2010
AMBATOVY SUSTAINABILITY REPORT
50
C5.2 Investment and Procurement Practices
Suppliers and Contractors
Ambatovy’s purchasing policy includes stipulations on
standards of ethical conduct, which follow not only the spirit but
also the letter of applicable laws in Madagascar and in other
countries for international purchases. It requires that suppliers
follow governmental regulations, company procedures and
sound business practices. The policy also has clear anti-
corruption clauses, aiming to prevent bribes and other unethical
behaviour throughout our supply chain. Ambatovy checks the
legal standing of in-country vendors before they are added to
the list of potential suppliers. The Supply Chain Management
Department has a code of ethics to ensure all suppliers meet
the Project’s standards with regard to human rights and with
irreproachable professional conduct.
Construction purchase orders have been managed separately
through the EPCM contractor and did not include the conduct
clauses for suppliers. However, the EPCM contractor
implemented its own worker code of conduct that addressed
issues such as local customs and civil behaviour. In addition,
bulletins have been issued to all site contractors reminding
them of the Project’s zero tolerance policy toward sexual
exploitation of children, alcohol abuse, illegal drug use and
misbehaviour. Contractors were required to acknowledge
receipt and confirm adherence to these bulletins.
Human Rights Training
The code of conduct has been in place since 2008 and was
updated in 2009. Since November 2010, the basic induction
training that all employees must complete has included a
review of the code of conduct, which details the Project’s
policy on human rights. All employees must agree to abide by
the code, which is also in the Ambatovy Employee Handbook
that each employee receives. The Project is implementing a
two-pronged approach by educating employees as well as
conducting community engagement on the issue. Human
rights violations are grounds for termination of employment.
C5.3 Non-Discrimination
Ambatovy’s recruitment strategy is based on non-
discrimination in terms of non-job related characteristics, such
as gender or race. It is supported by a clear methodology
that embraces transparency, equality and fairness for all
candidates.
By recruiting on a competitive basis, Ambatovy aims to select
the best candidate for each job. While our goal is to boost
local access to jobs, our policy is to offer positions to the best
qualified candidate based on employment-related indicators.
Our human resources policies state that we value all talents
and that all positions, including technical positions, are open
to men and women. Our maternity policy helps ensure that we
attract and retain top female talent, while promoting the health
of employees and their children.
Our goal is to have a workplace free of discrimination and
harassment. The Ambatovy Employee Handbook encourages
employees to report any instances of harassment to their
superior, their employee representative and/or the Human
Resources Department. This Department is responsible for
undertaking investigations and mediation to address any
allegations. Employees are guaranteed confidentiality and
protection from retaliation.
C5. Human Rights
