Case study: How Quebec Iron Ore promotes ethical business behaviour
Founded in 2015, Quebec Iron Ore is one of the world’s largest independent producers of high-grade iron ore following the 2018 launch of operations at its main asset, the Bloom Lake Mine in Quebec, Canada. Quebec Iron Ore and its parent company, Champion Iron Limited, use a variety of tools such as policies, training, charters, codes and procedures to foster and maintain a corporate culture that encourages ethical behaviour and compliance with their obligations.
This case study is based on the 2019 Sustainability Report by Quebec Iron Ore published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
Quebec Iron Ore’s reputation and the trust of those with whom it does business are among the most important assets of its business. Accordingly, it is essential for Quebec Iron Ore to conduct its business while respecting the highest standards of integrity, transparency and excellence Tweet This!. In order to promote ethical business behaviour Quebec Iron Ore took action to:
- implement an Employee Code of Conduct
- provide training
- promote misconduct reporting
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With this case study you will see:
- Which are the most important impacts (material issues) Quebec Iron Ore has identified;
- How Quebec Iron Ore proceeded with stakeholder engagement, and
- What actions were taken by Quebec Iron Ore to promote ethical business behaviour
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What are the material issues the company has identified?
In its 2019 Sustainability Report Quebec Iron Ore identified a range of material issues, such as health, safety and well-being, water stewardship, mine tailings management, equity and equal opportunity employment, respect for ecosystem support capacity, human capital management and engagement. Among these, promoting ethical business behaviour stands out as a key material issue for Quebec Iron Ore.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups Quebec Iron Ore engages with:
Stakeholder Group |
Governments |
Investors |
Employees |
Clients |
Indigenous groups |
Media |
Local communities |
Society |
Shareholders |
Suppliers |
Union |
Non-governmental organisations |
Industry peers |
How stakeholder engagement was made to identify material issues
To identify and prioritise material topics Quebec Iron Ore engaged with a total of 564 stakeholders – including employees, managers, the union, indigenous groups, suppliers, investors, clients, governments, municipalities, associations, and industry peers – through a survey and interview, asking them to rate the importance of the topics by ranking them on a scale of 0 (no importance) to 4 (great importance), and to indicate their level of satisfaction with how Quebec Iron Ore manages important issues.
What actions were taken by Quebec Iron Ore to promote ethical business behaviour?
In its 2019 Sustainability Report Quebec Iron Ore reports that it took the following actions for promoting ethical business behaviour:
- Implementing an Employee Code of Conduct
- Quebec Iron Ore produced an Employee Code of Conduct in 2017 that set standards for the behaviour expected of all staff in their daily activities and in their relationships with others. Although exhaustive, this Code does not deal with all situations that may occur, but provides guiding principles to support a decision process consistent with Quebec Iron Ore’s values, commitments and reputation. It outlines the key responsibilities of Quebec Iron Ore’s employees to shareholders of the parent company Champion Iron Limited, as well as individuals and communities. All employees and managers have an obligation to be aware of the Code and to agree to adhere to it. It should be noted that all employees, officers and directors are also subject to the Code of Conduct of the parent company, Champion Iron Limited.
- Providing training
- In 2019, Quebec Iron Ore launched an online training and certification course on the Employee Code of Conduct. In addition to reviewing the key topics of the Code, the process includes a mandatory test to ensure understanding of the concepts learned as well as a commitment to comply with the Code at all times. The test must be passed with a score of 100% for certification to be obtained. Training and certification must be renewed on an annual basis by all staff. The same process applies to the parent company’s Code of Conduct. Training and certification in the parent company’s and Quebec Iron Ore’s codes of conduct will be mandatory, starting in 2020. All staff should also be familiar with various company policies and procedures that provide detailed advice, guidance and directives on specific situations that may arise in the course of their work and ensure that they make the right decisions and do the right things.
- Promoting misconduct reporting
- Everyone working for Quebec Iron Ore has a duty to promptly report any situation in which its codes of conduct, their underlying policies or the law appear to have been violated. Champion Iron Limited will introduce a whistleblower policy for the parent company and its subsidiaries in 2020, which will apply to Quebec Iron Ore. This policy will notably be accompanied by an anonymous reporting procedure through a platform administered by an independent third party. Additionally, in accordance with its Code of Conduct, anyone working for Quebec Iron Ore who violates any law, the Code of Conduct or other policies or procedures may be subject to disciplinary action, up to and including termination of employment. In 2019, Quebec Iron Ore received two reports related to a potential Code violation, which were treated with the utmost diligence. No one was fired for violating the Code of Conduct.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standards addressed in this case are:
1) Disclosure 205-2 Communication and training about anti-corruption policies and procedures
2) Disclosure 205-3 Confirmed incidents of corruption and actions taken
3) Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices
4) Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.3
Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.3
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References:
1) This case study is based on published information by Quebec Iron Ore, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) https://www.globalreporting.org/standards/gri-standards-download-center/
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