Our Commitment - Pudur Corporation

Our commitment

To Sustainable Growth

Pudur’s vision is to be a company that is admired and respected for delivering superior business value and for being the industry’s trusted partner.To earn this trust we must continually find safer, smarter, moresustainable ways to run our business. We are always looking for new answers to the complex global and local challenges we face.

Our Approach

Our Approach

Turning challenge into opportunity

“Resourcing the rising aspirations and demands of a growing global population is a challenging task, yet our metals and minerals are fundamental to progress and development.”

We operate in a complex and interconnected world where global and local factors bring both risk and opportunity to the design, development and management of our operations.Managed well, our activities can create positive impact: for economic growth, for employment, for infrastructure and local business development in our host countries – and to allow us to deliver sustainable value for our shareholders.

But downside risk also exists: for our activities to have a negative impact on people, on the environment, on stability in host economies – threatening our reputation and our ability to continue operating.
As a leading business in our sector, with a position we intend to preserve and improve, the challenges are clear. And the potential opportunities are also great – for Pudur and for our stakeholders.

It is our goal and our responsibility to turn challenge into opportunity through our commitment and contribution to sustainable development. This is how we do it.

The importance of trust The importance of trust

Sustainable development is central to our vision of being our industry’s trusted partner. Our stakeholders’ trust is essential for our business – their confidence in us helps secure our license to operate and gives us stability. In turn, we thrive, and can return greater benefits to our stakeholders and host countries.

To earn this trust we must find ever-smarter answers to complex global and local issues such as resource scarcity, climate change, community employment and regional development. We see social, environmental and economic challenges like these as opportunities to build our reputation as a trusted partner and create more value for our business, our shareholders and the people we work alongside.

Stakeholder Engagement

By constructively engaging with stakeholders locally, nationally and internationally, we are discovering what matters most to those around us.

 We face growing expectations from stakeholders. Our partners and investors are increasingly risk-sensitive. Governments and regulators are more conscious of the commodities sector. Lenders, NGOs, local communities and the media, amongst others, expect us to demonstrate that we are operating responsibly.

We learn a great deal through regular contact and in our day-to-day business dealings. We also engage more formally to identify stakeholder priorities, preferences and concerns as part of our materiality assessment process.

We are building a more robust and resilient business model by taking account of what matters most to our stakeholders.

Who are our Stake holders?


Our Customers and Our Partners

Human resources, CRM, data mining and social media concept - officer looking for employee represented by icon. Gender discrimination in employees selection.

Our customer base is a key constituency. As an international trading firm, we prosper by building relationships with producers and end-users that endure. For producers, we seek to provide enhanced returns from accessing global markets; for end-users, we set out to minimize costs and provide cost-effective supply of commodities at a time and place to suit them. We seek to serve all parties’ interests by optimizing safety, efficiency and reliability.


Governments

Perdana Putra, Putrajaya, Malaysia

Pudur’s worldwide activities bring us into contact with governments in numerous countries.  Whether in emerging or developed economies, our activities can have a big impact on economic and industrial development: we connect resource producers to the global economy, invest in infrastructure, feed power generation and fuel industry.

Host governments require assurance that we operate as a responsible business partner and respect the rights and interests of their citizens. They want to be sure that we are paying national tax at an appropriate level and that our activities do not disadvantage domestic businesses.


Local and Global Regulators

Local and Global RegulatorsRegulatory oversight covers a range of issues including safety, emissions, financial operations, compliance with sanctions, and anti-corruption controls.The framework for international regulation is continually changing. We need to be prepared for that and, where appropriate, contribute to public debate in developing policy areas.


Our Employees and Contractors

Our Employees and ContractorsOur Business Principles includes a commitment by all employees and contractors to value respect, fairness, non-discrimination, equal opportunity, training and development, and diversity within the workplace. We seek to engage with all employees and contractors to instill a collective sense of responsibility.


Non-Governmental Organizations

Non-Governmental OrganizationsCivil society and NGOs play an important role in encouraging social progress, environmental protection and democratic debate. They hold a critical lens to the commodities sector and to our performance at local and international levels.We are working hard to develop mutually respectful and beneficial relationships with the NGO community.


Our Communities

Our CommunitiesPudur undertakes large-scale, long-term investments globally. We often operate in remote and challenging locations. Our activities can have a significant impact on local communities. We aim to communicate our approach consistently, manage our impacts responsibly and create opportunities for shared value.


Financial Institutions

Financial InstitutionsPudur’s business could not function without the liquidity financial institutions provide. Their policies are subject to intense scrutiny and increased regulation. They require assurance that our systems and processes mitigate risk and reflect internationally accepted standards.


Educational Institutions

Educational InstitutionsWe take the view that improving theoretical understanding will have a positive impact on our sector and will help us in our ambition to recruit the best talent. We work with students and academic institutions to support research and build knowledge.


Global and Local Media

Global and Local MediaIn an age of social media and 24-hour rolling news, swift and accurate information is vital. There are numerous media outlets acting as conduits to the general public and to stakeholder groups. We aim to provide relevant, accurate and timely responses to requests for information.


Our Suppliers

Our SuppliersWe work with numerous suppliers to deliver our services globally. We operate robust systems and processes and require assurance from our suppliers that they take the same approach.

Human Rights

In everything we do, we respect the human rights of our people, host communities and partners. Our Corporation Human Rights Policy was created to enshrine this duty.

The opportunityThe opportunity

Our operations have many contacts with the communities in which we work. It is vital that we uphold the human rights of our people and our local communities, including vulnerable groups such as women, children, indigenous people and victims of conflict. This is particularly relevant in regions where our assets require additional security.

Our AmbitionOur ambition

To eliminate human rights abuses and uphold international standards within the company and throughout our value chain.

Our ApproachOur Approach

Our approach is aligned with the Protect, Respect and Remedy framework from the UN Guiding Principles on Business and Human Rights and the ILO Core Conventions.

The managers of our commodity departments and individual operations are responsible for ensuring that our people comply with our Corporation Human Rights Policy; their efforts are overseen by the Board.

A risk-based approach

Each of our operations is required to conduct a risk assessment at key phases of its lifecycle. This assessment is fundamental to our approach; it forms part of each operation’s risk register, and is overseen by its senior management, who also oversee human rights training

While varying by region, the risk assessment may cover:

  • Workplace-related risks, including discrimination, bullying, harassment or assault, or any form of child, forced, bonded or involuntary labor
  • Risk of conflict, particularly relating to security
  • Respect for the rights of communities, including vulnerable groups such as women, children, indigenous people and victims of conflict
  • Risk of human rights infringements by our business partners

Our operations also consider broader mining-related risks in the surrounding areas, such as those related to artisan mining, on a site-by-site basis.

 TrainingTraining

We conduct regular human rights training for our workforce. This ranges from focused training on the Voluntary Principles on Security and Human Rights for our security employees and contractors, to general human rights awareness during day-to-day activities for our wider workforce.

Working with business partnersWorking with business partners

The activities of our business partners, including suppliers and contractors, may also have an impact on the human rights of their stakeholders. To address this, our contracts with partners require them to maintain lawful business practices. Contracts with some partners require them to work in alignment with our Code of Conduct, our Global Anti-Corruption Policy and our Human Rights Policy.

We recognize that some local contractors and suppliers, particularly those in poor and remote areas, may struggle to meet our requirements at first. We also believe that ending our relationship with them is not a solution that helps to enrich our host regions. For this reason, our operations assess their local partners and develop an action plan to help them to meet our requirements. This might include capacity-building programmes, monitoring of performance and corrective actions. However, we will end our relationships with partners who do not make reasonable timely efforts to comply with our standards.

SecuritySecurity

Our procedures are aligned with the Voluntary Principles on Security and Human Rights (Voluntary Principles) as part of our Group Human Rights Policy.

Some of the countries where we work have a higher risk of security-related human rights abuses. We expect our people to avoid complicity in human rights abuses and uphold international standards at all of our assets, regardless of location or function. If security risks are identified, our assets must:

  • Screen security contractors’ human rights performance and their ability to comply with our policy
  • Ensure that we have contracts in place with private security service providers that reference the Voluntary Principles, and memorandum of understanding with public security providers that state our commitment to upholding human rights
  • Require or conduct training on human rights
  • Continuously monitor our security contractors’ performance, including meeting with local communities to understand how it affects them

 

Starting implementation of the Voluntary Principles

In 2015 we concentrated on implementing the Voluntary Principles in many countries. We identified local risks connected to private and public security forces and agreed on appropriate mitigation measures. We also began to formalise our relationship with the public security forces through memoranda of understanding that set our commitment to the Voluntary Principles, and our expectations of the security officers’ conduct whilst on our concessions. We have also reviewed and strengthened our approach to training and awareness-raising in these countries.

Developing Group guidance

In 2014 we reported on our review of security practices in regions with a higher risk of security-related human rights infringements. Following this, we have developed detailed Group guidance on engagement with private and public security providers. This is to ensure consistent alignment with the Voluntary Principles in our contractual and other legal agreements, deployment and conduct, and performance monitoring. This provided a framework to support our country-specific implementation programmes.

Our GrievancesOur Grievances mechanisms include

Community engagement and addressing grievances

We respect and support the rights of our host communities. We use our engagement with local communities to help inform them of their legal rights, to ensure that they can have meaningful participation in inclusive consultations and that we carry out any consultation and negotiations in line with local methods for decision-making.

Engaging with vulnerable groups

Some of our stakeholders have faced economic and social discrimination in the past. Many of them have histories where their voices have not been heard. Where possible, we create ways of engaging with local communities to include these groups. This might mean women-only consultation meetings, supporting cooperatives solely for disadvantaged groups such as former artisan miners or victims of conflict-related displacement, and engaging with indigenous peoples on their rights and cultural heritage.

We uphold the ICMM position statement on indigenous peoples and mining.

A number of our operations are located on or near indigenous people’s territories. We have formal land use agreements, including indigenous land use agreements in Australia and indigenous benefits agreements in North America. Elsewhere, we engage in open dialogue with indigenous communities. This includes regular community consultative forums for many of our South African assets but also focus groups, direct correspondence, newsletters and face-to-face meetings at various locations.

Grievance mechanisms

We require our assets to have grievance mechanisms that are accessible, accountable and fair, and that enable our stakeholders to raise concerns without fear of recrimination. Any allegations are investigated, and appropriate action is taken. In all instances, we collaborate with local authorities.

We seek to manage grievances using a risk-based approach and in line with the criteria developed by the UN Guiding Principles. At operations in stable jurisdictions that have a low impact on their host communities we use less formal mechanisms, while more robust mechanisms are needed where the rule of law is weaker, and where our potential impact is greater or will vary over time.

Health & Safety

We provide a safe and healthy workplace for all employees, contractors and visitors. We identify hazards, risks and unsafe behaviours. Where these cannot be eliminated they are appropriately mitigated.

Our ApproachOur Approach

Health and safety is of the utmost importance to Pudur Corporation. The protection and wellbeing of our employees, suppliers, contractors, partners and the communities within which we operate are non-negotiable priorities. We regard strong health and safety performance as fundamental for our sustained commercial success.

Our goal is to eliminate fatalities and prevent occupational injuries and disease. We have a robust, targeted approach. We work hard to eradicate risks or keep them to a minimum, whether they relate to our employees or to others carrying out or overseeing duties on our behalf. We comply with national and international health and safety laws and the specific requirements outlined in our Policies and Business Principles. We are meeting these commitments through strong governance at Group and operating levels, supported by external assurance. We focus on skills development and risk management, and share good practice across the organization.

Our SafetyFirstOur SafetyFirst initiative

Our SafetyFirst initiative provides a framework for creating individual safety cultures across our diversity of geographical locations, working conditions, organizational cultures and workforces. The overall message is that every single individual should use their authority to stop unsafe work: “Safe Work or Stop Work.” The fundamental components of SafetyFirst are:

  1. Fatal hazard protocols: these address Pudur’s most common causes of fatalities and serious injuries
  2. Life-saving behaviors: these encourage focus on critical hazards (those with the highest potential for serious injury or fatalities) and the safety behaviors that mitigate them
  3. Supporting tools: these include risk awareness training, virtual reality training materials on each fatal hazard, and other training aids; they are available via our intranet with hard copies distributed in regions with poor internet access
  4. Empowering first-line supervisors: we expect them to take responsibility for their work areas, manage technical safety aspects, such as wearing PPE, and motivate safe behavior

Our departments have embraced SafetyFirst and are adapting it to suit their assets and locations, in consultation with the relevant stakeholders.

Society

We aim to be good corporate citizens, and engage respectfully with communities in which we work. We respect human rights and seek to contribute to the long-term social and economic development of communities affected by our activities.

Our ApproachOur Approach

Pudur is committed to respecting human rights across all of its business operations and value chain activities. Our approach is enshrined in our Policy and Business Principles and is informed by the UN Guiding Principles on Business and Human Rights amongst other internationally recognized standards. We require business partners to apply comprehensive, comparable and complementary policies and principles.

Physical trading remains the core of our business. With a significant fixed asset base in developing economies, we are acutely aware of the impacts of our operations on nearby communities. Understanding local contextual issues and engaging respectfully in our operating environment is critical to maintaining our social license to operate.

Our activities stimulate socio-economic development in local communities and for their national economies. We create employment, develop skills, build infrastructure and procure from local suppliers. At the same time we recognize that our activities can also have an adverse impact on local communities and their way of life. We seek to minimize or mitigate such negative consequences.

 ResettlementResettlement

We seek to avoid resettlement wherever possible.

When it cannot be avoided, we proceed in accordance with the International Finance Corporation (IFC) Performance Standard 5: Land Acquisition and Involuntary Resettlement. We focus most on ensuring transparency and accountability and making sure that the community affected is able to participate in planning.

After re-settlement we have programmes for restoring livelihoods, and we carry out ongoing monitoring.

Economic ValueEconomic Value

Creating societal valueOur business activities make a significant contribution to the national and local economies in which we operate. We ensure that these benefits come from all points on our value chain, with the most significant ones stemming from employment and procurement.

To help us measure our socio-economic contributions on the ground, and report on them consistently, we are developing a social value creation scorecard. This will allow us to consistently measure each operation’s contribution to social value through our five core activities.

Our commitment to transparencyWe support transparency in the redistribution/reinvestment of these payments and are active participants in the Extractive Industries Transparency Initiative (EITI). We believe that the EITI fosters open and competitive markets.

Managing ImpactManaging Impact

Addressing complaintsWe know our operations may have a negative impact on the surrounding communities. We identify impacts in many ways, including through environmental and social impact assessments, stakeholder analysis and complaints mechanism.

Issues must be recorded in each operation’s risk register, and updated at every stage of the operation’s lifecycle.

Our complaint proceduresOur complaints mechanisms are important for finding out about community concerns, allowing us to fine tune our operational approach to minimise problems.

Common topics of complaint in recent years are noise, odour/fumes and dust from our natural resources operations.

We make significant investments in noise attenuation, upgrading our equipment whenever relevant improvements arise. We address specific odour-related problems and generally make continual improvements to our emission monitoring and management. With regard to dust, our management activities include wetting down roads, washing vehicles before they leave sites, and covering truck loads.

Local employment & procurementLocal employment & procurement

Our principal contribution to our host regions is through employment, both directly and via contractors. Our impact is particularly significant in developing countries, where our local employees can have as many as nine direct dependents. Improving the prosperity of our workforce also funds a general uplift in local economies, resulting in further job creation.

We are committed to employing locally wherever possible, and we invest in training to ensure that our local employees can build their careers.

 Local suppliersLocal suppliers

We use local suppliers wherever possible, as this is cost effective and helps communities to reduce their reliance on our operations for employment. It is also an important building block for the development of local economies; in some countries, national development objectives determine procurement requirements for each region.

We have identified Pudur operations with limited numbers of local suppliers. We are working with those communities and local government representatives to support local business development. We offer targeted training on business management skills, underwrite credit applications and guarantee future business within specific limits.

We also encourage our large international contractors to develop local partnerships to transfer skills and build capacity locally.

Our People

We maintain a working environment based on integrity, ethical conduct, equal opportunity and mutual respect.

Our ApproachOur Approach

At Pudur, we have built up a distinctive culture that binds our global organization and drives performance across regions and disciplines. Being able to recruit, retain and develop skilled and high performing people is critical to maintaining our competitiveness.

Respect, diversity and competitiveness are fundamental tenets. We strive to create an environment in which people flourish and maximize their potential. To do that, we set high standards – for ourselves and for those that support us in our day-to-day activities.

Pudur people have an entrepreneurial outlook. They are recognized for their reliability, efficiency and sense of responsibility. Their focus is on delivering and sustaining growth.

Our decentralized structure devolves decision making to give individuals significant autonomy. Robust systems and processes support a culture of accountability and control. It is a combination that motivates staff, promotes responsiveness and allows teams to operate effectively across diverse businesses, different cultural norms and varying socio-economic conditions.

Our approach to managing our people and our contractors is enshrined in our HSEC Policy, our HSEC Business Principles, and our Code of Business Conduct and employee handbooks.

Pudur’s Human Resources team oversees our people strategy on behalf of the Group. The Chief Human Resource Officer reports to Pudur’s President who sits on Pudur’s Management Board.

 Protecting our peopleProtecting our people

We aim to help our people stay healthy. We are often the largest local employer, so providing support is the right thing to do, as well as making good business sense.

Well-being programmesMany of our sites have established well-being or “fit for work” programmes, which target mental and physical health issues such as obesity, smoking, stress and depression.

Public health programmesOur operations are often sited close to communities with limited healthcare. Local health services might be in the early stages of development, or local authorities may not have the resources to cope with the scale of need.

We work with local authorities, local community representatives and other partners, such as NGOs, to help to overcome major public health issues in the regions where we work, such as HIV/ AIDS, malaria and tuberculosis.

HIV/AIDSWe recognized the actual and potential impact of HIV/AIDS nearly 25 years ago. Research showed that if companies helped tackle this disease, it would not only reduce sick leave and improve life expectancy but that sufferers could live normal lives while receiving treatment. This led to Pudur drawing up an HIV/AIDS intervention strategy with very specific targets. We encourage our people to find out their HIV status, and our HIV-positive employees to get treatment.

 DiversityDiversity

We believe that diversity is essential to our business; we aim to employ work forces that reflect the demographics of the communities in which we operate.

We prohibit discrimination on the basis of race, nationality, religion, gender, age, sexual orientation, disability, ancestry, social origin, political or other opinion, or any other bias. We do not tolerate any form of racial, sexual or workplace harassment.

Achieving gender diversity is a major challenge, as many of our operations are geographically remote and employ shift working. In these regions, we focus on maximizing local employment to contribute to the local economy, rather than on our gender balance.

Gender diversityOver 70% of our corporate employees are women. Our corporate offices have family-friendly policies and work with our people to accommodate their family commitments. Our industrial operations have a number of initiatives in place to encourage and support women in traditional and non-traditional roles.

All our sites comply with, and often exceed, their national legislation on parental leave and flexible and part-time working. We consider requests for job-sharing when possible, and when an employee is pregnant or breastfeeding we accommodate this as far as is appropriate.

Local EmploymentLocal Employment

Many of our industrial operations are very near to local communities, and we are acutely aware of the impact we can have when we expand or reduce our workforces.

Most of our marketing and industrial operations have established targets to provide high-value employment for local people. This may include in-country employment, with appropriate training and mentoring opportunities (particularly in industrial assets), and opportunities to work at our Malaysia headquarters or elsewhere in the world (particularly within our marketing activities).

Local skills developmentOur assets consider how best to replace ex-pats with local employees, supporting local socio-economic development. Skill requirements are assessed for each job and a gap analysis identifies the training needed to equip local employees to skill-up. Training is tailored so each employee can acquire the lacking skills needed to do the work efficiently and safely. We hold “introduction to Pudur” sessions at some of our regional offices to build awareness of Pudur at local schools and universities and encourage applications.

In-role trainingNew employees go through the training required by their job profile, which includes sustainability considerations before they start work. We are committed to ensuring all our employees become functionally literate and numerate.

Engagement & retentionEngagement & retention

We continually work to actively engage with our workforce about many topics, including safety, personal health and advancement opportunities. Whenever there are significant organizational changes, like closures, acquisitions, mergers or divestitures, we consult and communicate with our people and provide support when they need it.

Supporting our peopleWhen we are forced to close an asset, either because it has reached the end of its viable life, or due to market conditions, we work hard to minimize the impact on its workforce. We try to work with governments and union representatives to develop strategies to help those employees. We give career advice and work with employment counselors to draft resumes and prepare for job interviews. We also liaise with our peers in the region to identify potential job opportunities.

Our job vacancies are advertised internally; our HR teams use this list to suggest redeployment opportunities. In addition, we may look for vacancies at operations near to the assets affected and offer jobs to employees with the right skills. In South Africa, we have helped a number of our underground operators retrain to work in our opencast mines.

Grievances and conflict resolutionWe require employee grievance and conflict resolution mechanisms at all operations. We follow due process for grievances to make sure that any serious conduct, performance or treatment issues are dealt with fairly. This includes giving individuals the opportunity to tell their side of the story before any final disciplinary decision is made.

Retention & developmentWe encourage our businesses to develop succession planning and retention strategies that best reflect their local working environment. This means that there are different approaches used in different regions, but some include:

  • Regular reviews matching the current talent pool against future business requirements, followed by strategies to fill any gaps; this includes identifying skill gaps in the “next level down” and training our people for the roles above theirs, to build competencies
  • Implementing a talent and succession planning process to help build a division-wide view of talent, and plan for the replacement of leaders and critical roles
  • A leadership development programme where hand-picked individuals take part in six months of structured training
  • External leadership training courses for individuals identified in annual performance reviews, with the possibility of studying up to a masters level with financial support and study leave
  • An online database tracking upcoming critical gaps in the workforce, to allow current employees to develop the appropriate skills; it is also used to post short-term opportunities and prioritize transferring current employees before hiring external consultants or contractors
  • Supporting “fast trackers” with leadership skills and management competencies
  • Using short-term international assignments to help our talented people (this also helps disseminate technical and organizational experience throughout the Company)

Environment

We are committed to minimizing the impact from our business operations on the natural environment.

Our ApproachOur Approach

We require that the planning, design and operation of all corporation activities and facilities explicitly consider and target environmental risk in its many forms.

For those divisions and subsidiaries that operate industrial assets, our goal is to eliminate or mitigate any adverse environmental impact and maximize the opportunity to improve environmental conditions. This requires the maintenance of environmental management processes and systems appropriate to the products we handle and the activities we undertake. A number of our existing facilities are certified to the International Standard ISO 14001, the world’s most recognized framework for environmental management systems.

For Pudur, mitigating adverse impact also means investing in and exploring alternatives to traditional and more polluting forms of transportation: alleviating logistics bottlenecks and in so doing reducing carbon emissions. In the design and construction of new facilities, adaptation to meet the reality of climate change has become standard.

We support policies that address climate change without damaging society’s ability to meet the growing demand for secure, affordable energy and vital natural resources.

Pudur is committed to setting indicators and targets to further enhance our management and reporting against environmental impacts, improvement measures and achieved performance.

Climate change & energyClimate change & energy

As national economies grow, so does global energy demand. The need for secure, affordable energy is universal; it is a pivotal factor for nations to achieve their socio-economic goals. In the developing world, access to energy is key to improving living conditions, education, healthcare provisions and economic development.

Public policy and transparencyWe believe that fossil fuels will continue to play a significant role in the global energy mix, but we also recognise that producing and using these fuels contributes to greenhouse gas (GHG) emissions. Climate change issues are now part of the political, societal and regulatory landscape. Companies, governments and society must work together to find realistic ways to reduce global GHG emissions at the lowest possible cost.

We are committed to playing a constructive role in the development of public policy for climate change and energy; an important part of this is engaging with stakeholders and supporting constructive and informed public debate.

We openly and transparently disclose our carbon and energy footprints and participate in the CDP Climate Change programme.

We divide our CO2 emission reporting into three different scopes, in line with the Greenhouse Gas Protocol. We measure direct and indirect emissions generated by the assets, entities and facilities in which we have a controlling stake.

Mitigating the effects of climate changeWe work to mitigate and manage any physical impacts of climate change that we can affect. Our assets continually assess their emergency preparedness, which include preparations for extreme weather events. Where such events are expected to increase in frequency, our operations update their design.

Reducing emissionsWe also work to reduce the GHG emissions from our industrial activities in many ways, including the use of waste for power and cooling. Wherever we operate, we seek to manage our energy and carbon footprint.

We actively support the development of low emission technologies and prioritize renewable energy sources where practicable.

EnergyMany of our assets use energy intensively; it is a significant component of our total operational costs. As such, we aim to continually improve energy efficiency across the Group. Our commodity businesses have bespoke energy efficiency plans and carry out regular energy audits.

Land ManagementLand Management

We own large areas of land around the world; some of our operations are in environmentally sensitive areas. Responsible land stewardship throughout our operations’ lifecycles can influence our legal and societal license to operate. It also reduces our operational risks and mine closure liabilities.

We make efforts to recognize the cultural heritage of local indigenous people when planning our operations, as we understand that they may have a unique connection with the land.

Protected areasWe respect legally designated protected areas and adhere to associated regulations. Our extractive and agricultural assets do not explore or mine in World Heritage areas. Our operations work to avoid the loss of any International Union for Conservation of Nature (IUCN) Red List threatened species.

We run conservation programmes in areas with complex, vulnerable wildlife ecosystems, ranging from first-aid for wounded or trapped animals, to protective enclosures, to breeding programmes. We also work with local communities to establish patrolling or ranger programmes to protect wildlife.

Environmental impact assessmentsOur operations incorporate biodiversity considerations into their environmental impact assessments, along with any risks that our impact on biodiversity may have for local communities. When the opportunity arises, we disseminate scientific data and promote practices and experiences in biodiversity assessment. We support the development and implementation of scientifically sound, inclusive and transparent procedures for integrated approaches to land use planning, biodiversity, conservation and mining.

Rehabilitation and closureWe are committed to ongoing rehabilitation at our mining operations; we generally store and reuse topsoil either nearby, or in progressive rehabilitation. We maintain topographical data to minimize impact on the landscape. Where appropriate we also identify any threats to the area’s biodiversity and help protect species that could be affected. We engage with local communities to identify appropriate closure procedures and ensure that closure activities happen in accordance with appropriate post-mining land use.

Agricultural landWe are committed to minimizing the environmental impact of our land cultivation while maintaining its long-term productivity. In 2014, we joined several global initiatives researching precision agriculture technologies and other agronomic improvements.

Air PollutionAir Pollution

Wherever we operate, we comply with relevant regulatory limits and international standards for air emissions.

We are continually investigating new initiatives to reduce fugitive dust emissions and to reduce or eliminate stack emissions.

Our open cut operations emit dust (also referred to as particulate matter or PM) from excavation and movement of material. We monitor dust levels at affected communities and minimize dust in a number of ways that includes construction of berms to prevent dust travelling to communities, optimizing our blasting activities, watering our haul roads and using protective coatings on waste storage facilities.

Water ManagementWater Management

Water is an essential input for all our activities, and we ship petroleum products and crude oil, plus vegetable oil, ores and concentrates, over maritime and inland waterways. This makes protecting maritime and inland waters, and maintaining access to high-quality water, our key water-related sustainability challenges.

We prioritize efficient water use, water reuse/recycling, responsible waste water disposal and maintaining any equipment that might pose a hazard to water quality. We engage with local water users to avoid material adverse impacts on the quality and quantity of local water sources or compromising their access to water.

Dealing with water risksWe have identified water as a material risk at a number of our assets. The challenges they face include water scarcity, managing surplus water from storms and ensuring water quality. These all carry the additional risk of increasing costs for our assets.

We have analysed each asset’s location using the World Business Council for Sustainable Development water tool, which defines water stressed areas as having less than 1,700m3 of water available per person per year. The results show that about half of our operations are located in water stressed areas: 17 are in regions of “extreme scarcity,” 64 of “scarcity” and 11 of “stress.”

Developing our approach – During 2015 we used these considerations to create a Group water strategy, with five primary objectives:

  1. Identification and assessment of our material water impacts, risks and opportunities
  2. Gaining an understanding of our water footprint
  3. Development and implementation of water management plans covering each of our assets’ lifecycles to avoid, minimize or mitigate the impacts and risks
  4. Improvement of our water management performance, including identifying and setting water-related targets
  5. Ongoing engagement with significant stakeholders and public reporting on our progress

Over the next three years, we plan to focus on:

  • Developing and implementing a water management framework that is appropriate for our assets; each asset’s risk profile will determine the stringency of requirements that applies
  • Aligning our current water metrics and definitions with applicable reporting standards (e.g. GRI, ICMM, CDP Water, the Water Accounting Framework)
  • Introducing an appropriate water balance tool to help high risk assets use a standard approach to reporting water use
  • Developing consistent water quality indicators, aligned with relevant international standards
  • Collating existing case studies on sound water management practices (e.g. flood management, water diversion, water efficiency methods and technologies) from around the Group; sharing the results amongst our assets

Managing water scarcity – Where water availability poses significant environmental risks, we require assets to implement water management plans, set water intensity targets and execute water efficiency measures. We develop these plans in collaboration with local communities and other stakeholders, according to the site’s specific operational and environmental context. The individual measures taken to manage water scarcity vary and depend on local specifics, but include:

  • Reducing water loss via evaporation
  • Replacing purchased water with waste water from other organizations
  • Researching new sources of water (e.g. desalination)
  • Deepening water storage dams to improve storage capacity
  • Establishing water efficiency committees within certain assets
  • Improved tailings management (e.g. setting targets for water recovery from tailings)
  • Employing best-practice agronomic techniques that improve water-use efficiency

Responsible use of the water we withdraw- Our mining and agricultural operations prioritize water reuse and recycling wherever possible. We work on a regional basis with local communities, authorities, agricultural and other industry users to develop and implement water use strategies that ensure sustainable, equitable access and proper water management between all the stakeholders in the catchment area.

Some of our underground mines have a high water content and require ongoing de-watering. We work with local communities and utility providers to use this water to help meet local needs.

Our agricultural products business is taking a number of steps to recycle and reuse water. These include reducing potable water consumption through reuse of process water and using industrial water as an alternative water source.

Preventing water contaminationWe dispose of our waste water responsibly; we are diligent in maintaining the integrity of equipment that may pose a hazard to water quality. Depending on the type of operation and requirements we treat waste water with processes that include pH neutralization, the removal of heavy metals, suspended solids, oils and greases. We carefully monitor water discharge at the point of discharge as well as at the receiving bodies such as rivers and estuaries, to ensure that the quality of the discharged water will not impact local water quality and the natural environment. We are implementing new technologies to help minimize or eliminate uncontrolled water discharge.

Marine water contaminationOur marketing operations maintain a large fleet of chartered vessels. To avoid spills and water contamination, we have minimum requirements for the vessels we own. Our chartered vessels are vetted in accordance with our chartering standards. The vessels we use are double-hulled, an important measure to prevent leakage.

In the unlikely event of a spill, our emergency response plans are designed to minimize damage.

Our operational and maintenance procedures are aligned with relevant international standards, including the OCIMF/ICS guidance and MARPOL regulations and the Ballast Water Management convention for all ballast water exchanges.

Waste managementWaste management

To avoid or minimize any adverse impact on the environment or our surrounding communities, our operations continually review their waste management and identify opportunities for improvement.

Types of wasteMost of our waste is mineral; this includes tailings, slag and rock. Our operations have rigorous waste management systems to dispose of waste while preventing environmental contamination.

Our natural resources assets generate tailings, which are stored in purpose-built tailing storage facilities. The tailings are placed in specially designed ponds filled with tailings and water; over time, the water evaporates while the tailings settle, eventually filling the dam. At this point, the dam is capped, sealed and rehabilitated.

Reusing wasteWe reuse as much waste as possible. For example we use waste rock to backfill our mines, and fill roads with non-hazardous tailings.

Protecting tailingsOur tailings facilities are monitored continuously to ensure integrity and structural stability. Flooding and seismic activity are the main natural phenomena that may affect them.

 BiodiversityBiodiversity

The rate of biodiversity loss remains a serious global concern as the human population grows and competes with habitats containing the world’s remaining biodiversity. Our activities have the potential to adversely impact biodiversity and this generates significant interest with key stakeholders, including government, local communities and non-government organizations (NGOs).

Pudur has long recognized the importance of sound biodiversity management and has had a biodiversity strategy since 2012. The strategy requires that all sites understand their biodiversity risk and impacts. Those sites deemed to pose high or very high risk to biodiversity must develop an action plan to help understand and minimize impacts, and, where appropriate, implement actions to achieve a net positive impact (NPI).

It’s important that any strategy maintains its relevance, and in 2014 we undertook a review of our biodiversity strategy, taking into account our many years of implementation experience and the views of our stakeholders.

Carbon Policy

We are committed to reducing our Carbon Impact and are currently working towards global targets. The management of our carbon emissions is a long term commitment by Pudur Corporation and supports our beliefs of making tomorrow a better place. This policy statement represents our environmental stance and the practices we apply when conducting business.

Our commitmentsOur commitments

We are dedicated to reducing our carbon footprint and working towards better environment, with an overall aim of reducing the negative impact that our business activity has on the environment. In order to achieve this we are committed to:

  • Evaluation of alternative fuel to ascertain their potential benefit to the fleet
  • Using Public Transport all the time, this mean disposing of all our entire private jet fleet
  • Work @ Home policy for the staff
  • Using solar or wind energy for our power needs wherever possible
  • Ensuring vehicles are properly maintained – poorly maintained vehicles have higher fuel consumption and toxic emission levels
  • Identifying opportunities to reduce mileage by recording and analyzing business travel, incorporating fuel efficient driving principles
  • Promote safe, economic and environmentally friendly training
  • Ensuring mileage reimbursement rates and travel allowance rates are environmentally sensitive and do not encourage drives to make excessive journeys
  • Promoting satellite navigation and telematics to help drivers avoid congestion and utilize the most efficient route to reach their destination
  • Utilizing locally based staff to reduce time on the road
  • Policies to manage the added risks, costs and environmental impacts of our global fleet
  • We will work in partnership with our clients and supply chain partners to assist them in achieving sustainable working environments and supporting their sustainability innovations

TargetsTargets

In order ascertain the impact of our Policy we have in place a number of targets:

  • Reduction in C02 of 90% by 2020 by better transport planning and tracking devices.
  • Decrease electricity use by 50% in the office through the use of ‘go green electricity campaign’.
  • Reduction in waste paper by 90%; through our paperless office policy

Stewardship

We aim to deliver competitively-priced commodities that meet our stakeholders’ needs and add societal value around the world, while progressively reducing any risks associated with the use of our products.

The opportunityTo deliver high quality products, quickly, consistently and at a competitive price, to our customers around the world.

Our ambitionTo understand and manage any health, environmental and social impact associated with our products, to pass this information along the supply chain, and ensure our continued license to market them.

 Our ApproachOur Approach

We are committed to fully understanding the health, environmental and societal impact of our products; this is enshrined in our product stewardship policy. It improves our knowledge of our products’ qualities, which is reflected in how we produce, transport and store them. We promote this knowledge by participating in industry consortia and regulation development, and through engagement with our customers.

We help our stakeholders understand our productsWe have worked with experts, industry consortia and our peers for many years, to improve understanding of our products’ properties and their impact throughout their life-cycle. This helps us to ensure their compliance with international standards, including REACH. We capture this information in material safety datasheets, which we have developed for all our products and that reflect the classifications developed by consortia such as REACH, ECHA and others.

Using our safety datasheetsWe have produced over 6,000 datasheets, including variants for different languages and legal entities, held in a centralized database that is fully integrated with the systems used by our marketing and sales teams in many regions. In these regions, when one of our marketers attempts to bring a product without REACH clearance into a port, our product stewardship team receives an automatic alert. We require sufficient information to check the product before shipping can take place. The database also automatically issues the correct datasheet to each customer on purchase. Datasheets are available in all 41 official languages and, where appropriate, additional languages such as Mandarin, Japanese and Korean.

Ensuring integrated product management throughout our value chainWe are committed to addressing product safety considerations in all our extraction and production processes. This includes efforts to minimize greenhouse gas (GHG) emissions at all our assets and to maximize reuse of our waste products.

A coordinated approachOur industrial assets work closely with our marketing teams; our traders regularly visit industrial sites, and we promote the development of cooperative networks to ensure the concept of life-cycle management is incorporated in all phases of production and marketing. Our traders also meet with our customers regularly to share process safety and good practice advice.

Minimizing wasteThe relationships our traders build with our customers provide opportunities for waste minimization on a global scale. Our traders work with each site to ensure our production levels match market demand and stakeholder need, helping to minimize waste. We track supply and demand across our global resource portfolio to help optimize the quality of our products and maximize resource recovery. Tracking demand helps us blend materials and manage concentrate quality to optimize smelter efficiency and reap significant cost savings.

Safe UseSafe Use

We share understanding of our products’ value chains and associated risks with our peers, customers and other stakeholders. We help our customers implement their own material stewardship strategies, inform them of regulatory decision-making and generally help minimize risk to human health and the environment.

Helping customers with regulatory complianceFor instance, we provide clients in the US electronics industry with documented evidence showing that our products are free from minerals sourced from conflict-affected and high-risk areas. This helps them ensure their compliance with the Dodd-Frank Act. We provide similar evidence to support compliance with other legislation, such as the ROHS directive and REACH.

RegulationRegulation

We actively engage with key stakeholders regarding regulatory developments that impact product stewardship.

Conflict minerals – European legislation – Following the implementation of Dodd-Frank’s Section 1502 on conflict minerals in the US, the European Union is currently investigating and debating whether similar legislation should be developed in Europe. We are engaging with members of the European parliament, policy advisers and member state representatives specifically on this topic.

Our discussions have focused on the scope of reporting: the minerals and regions to be included in any future reporting requirements. We are advocating an approach that reflects both existing regulations and voluntary initiatives. We believe that any EU legislation should not go further than the minerals covered by the Dodd-Frank regulation and other schemes, such as the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains for Minerals from Conflict-Affected and High-Risk Areas. Developing conflicting regional legislation will complicate and potentially undermine the impact of responsible sourcing schemes.

Setting the scope for sourcingIt took time to develop the existing sourcing mechanisms for tantalum, tin, tungsten and gold (referred to as 3TG) and the corresponding OECD due diligence supplements. It will take even more time to ensure these schemes become fully operational. Covering additional minerals and regions would, in our opinion, be counter‑productive.

A global approachWe believe that the challenges of responsible sourcing from conflict-affected areas are global; a global solution is required to address the situations that lead to conflict. Any legislation or guidance developed by the European Union should not create suspicion of companies that use raw materials from conflict regions and a de-facto trade embargo for minerals from areas affected by conflict. A blanket ban on minerals from conflict‑affected regions will not address the conflict and will lead to increases in unemployment and social unrest, as well as the deterioration of peoples’ livelihoods.

Transparency

We believe that transparency comes in many forms – from being open about financial performance, to driving deeper stakeholder engagement, to improving monitoring and reporting within the organization and across our supply chain.

We take the view that transparency is indispensable in our corporate responsibility journey. There are increasing demands for greater disclosure of payments to governments by commodity trading firms as well as mining companies and upstream oil producers. Disclosure can assist in improving governance in resource-rich countries.

As a major facilitator of global business, we also believe that natural resource wealth should be an important engine for economic growth that contributes to sustainable development and poverty reduction. Being open about how we manage natural resources gives the populations in countries where we operate the tools to hold governments and business to account.

Our Conduct

Pudur is committed to doing business in accordance with high standards of ethics and integrity. All our employees are required to abide by our Code of Business Conduct.

It is a commercial imperative for Pudur that our business is, and is seen to be, one that acts with integrity and maintains high ethical standards. Our management teams work together with Compliance, Legal, Human Resources and Corporate Affairs departments to promote ethical behavior amongst our employees and contractors.

Pudur is a global company, which operates within the European regulatory framework. We are constantly evolving our business model to adapt to shifting cultural norms, geographies and regulatory regimes. There is a strong sense of common endeavor at Pudur, and the company’s owners also work in the business. There is a shared understanding that the risks facing the Group affect us all.

Our Code of Business Conduct is a cornerstone of Pudur’s approach. It defines what is expected of our business and our people. It promotes good business judgement and compliance with relevant laws and regulations.

We have adopted five key principles that define the way we conduct ourselves worldwide. Our Compliance Department develops global systems and safeguards to ensure we adhere to these principles wherever we operate.

  1. Integrity: We are honest and straightforward in all our business dealings.
  2. Care and diligence: We conduct and manage our business with due skill, care and diligence.
  3. Best practice: We develop compliance procedures that meet best practice standards, not just minimum legal or regulatory requirements.
  4. Market conduct: We ensure our business dealings are conducted in accordance with the highest standards of market conduct.
  5. Management and control: We put appropriate procedures in place to manage and control the business effectively and meet the requirements of our Code of Business Conduct.

Supporting Development

We are a major investor in the developing world. Wherever we operate, we make a commitment to create value in a sustainable manner. Our objective is to have a sustainable and positive impact on the communities in which we operate. We undertake and contribute to activities and programmes designed to improve quality of life for the people in these communities. 

Delivering long-term sustainable benefits to local communitiesSuccessful and sustainable investment is critical to improving the living standards in developing countries. We employ or contract around 13,800 people, support local businesses and service providers, and invest extensively in local education, healthcare and infrastructure. During 2015, we contributed $16 million to initiatives that directly and indirectly benefit the communities living close to our assets.

Working in collaboration with governmentsThe issues of wealth distribution, public service provision and poverty reduction matter to Pudur, but go far beyond the capacity or proper remit of any company in any particular country. These matters are of concern to us all, but we recognize that their resolution can only be achieved by the legitimate governments of those affected countries and the properly constituted international agencies within whose remit these matters lie.

We acknowledge that through our presence in developing countries we have a role to play in bringing about long-term improvements both to society and the economy. Through incremental change, we are raising standards at our assets and we will continue to make progress via our leadership in this area.

Local employment and local procurementWe prioritize employing people who live in the regions where we work and we invest in education projects, skills development programmes and apprenticeships for local people. Local employment is one of the most obvious signs of the economic benefits we supply to our host countries, especially as many have comparatively high unemployment rates.

We aim to buy locally where possible. We prefer to use local contractors and suppliers for services, including for maintenance, catering, transportation and basic construction materials. We pay commercial rates within agreed timescales. We work with local suppliers to help them meet our quality and compliance standards. We invest in enterprise development to help local people to provide goods and services.

We work with governments to improve transparency of revenue flows and to strengthen governance of these funds for local, regional and national development. We support fiscal transparency via our endorsement of the Extractive Industries Transparency Initiative (EITI). Our latest submission detailing our activities in participating countries can be found on the EITI website.

 

Education Partnership

We take the view that improving theoretical understanding will have a positive impact on our sector and will help us in our ambition to recruit the best talent. We work with students and academic institutions to support research and build knowledge.

Many of our industrial operations are very near to local communities, and we are acutely aware of the impact we can have when we expand or reduce our workforces.

Most of our marketing and industrial operations have established targets to provide high value employment for local people. This may include in-country employment, with appropriate training and mentoring opportunities (particularly in industrial assets), and opportunities to work at our Malaysia headquarters or elsewhere in the world (particularly within our marketing activities).

Local skills developmentLocal skills development – Our assets consider how best to replace ex-pats with local employees, supporting local socio-economic development. Skill requirements are assessed for each job and a gap analysis identifies the training needed to equip local employees to skill-up. Training is tailored so each employee can acquire the lacking skills needed to do the work efficiently and safely. We hold “introduction to Pudur” sessions at some of our regional offices to build awareness of Pudur at local schools and universities and encourage applications.

In-role trainingIn-role training – New employees go through the training required by their job profile, which includes sustainability considerations, before they start work. We are committed to ensuring all our employees become functionally literate and numerate.

Tax Transparency

Our verticals are mostly long-term businesses. Any development project is highly capital-intensive, with many years before returns are generated. Our investment decisions are affected by each host country or region’s competitiveness and suitability as a long-term mining destination, due to the stability of its regulatory and fiscal framework.

Payments to governmentsPayments to governments

Taxes and royalties are direct annual cash contributions made to our host governments. Tax is paid on the income generated within the country and royalties are paid as a percentage of either the revenue or volume of the natural resource extracted and sold. Payment levels are determined by the national, regional or local government for each operation in accordance with the provisions of local laws and regulations. The payments we make often represent a significant source of income to those countries and regions.

Creating value for societyCreating value for society

Pudur’s socio-economic contribution creates the most significant value in the developing world. If we were not present in these countries, there would be fewer sources of employment, far lower payments to local suppliers, and often significantly lower tax revenues. Our reach also extends beyond the contributions of our operations and employees through our support for local procurement and service providers, education and health initiatives and development projects that deliver sustainable benefits to our local communities.

Other taxes and paymentsOther taxes and payments

In addition to income-based taxes, we are responsible for other, non-income based taxes, which, amongst others, may include licence fees, property taxes, capital taxes, withholding taxes, export taxes, employer-related payroll taxes and other tax payments, as required by the applicable domestic tax laws.

We engage with a variety of stakeholders on a range of tax-related issues. We build and maintain partnerships with tax authorities and work together to address any disputes.

Supporting transparency and EITISupporting transparency and EITI

We support increased transparency as to how payments are redistributed and or reinvested in our host communities. We are active participants in the Extractive Industries Transparency Initiative (EITI), an extractive industry sector initiative promoting good tax governance, accountability, transparency and the prevention of corruption through the verification and full publication of company payments and government revenues.

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