IGBR CODE OF CONDUCT for health & safety sets out the minimum standards that people must adhere to when doing business. The Code of Conduct ensures a daily reporting framework for illness and injuries, including preventative measures adopted.

The Code of Conduct has POLICIES, setting out the minimum procedures to be followed at all times. They are implemented and supported by the managers and supervisors in charge.


Our Health & Safety framework requires the following to be done for each hazard that might result in injury or illness:

Identify hazards that could potentially have a negative impact on people’s health and safety.

Asses the hazard(s) identified based on IGBR’s framework for hazard assessment with reference to occupational exposure limits.

Establish the identified hazard risk profile and put in place a process to monitor and control this risk hazard.

Let relevant stakeholders know the hazard including the results of the hazard assessment.

Overview of the Code


The Code of Conduct (the “Code”) applies to all the businesses of IGBR, including people who are contractually obligated to these businesses.


IGBR Code of Conduct defines the minimum standard for Health & Safety. The Code of Conduct is not prescriptive, it does not contain prescriptive rules for each and every situation and event that might arise. In the absence of guidance provided by our Code, every individual is expected to exercise reasonable judgement.


Behaviour that is in breach of the Code shall be reported to the manager or supervisor, which may then result in disciplinary action including termination of employment.

Applying the Code of Conduct

Where IGBR has Active Interests in Mining Projects and Producing Factories

Where IGBR has investments mining or manufacturing plants, we aim to influence our alliance partners to adopt the policies and procedures laid out in our Code of Conduct.


Where our potential new partner’s health and safety policies are misaligned with our Code and where reasonable steps cannot be undertaken to mitigate health & safety risks, IGBR opts out of such partnerships.


For IGBR health and safety of people is our first priority.

Responsibility of Leaders, Managers and Supervisors

Leader, managers and supervisors must lead the Code by example. Our leaders, managers and supervisors must:


  • Create a positive environment, where employees and contractors are trained to follow the protocols set by the Code
  • Promote a culture where people’s attitude towards safe operations becomes the first priority
  • Provide a working environment where people feel comfortable saying ‘no’ to any job that compromises their own and others safety.
  • Promote an environment where people do not hesitate asking questions and raising concerns without the fear of being judged or retaliation.


Leaders, managers and supervisors are expected to communicate IGBR’s Values and the Code to the people involved in each supply transaction.

Sourcing Partnerships

IGBR ensures that our supply partners:


  • Are legal and law-abiding practices,
  • Follow our Code of Conduct in business transactions with us,
  • Follow safe and healthy business practises, and
  • Follow business practises that prioritise people’s safety first.


These requirements are stipulated in our contracts with our partners, where appropriate. IGBR may terminate the contract with our partner where they breach the Code.

Asking questions and raising concerns

We promote a safe environment to work!


Where concerns are raised, the confidentiality of those raising the concern will be respected and protected, should they opt to remain anonymous. Concerns need to be communicated vocally straight away following by an electronic record. You can send emails raising questions or concerns to enquiry@igbr.com.au, attention the note to IGBR Director and state the subject of the note as “Code of Conduct”.


We understand these calls or emails are a priority and will be assessed promptly. Abuse of these channels of communication is not acceptable.

Health & Safety

Health & Safety is our first priority. We take responsibility to ensure that people remain safe.


We aim to create a workplace free of injuries and fatalities. We encourage people to take responsibility of their own safety and the safety of their colleagues, contractors and the communities in which they operate. They do this by first and foremost following our Code and systems established for the safety of the people.


IGBR has strict compliance requirements towards people being fit for duty – mentally, emotionally and physically. It is mandatory for people to follow our health and safety instructions to create a safe environment for themselves and their colleagues.


People shall not put themselves in the line of fire and must use their authority to stop work where they consider it unsafe.


People are fundamental to our business. We treat are people with respect, including fair opportunities to grow and develop their careers.


When our people grow, our business grows. At IGBR, we expect every employee to improve at least 5% in productivity annually. Every employee needs to find ways where they become more skilful in their jobs, resulting it higher results with the same amount of time and effort.


Our people are required to understand how IGBR operates, and what is required to be successful and sustainable in the long-term. It is our leader’s responsibility that our employees do not fail. If our employee’s productivity increases by 5%, they are not working hard, but smarter.


We invest in employee development programs, when and where the long-term benefits are expected to come back to the organisation.


We do not tolerate any form of workplace discrimination, harassment or physical assault, or any form of child, forced, or compulsory labour. We seek to reflect the diversity of the communities in which we operate within our workforce. We respect the rights of our employees and contractors, including the freedom of association and collective bargaining.


IGBR recognised the benefits arising from employee and board diversity, including a broader pool of high-quality employees, improving employee retention, accessing different perspectives and ideas and benefiting from all available talent.


Our Diversity Policy includes, but is not limited to, gender, age, ethnicity, disability, sexual orientation and cultural background. This is the foundation on which IGBR has built its approach to Diversity.


The long-term ambition is to reach a balanced composition of Diversity at all leadership levels and in general to build a much more diverse organization. We progress towards a gender balanced leadership composition.


IGBR is committed to providing opportunities for people from diverse cultural and social backgrounds. We monitor our performance in achieving the objectives of this Policy. The Directors are responsible for the implementing and reviewing this Policy.


IGBR’s engagement with the community is integrated into all stages of our business transactions.


We respect and promote human rights within our area of influence. This includes respect for the cultural heritage, customs and rights of those communities, including those of indigenous peoples.


We work with governments, local authorities, community representatives, inter-governmental and non-governmental organisations and other interested parties to develop and support community development projects. These projects and other donations are developed and decided in accordance with our policies and guidelines. These activities, along with the employment we provide, contribute directly and indirectly to the prosperity and development of our local communities in particular and our host countries. Where possible, we support and promote local employment and local procurement through training and small and medium enterprise development.


Throughout our operations, environmental impacts are identified, analysed and reflected in our planning, management systems and day-to-day activities. We comply with applicable laws, regulations and other requirements for environmental management. Where these are less stringent than our own standards, we apply our higher standards.


We conserve and protect environmental resources through a broad range of proactive initiatives, which include the efficient use of energy and water, minimising waste, reducing emissions and protecting biodiversity. Throughout the lifecycle of our activities, we conduct ongoing consultations with local communities and other stakeholders to ensure that we operate in a manner that is appropriate.


We undertake responsible closure planning with the purpose of achieving final sustainable land use.


We manage our waste sensibly. We regularly examine the integrity of our facilities to mitigate against the risk of serious incidents. We acknowledge the increasing societal and regulatory pressure to reduce carbon emissions to address climate change. We work proactively to manage our energy and carbon footprint and support the development of low emission technologies. We work with policy makers and others to promote the development of a least cost pathway to reducing global emissions while at the same time meeting the needs for affordable energy in developing nations.


We believe in the importance of maintaining active engagement and dialogue with stakeholders. We are committed to communicating regularly, openly and accurately with our employees, contractors, customers, suppliers, local communities, and investors, as well as appropriate associations, governments and other stakeholders.


We undertake fact-based, timely and constructive communication with all our stakeholders across a wide range of matters. We share information on matters that affect our operations and activities with relevant stakeholders. Our engagement with all our stakeholders supports our decision-making process.


We regularly engage in dialogue with governments on issues that affect our operations and activities. Seeking to maintain open and constructive relationships with governments ensures awareness of the opportunities, constraints and concerns related to our operations and marketing activities on an ongoing basis. Communications with governments must only be undertaken by suitable senior management or authorised personnel and all information shared should be accurate and not misleading.

Compliance and Tax

Conflict of interest: A conflict of interest is a situation in which an individual has a private interest sufficient to potentially influence the objective exercise of his or her professional duties. Everybody working for IGBR must avoid actual conflicts of interest and, wherever possible, avoid apparent or potential conflicts as well. We must safeguard IGBR’s legitimate interests through properly performing our professional duties.


Any concerns around an actual or potential conflict of interest or an unclear situation should be immediately referred to an appropriate supervisor, manager or compliance contact. Contractors, suppliers and partners are engaged through a fair, formal process that includes, where appropriate, written requirements reflecting our Values and policies.


Bribery: A bribe is any financial or other advantage which is offered, provided, authorised, requested or received as an inducement or reward for the improper performance of a person’s relevant function, or the receipt of which in itself would constitute improper conduct. You must not solicit, accept, offer, provide or authorise any bribe either directly or indirectly or through any third party. Any concerns about potential bribery must be reported to a manager, supervisor or an appropriate compliance contact or, where appropriate, through the ‘Raising Concerns’ programme.


A public official may offer to enable or speed up a process that is his or her duty to perform, in return for a small payment. Such payments are often called facilitation payments and should not be made. All dealings with public officials must be transparent and we must guard against circumstances where even the appearance is made of inducing a public official to perform his or her work improperly. Further guidance on this matter can be obtained from the global anti-corruption policy or an appropriate compliance contact. Anyone working for IGBR who fails to comply with applicable anti-corruption laws and the IGBR Anti-Corruption Policy may face disciplinary action that could include dismissal.


Political contributions and activities: We do not permit any of our funds and resources to be used as a contribution towards a political campaign, political party, political candidate or any affiliated organisations. We will not use charitable donations as a substitute for political payments.


As a signatory of the Extractive Industries Transparency Initiative, we support increased transparency around payments to governments across the world and how they are redistributed and/or reinvested into the communities in which we operate. The pricing of transactions between IGBR companies is based on fair market terms, whereby exchanges of goods, property and services are conducted on an arm’s-length basis. We will continue to review our tax payment reporting and make appropriate improvements in line with any applicable regulatory developments.


Competition: We are committed to the principles enshrined by competition laws. We expect everybody working for Glencore to be aware of competition laws, to avoid infringement and ensure that suppliers or trade customers are not engaging in anti- competitive activities that could damage our business or reputation. We provide our at- risk employees with specific training and guidance on what actions may breach the law and the practical steps that can be taken to ensure compliance.


Sanctions: Sanctions are laws, regulations and compulsory measures enacted by governmental authorities in relation to particular states, regimes, entities and individuals. Such laws, regulations and measures may directly or indirectly restrict transactions involving goods, services, payments and capital transfers, or the movement of persons. They may also include other prohibitions, licensing and reporting obligations. You must respect and uphold any applicable sanctions.


Money laundering: Money laundering is a process whereby the origin of funds generated by illegal actions is concealed source. We will not participate or assist any third party in money laundering or any other illegal practice. We encourage and support everybody working for IGBR to report to a supervisor, manager or compliance contact any concerns relating to a current or prospective counterparty being engaged in money laundering.


Inside information: We have systems and processes in place that help to ensure that inside or confidential information about IGBR is secure and protected.


These activities also ensure that all products come with documentation for customers to allow safe transport, handling and use. Our marketing, logistics and product safety functions work closely together with our partners and service providers to ensure that quality and safety requirements are met throughout our supply chains. We ensure that customer enquiries are dealt with in a timely and accurate manner. We engage with all stakeholders involved with any aspect of our products. We attempt to promote the responsible use and management of these products.


We have detailed management policies and programmes that ensure our products meet regulatory requirements and our own quality standards and our customers’ needs.

Policies in place to support the Code of Conduct

Health & Safety Policy

Hazard Management Policy

Risk Management Framework

Human Resources Policy