicity 
• Entrepreneurialism

For a mining and trading business, those are good values. Safety is a huge concern for people in the mining industry, so employees (especially lower-level employees) can see a clear connection between a major risk to them and how the company wants to protect them from that risk. 

Integrity, responsibility, and openness all emphasize the importance of good business conduct, which is a message people need to hear when their employer has paid $1.1 billion for corruption and market-manipulation charges.

Simplicity and entrepreneurialism, meanwhile, remind everyone that Glencore is a business, and two of the primary missions of a business are to (a) run efficiently; and (b) grow and make profit. 

Glencore then introduced its new Code of Conduct with a gigantic town hall event last July. The in-person portion happened in three locations simultaneously, drawing 500 employees to sites in Switzerland, Britain, and South Africa; another 3,000 employees watched online; and the whole thing was a panel discussion featuring eight senior Glencore executives. The discussion included a review of the various reporting channels available to employees, and afterward senior managers encouraged local teams to run their own local Code of Conduct campaigns. 

So far, so good. Glencore also developed a simple framework to help employees make decisions with integrity, and to keep them working in step with the Code. See Figure 2, shamelessly stolen from the Glencore report.

 

 

Let’s be honest: several of the steps on this framework — “Is it consistent with our values and our policies?” and “Am I comfortable with the impact my decision will have on others?” — leave lots of room for subjective individual judgment. Training and communication are how you channel that subjective judgment along the company’s desired lines.

Still, the framework itself is a nifty tool. Simple, clear, concise; just the sort of thing you could print out and hang in every employee breakroom you have.

Size of Glencore Compliance Team

The Glencore report also devotes a long section to the staffing and structure of its compliance team. 

At the headquarters level are two teams. The “corporate compliance” team is responsible for designing, monitoring, and improving the whole program. It includes subject-matter experts for each of Glencore’s big compliance risks, plus the heads of the teams that actually run the program’s various elements. A second “regional compliance team” oversees the implementation and management of the program at offices and industrial sites around the world, and also provides guidance to local compliance officers. Both teams together have 136 full-time employees. 

Another 66 full-time employees are local compliance officers around the world who manage “on-the-ground implementation” of the program; and they’re helped by another 35 “local compliance coordinators” who have other primary jobs in corporate or operations roles but dedicate part of their time to the compliance program. Then there’s another 24 local compliance support staff, for a total of 261 people in all. 

Those employees are assigned to various locations around the world based on (a) the volume and nature of Glencore’s business in those countries; and (b) the risk profile of the countries. The company even included a nifty world map (Figure 3, below) depicting how many compliance people are where.

 

 

That’s enough for today, and we’ve barely scratched the surface of all the material in Glencore’s report. 

The big question, of course, is whether Glencore will continue to release such a robust discussion of its ethics and compliance efforts in the future, now that the Trump Administration has ended the compliance monitorships and essentially terminated any further attention to Glencore’s rehabilitation.

We can’t fault the company if it decides to do so; it’s not Glencore’s job to subsidize our exploration of ethics and compliance. Other companies that have published ethics and compliance reports in the past only did so while living under a consent decree of some kind, and stopped as soon as they could.

That would be a shame, because there really is a lot to study and consider in Glencore’s report. Kudos to the leadership for publishing it, and we’ll take further deep dives in future posts.