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    The combination of our management model and our ethical integrity leads us to our purpose: We exist to improve life and transform the future. To reinforce this commitment, Vale has established an Ethics & Compliance Program with structured governance and clear rules and guidelines on how to overcome dilemmas and make the best decisions in a responsible and ethical way.
    Launched in 2021, the Ethics & Compliance Program is designed to enhance our approach to promoting ethics and integrity, principles which have always been part of our company's management model. Vale annually reports on progress in a voluntary annual report describing our compliance processes, the outcomes of training and communication initiatives, and key statistics from our Whistleblower Channel. 

    Our approach

    Each day, Vale works to build a principles-based culture of ethics and integrity. Comprising seven elements (see the diagram below), our Ethics & Compliance Program takes a preventive stance by promoting ethical behaviour among all individuals working for Vale or acting on its behalf.

    The seven elements of our Ethics & Compliance Program 

    How we prevent > detect > and correct misconduct

    Click on the buttons below to navigate the page: 

    Governance 

    Autonomy, independence and tone from the top: Vale's Ethics & Compliance Program governance is structured to ensure that the entire organization is committed to our ethical principles.
    The Audit and Compliance Department is responsible for the Program. Reporting directly to the Board of Directors, and with further oversight from the Audit and Risks Committee, the department works in partnership with the Conduct and Integrity Committee.
    This governance structure is designed to ensure impartiality and prevent conflicts of interest. Through periodic external audits, the Audit and Risks Committee assesses Program effectiveness every two years and contributes to its ongoing improvement. 
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    Guidelines

    Translating our values into ethical principles and clear rules: this is the main objective of the Guidelines of the Ethics & Compliance Program.
    Acting with integrity is one of our values. Our Ethics & Compliance Program guidelines also include anti-corruption rules. Vale’s Global Anti-Corruption Policy is our primary source of guidance on anti-corruption, reaffirming our commitment to doing business with integrity. Our Global Anti-Corruption Manual additionally provides practical guidance to employees. Suppliers are required to comply with an Anti-Corruption Guide developed specifically for suppliers and other third parties. 
    We also share our values and ethical principles with our suppliers and other third parties through our Principles of Conduct for Third Parties.
    Acting with integrity is one of our values. Our Ethics & Compliance Program guidelines also include anti-corruption rules. Vale’s Global Anti-Corruption Policy is our primary source of guidance on anti-corruption, reaffirming our commitment to doing business with integrity. Our Global Anti-Corruption Manual additionally provides practical guidance to employees. Suppliers are required to comply with an Anti-Corruption Guide developed specifically for suppliers and other third parties.

    Key public documents that guide the ethical conduct of Vale and its third parties: 

    Communication & Training 

    Our ethical principles need to be communicated, understood and put into practice by everyone who works at Vale. This is the objective of the Communication & Training actions.
    For each audience, a different approach. Customization is an essential part of our Communication & Training strategy. With global initiatives and specific actions for employees who are more exposed to risks, the Ethics & Compliance Program seeks to guide everyone on how to make decisions in an ethical and responsible way.
    We provide annual updates on our training initiatives in our Ethics & Compliance Program Report. 

    Risk Analysis 

    Keeping track of the company's adherence to the Program Guidelines through controls, tests and continuous monitoring actions, we closely monitor the adherence of our company's processes to the Guidelines of the Ethics & Compliance Program.

    The role of each Line of Defense in our Ethics & Compliance Program​

    The 1st Line of Defense — which is  directly responsible for our operations or administrative functions—works to implement effective prevention and mitigation controls and ensure that corrective action plans are adequately established and implemented to continuously improve our risk management processes.
    Corporate Integrity works as a specialist 2nd Line of Defense in the management of Corruption Risk in our company. As part of this work, the Corporate Integrity area carries out a series of analyses on suppliers and third parties; external socio-environmental and institutional expenditures; conflicts of interest; gifts, travel and hospitality. We  have a methodology for continuously assessing the risk of corruption, which allows our monitoring, communication and training actions to be customized according to the level of exposure to risk in each area.
    Our Whistleblower Channel is part of the 3rd Line of Defense and is responsible for investigating allegations and providing impartial assurance, including on the effectiveness of risk management and prevention, internal controls and compliance functions.

    Monitoring and Control 

    Through controls, tests and continuous monitoring actions, we closely monitor the adherence of our company's processes to the guidelines of the Ethics & Compliance Program. All non-compliance identified is addressed with the first line of defense responsible for the process.
    How we manage the risk anti-corruption:

    15

    controls are part of our control map and enable us to manage the risk of corruption​

    05

    controls are considered key, are in Vale's risk matrix, and are related to the main risk analyses of the Ethics & Compliance Program

    Whistleblower Channel 

    Vale's Whistleblower Channel can be used by anyone, inside or outside the company, who wants to report a suspicion or violation of our Code of Conduct. 
    The channel is an exclusive platform for registering allegations, operated by an independent company and structured to guarantee: 
    For detailed figures on our Whistleblower Channel and information on corrective action taken, see our Ethics & Compliance Program Annual Report​.

    Respect Channel 

    Vale employees and contractors in Brazil and Canada also have access to a channel operated by a specialized, independent team, to provide support and advice to individuals experiencing harassment or discrimination. When contacting the Respect Channel, employees or contractors have the option to decide whether they wish to formally file an allegation for investigation by the Whistleblower Channel team.​
    Learn more about Vale’s Whistleblower Channel here. 

    Consequence Management​

    When misconduct is confirmed, we act with fairness and transparency,in accordance with our Consequence Management Policy.​
    Vale's Whistleblower Channel operates independently and confidentially to ensure allegations are investigated fairly. Disciplinary measures and corrective actions are taken for any confirmed cases.
    However, consequence management process is not exclusive to our Whistleblower Channel. It also applies to instances of misconduct identified in day-to-day operations. Consequence management is an additional tool for addressing ethical misconduct at Vale.

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