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2012 - AMBATOVY SUSTAINABILITY REPORT
Respect for others in the workplace is a basic requirement for employment at Ambatovy. All employees are required
to respect the rights of those with whom they work and the communities around our sites. Each year, employees are
required to review our Code of Conduct and other key policies, such as those about health and safety, violence-free
workplace and reportable concerns and privacy.
Anti-Corruption
Our Code of Conduct requires that we conduct our business in a moral and ethical manner and that our employees
comply with all applicable laws. At the end of 2012, we rolled-out our anti-corruption and business ethic policies. By
mid-2013, more than 90% of our employees have completed training on these policies, allowing them to learn ways in
which they can avoid and prevent corruption, fraud and conflicts of interest. Training was offered in Malagasy, French
and English.
Security Practices
Ambatovy is committed to the highest ethical standards throughout its operations. In line with this commitment, we
uphold the Universal Declaration of Human Rights and recognise our responsibility to respect human rights as outlined
in the Unites Nations Guiding Principles on Business and Human Rights. Ambatovy works with private and public
security forces and strives to implement, when and where possible, initiatives in accordance with the guidance of the
Voluntary Principles on Security and Human Rights (VPs). The VPs are considered security best practice and provide
guidance for maintaining safe and secure operations while respecting human rights. The VPs are also particularly
applicable to companies in the extractive industry.
Throughout 2012, Ambatovy facilitated and participated in a number of initiatives to promote and integrate the VPs
throughout Ambatovy’s areas of operation. In 2012, a human rights-based risk assessment was conducted by
independant third-party experts. Meanwhile, Ambatovy began embedding the VPs into company policies, memorandums
of understanding with public security and in private security contracts. Ambatovy engaged with Madagascar’s armed
forces, gendarmerie, police and defence authorities, to discuss the VPs.
Partnerships have also been formed with the United Nations, the International Committee of the Red Cross and the
Ministry of Justice to deliver security and human rights awareness training. By 2014, Ambatovy intends to formalise
this on-going commitment by becoming a participant in the Voluntary Principles Association, a global organisation
that includes governments, NGOs and mining companies seeking to promote human rights.
Grievance Mechanism
Ambatovy is committed to facilitating stakeholders’ questions and concerns. A grievance mechanism to address
affected communities’ concerns and complaints is an important pillar of the stakeholder engagement process. As a
responsible mining company, Ambatovy is committed to complying with the laws and frameworks that regulate mining
activities. Ambatovy’s comprehensive grievance mechanism, created in 2010, is modelled on best practice guidance.
In 2012, we significantly improved our 30-day response rate from 28% to 48% and the rate of complaint resolution
improved by nine percentage points compared to 2011. Some of the grievances we received concerned
compensation procedures as well as environmental impacts.
Business ethics
