Engaging with Our Host Communities

CODE PRINCIPLES

We seek to establish long-term community relationships based on meaningful engagement, care, respect, transparency, trust, honesty, humility, and good faith.

  • We respect and seek to promote the culture, heritage, life systems, customs, beliefs, rites and socio-cultural practices of neighboring communities.
  • We value the traditional rights of indigenous communities over their habitat; recognize the unique relationships of indigenous communities with the environments, and respect community sites which are culturally or religiously significant.
  • We value the participation of indigenous peoples in our workforce.
  • We assess and consider the social, cultural, environmental and economic impact of our operations on others.
  • We maintain the safety and security of our operations, while respecting the human rights of those in our host communities.
  • We contribute to the development and quality of life of our host communities.
  • We do not offer or provide anything of value with the intent to improperly influence a community representative to gain business or an improper advantage.
  • We seek opportunities to procure locally where possible, to support the economic and social development of our host communities.
  • We value the culture, heritage and diversity of views of our host communities, and respect community sites which are culturally or religiously significant.
  • We respond to community complaints in a timely manner and undertake action to address their concerns when appropriate.
  • We will not retaliate against any Albemarle employee or member of our host communities for making a community-related complaint.

Our Code Principles in Action

  • Consult with the employee responsible for local community engagement and any relevant country manager in advance of all meetings with community representatives.
  • Ensure a summary is prepared of all meetings with community representatives, and provide a copy to Government Affairs.
  • Follow this Code (Offering or Accepting Gifts & Hospitality) if you are considering offering anything of value, including gifts or hospitality, to a community representative, or receiving the same from a community representative.
  • Follow this Code (Making a Charitable Donation) and the Anti-Corruption Policy if you would like the Albemarle Foundation to make a charitable donation in the US, or if you wish the Foundation to match your own donation in the US.
  • Ensure planned donations to a community project are included in the appropriate Annual Operating Plan.
  • Obtain pre-approval in accordance with the Charitable Donations & Community Projects Procedure before offering or giving (outside of the Albemarle Foundation) financial or in-kind support to a community project.
  • Ensure that community project donations are paid to the authorized recipient; used for the approved purpose; supported by a receipt; in accordance with any applicable local tax requirements; and booked to an appropriate GL account.
  • In accordance with the Code (Hiring New Employees) obtain pre-approval from Global Ethics & Compliance before offering employment, a temporary contract or an internship to:
    • a community representative in a position of influence or authority over Albemarle’s business;
    • a relative of such a community representative; or
    • an individual who was such a community representative in the past two years.
  • Consult with Global Ethics & Compliance if you, your spouse, your partner or a relative becomes a community representative who has influence over Albemarle’s affairs, and notify your supervisor in accordance with this Code (Managing a Conflict of Interest).
  • Immediately contact Global Ethics & Compliance or the Legal Department if a community representative makes a request for a bribe, including a facilitation payment.
  • Report any complaints or inquiries received from host communities to the employee responsible for local community engagement and any relevant country manager, and in accordance with any applicable grievance mechanism.
  • Obtain pre-approval in accordance with this Code (Selecting and Managing Vendors) and the Global Procurement Policy before using such a Compliance Sensitive Vendor (which includes vendors who we know or suspect are directly or indirectly owned by a community representative or a close relative of a community representative; who engage with our host communities on our behalf; or who are recommended by a community representative).
  • Vendors who provide site security services may engage with local police, military or other government officials on our behalf. They are Compliance Sensitive Vendors. Obtain pre-approval in accordance with this Code (Selecting and Managing Vendors) and the Global Procurement Policy before using such a vendor.

DEFINED TERMS

Anything of Value

is broadly defined to include any type of benefit to the recipient, such as:

  • money (all currencies including bitcoin, and method of delivery such as cash, check, wire, electronic, mobile transfer);
  • cash equivalents such as gift, store, discount, mobile phone or stored value cards
  • Gifts;
  • meals, entertainment and other hospitality;
  • travel, including flights and accommodation;
  • offers of employment or an internship;
  • a contract for the procurement or sale of goods or services;
  • a contract for the procurement, sale or lease of property;
  • a charitable donation or contribution to a community project;
  •  a commercial sponsorship;
  • confidential information;
  • investment opportunity; and
  • any other form of personal favor.
Bribe

Bribery means offering, providing or receiving anything of value with the intent of improperly influencing any person to take an action to obtain an improper advantage. This includes, for example, improper influence over the:

  • the decision whether to accept an application, official form or any other type of paperwork;
  •  the grant or revocation of a permit, license, quota, visa or any other award which allows the recipient to undertake a specified activity;
  • the award of a commercial procurement or sales contract;
  • the decision to enforce, or not enforce, a particular law or regulation against a company or individual;
  • the decision to enforce, or not enforce, contractual terms such as performance guarantees;
  •  the decision to require, or not require, a payment to be made or how much is to be paid (e.g. taxes); and
  • the sponsoring or approval of a change in existing law.

Bribery also includes the making of facilitation payments.

Facilitation Payments

Small payments made to lower-level government officials as a personal benefit to them to secure or speed up a performance of a routine action (e.g. licenses, permits, visas, customs clearance).

Relative

An individual’s spouse or spousal equivalent; the individual’s and the spouse’s grandparents, parents, siblings, children, nieces, nephews, aunts, uncles, and the spouse or spousal equivalent of any of these people; or anyone who shares the same household.

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