Code of Conduct: Governance, Ethics, Sustainability for Rio Tinto

This report provides a detailed analysis of Rio Tinto's Code of Conduct, a comprehensive document outlining the company's commitment to ethical business practices, governance, and sustainability. The report begins with an introduction to the code, emphasizing its purpose and applicability to all stakeholders, including employees, directors, and contractors. It then delves into the core values of Rio Tinto, which include safety, respect, teamwork, excellence, and integrity. The report further explores the company's principles, covering compliance with laws, anti-discrimination policies, and measures to prevent exploitation and corruption. It also examines the company's stance on dishonest and fraudulent behavior, detailing practices to ensure honesty and integrity. Finally, the report highlights the importance of whistleblower protection, outlining procedures for reporting unethical issues and the roles of various officers in safeguarding whistleblowers. The report concludes with a discussion of enforcement mechanisms and contact details for reporting concerns, demonstrating Rio Tinto's commitment to upholding its code of conduct.

Running Head: Governance, Ethics and Sustainability
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Governance Ethics and Suitability
Student’s Name
12/30/2018

Governance, Ethics and Sustainability 1
Code of Conduct
Introduction
The manner of our work stipulates how we fulfill our promises and deliver the best results to our
every stakeholder. The code of conduct presented hereby is a public statement that Rio Tinto
Limited is committed to deliver the right and best possible output to society. The code of conduct
set out the expectations and responsibility of the management of the company, which is required
to be followed (Puffer, 2015).
Applicability
All the directors, employees, labor and other personnel are required to follow this code of
conduct. This code does not cover every aspect but the same is only an outline of the company
policies and practices.
Our Values
Safety:- Considering the human life, safety and security thereof over and above rest of
the things
Respect: - We consider the interest of everyone and treat them with full of respect and
dignity.
Teamwork:- We believe in teamwork, works together and learn from the experience of
each other.
Excellence:- We try to push ourselves on regular basis and always try to perform better

Governance, Ethics and Sustainability 2
Integrity:- This is last but not least value of us. We believe to perform our work in an
integrated manner and in such a manner; we do what is right and not what is easiest.
Our principles
The management and employees of Rio Tinto are required and expected to act according to the
following principles
Compliance with law
Being an Australian company, various legislations are applicable to the company. To achieve the
Primary objective, the company is required to comply with the provisions of Corporations Act
2001 (Cth) and to make all the required disclosures under the same. In addition to the
Corporations Act 2001, ASX Listing Rules obligations also need to be complied with. To
comply with these legal provisions, a separate compliance policy has also been developed.
Further, Rio Tinto is committed to complying with the provision of competition and Consumer
laws of Australia. We respect our customers and competitors and understand their concern.
Employees are the people responsible to deal with the consumers. For this reason, the company
arranges training development program on the gap of regular interval.
Discrimination
In Rio Tinto, there are several employees working. The company does not discriminate among
its employees based on any possible factor such as race, religion, gender, pregnancy, or so on.
Discrimination here refers to a situation where a company treats one or more employees in a less
favorable manner than the others (CCH Australia Limited, 2010). In order to ensure no
discrimination in the workplace, the company adheres to follow the provisions of the following
legislations namely:-

Governance, Ethics and Sustainability 3
Racial Discrimination Act 1975 (Cth)
Sex Discrimination Act 1984 (Cth)
Disability Discrimination Act 1992 (Cth)
Age Discrimination Act 2004 (Cth)
Provisions of all these legislation require an employer to provide discrimination-free workplace
to it is employees. It is the responsibility of the Management of the company to ensure that there
is no direct or indirect discrimination among employees. To escalate the discrimination at the
workplace, management and senior employee of the company must
Publish advertisement which is not influenced by any particular factors which can lead a
discrimination
Take interviews in a similar manner without providing privilege to anyone
Select the candidates considering their qualification only
Avoid the unlaw discrimination and to provide opportunities to employees based on their
qualification only.
Rio Tinto believes in the healthy development of every employee and therefore try to avoid
unfair practices such as discrimination. Not only the top management but also the middle and
junior level managers are also bound with Anti-discrimination policy of the company. In case of
any issue related to discrimination, the affected person is advised to contact the Anti-
discrimination committee of the company, which is there to consider the complaints, related to
this issue.

Governance, Ethics and Sustainability 4
Exploitation
Exploitation is an activity where one uses others in an unfair mode for his/her personal benefits
(Scott, 2017). Rio Tinto is very much active to ensure that no exploitation of any of the
stakeholders would there. It is to state that anti-exploitation policy is specifically developed for
employees. Employees are an important part of the organization and the same cannot think of its
working without them. As Rio Tinto is engaged in mining activities, many of the people are
connected with the same as labor (Riotinto.com, 2018a). The company is expected to follow the
provisions of the labor code while dealing with the labor. In order to ensure the zero exploitation
in the company, management, and other senior employees are required to
Provide fair means of work to labor. In such a manner company, the company must
provide safety and a secure working environment for the labor
Give the possible targets to achieve. The company must not give impractical targets to
labor an employees.
Give rest to the labor and other employees during the week as per the agreements made
with them
Avoid issues such as underpayment. The company is required to make the fair payment
to employees and to not deduct their wages and salaries for invalid reasons
Say no to child labor. Child labor is a curse for the innocent children and prevents their
social development. Rio Tinto will not engage any child as labor.
Arrange health measures. Being a worker of the mining industry, their health can be
affected in an adverse mode. Therefore shall ensure the best measure to be there to
provide a healthy environment.
Ensure that no employee faces any sexual exploitation during working.

Governance, Ethics and Sustainability 5
If any employee or labor feels that Rio Tinto has done any kind of exploitation with them, they
are welcome to address the issue to their immediate manager.
Corruption
Corruption can lead to an issue of reduction of goodwill, brand image and public trust
(Mascarenhas, 2018). Rio Tinto believes that corruption, (regardless of which level the same
happens) can spoil the total working structure of the company. Not only the management this
time, we expect from our employees to be corruption free all the time (Riotinto.com, 2018b).
The company treats all the stakeholders as family and expect that all of them will certainly put
efforts to develop the brand image. Prevention of corruption is also necessary as the same bring
negative results on the financial performance of the company (Nejati, 2013). Although it is a
matter of integrity and values, yet the company is required to ensure the corruption in any form
does not present there. Rio Tinto personnel are required to observe the following all the times
Do not offer a bribe to anyone. They are not required to make any payment in an unfair
mode with an intention to bring the success or profits to the company. All the profits
must come out of the fair practices only.
No one in the company will accept the bribe in a direct or indirect manner. Here direct
manner refers to the money (either cash or cheque) and indirect manner refers to gifts,
hospitality, or entertainment in breach of Rio Tinto’s Policy.
While dealing with government officials or other authorities, Rio Tinto Personnel are
required to behave in an ethical manner. They are not expected to pay any bribe in order
to make their work success.
Do not be a part of any fraudulent activity and try to prevent the same if comes into
knowledge.

Governance, Ethics and Sustainability 6
Rio Tinto shall only provide and recognize those political contributions, which are fair
and officially allowed by the board of directors of the company.
Here, the most significant aspect to discuss is that personnel are not only required to avoid bribe
by them, but the same is required to make the efforts to prevent the bribery culture in the overall
organization.
Dishonest and Fraudulent Behavior
Honesty is the core requirement of ethics (Robinson and Dowson, 2012). We want our
management, employees, and all other personnel to be honest in their working. Fraudulent
behavior of any of them is not at tolerated at all. Rio Tinto officials and other personnel are not
expected to do any unethical, fraudulent, or improper business activities. We have zero tolerance
with respect to fraudulent behavior and we want our personnel to be loyal and faithful to us. Here
following activities will be counted as a fraud:-
 Manipulation in accounting (I-sight.com, 2018)
 False claim of expenses
 Insider trading
 Theft (Kappel, 2017)
 Claiming false qualification
 Sharing business information with outsiders
 collusive tendering
 Any other activity that leads personal interest of Rio Tinto officials
To ensure that there is no fraud, following are some of the practices that people at various
hierarchal levels are expected to adhere. They are required

Governance, Ethics and Sustainability 7
To report their working to the immediate seniors
To make proper disclosures as required under various laws applicable to the company of
timely basis
To keep the statement of the expenditure they have spent on behalf of the company
To disclose their personal interest in the business transactions
To not to use insider and confidential information of the company for their personal
benefits.
The employee, management and other members of the company are expected to meet with the
higher standards of integrity and honestly while their working.
Whistleblower Protections
Whistleblowing is a facility where one can report the unethical issues of the organization to the
management (Miceli, Near, and Dworkin, 2018). A person who performs this activity is known
as a whistleblower (Brown et. al, 2014) Rio Tinto welcomes all the employees and other
personnel who wish to address any unethical issue of the company. Here unethical issue involves
all the activities that are mentioned in the aforesaid parts and includes sexual harassment,
unlawful, discrimination, bullying, and other exploitation. People are not required to be afraid
while reporting such issues as the company has a whistleblower protection policy, which
provides a safeguard to the whistleblower, by various methods. Rio Tinto personnel who wish to
report an issue have to follow the prescribed procedure laid down by the company. The same is
presented as under:-
The procedure of Whistle Blowing

Governance, Ethics and Sustainability 8
A person, who wishes to report any issues, can report the same by calling or dropping an e-mail
to the contacts as prescribed at the end page of this code of conduct. In addition to this, a
whistleblower can report the issue to any senior who is a person with ethics. A whistleblower is
also required to ensure about his/her safety during reporting an issue.
Following are some of the officials who play a vital role in whistleblower protection:-
Whistle-blower Protection Officer
As the name implies, the lead task to do by a whistleblower protection officer is to protect the
interest of whistleblower. This officer will consult with financial, legal, and other experts to
make the updations in whistleblower protection policy.
Whistle-blower Investigations Officer
The officer is responsible to carry out an investigation with respect to all the complaints and
reports received from whistleblowers. In order to carry this investigation, such officer is required
to conduct some basic inquiries in relation to the concerned matter, which will further lead to
personal investigation and interviews with the people involved. On the basis of the investigation
carried out by this officer, the correctness of the reporting made by whistleblower comes into
light.
Enforcement
People to whom this code is applicable are required to adhere the same. The code is not optional
and compliance of the same is mandatory. The top management can make the amendments in
this code and the same will be informed to the public. Management of the company will take

Governance, Ethics and Sustainability 9
action against people who would breach this code of conduct. The action can come in the form of
penalties, warning, trial or dismissal of liable personnel.
Contact Details
All the queries and reporting related to the aspects of this code of conduct can be made on the
following:-
By telephone to 61 3 9283 3333
By letter to Level 7, 360 Collins Street, Melbourne
Australia 3000

Governance, Ethics and Sustainability 10
Reference
Age Discrimination Act 2004 (Cth)
Brown, A. J., Lewis, D., Moberly, R. and Vandekerckhove, W. eds., (2014) International
handbook on whistleblowing research. UK: Edward Elgar Publishing.
CCH Australia Limited. (2010) Australian Master Human Resources Guide 2010. Australia:
CCH Australia Limited.
Corporations Act 2001 (Cth)
Disability Discrimination Act 1992 (Cth)
I-sight.com. (2018) 41 Types of Fraud and How to Detect and Prevent Them. [online] Available
from: https://i-sight.com/resources/41-types-of-fraud-and-how-to-detect-and-prevent-them/
[Accessed on 31/12/2018]
Kappel, M (2017) 5 Types Of Fraud In Business That Could Put You In A Bind. [online]
Available from: https://www.forbes.com/sites/mikekappel/2017/10/04/5-types-of-fraud-in-
business-that-could-put-you-in-a-bind/#dfc9c6713e5c [Accessed on 31/12/2018]
Mascarenhas, O. (2018) Corporate Ethics for Turbulent Markets: The Market Context of
Executive Decisions. UK: Emerald Group Publishing.
Miceli, M P, Near, J P and Dworkin, T M (2018) Whistle-Blowing in Organizations. NY:
Psychology Press.

Governance, Ethics and Sustainability 11
Nejati, M. (2013) Frontiers of Business, Management and Economics: An Interdisciplinary
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Puffer, S M (2015) International Management: Insights from Fiction and Practice: Insights from
Fiction and Practice. Oxon: Routledge.
Racial Discrimination Act 1975 (Cth)
Riotinto.com. (2018a) Our purpose. [online] Available from:
https://www.riotinto.com/aboutus/about-rio-tinto-5004.aspx [Accessed on 31/12/2018]
Riotinto.com. (2018b) The way we work. [online] Available from:
https://www.riotinto.com/documents/RT_The_way_we_work_EN.pdf [Accessed on 31/12/2018]
Scott, S. (2017) Labour Exploitation and Work-based Harm. UK: Policy Press.
Sex Discrimination Act 1984 (Cth)