Hydro Annual Report 2011b

The annual business planning process and inclusion of key
performance indicator actions are used to implement the
integrity program as well as other corporate responsibility topics.
Requirements have been drawn up regarding how corporate
responsibility should be taken into account in business
development, investments and during the execution of projects.
In 2011, a mapping tool for non-financial compliance
risk was developed and risks identified for all business areas.
These risks were used as basis for mitigating actions and
included in the business plans for 2012. Risk assessments are
now a part of the quarterly follow-up meetings that are mandatory
for all business areas in Hydro.
Employees may report breaches or perceived breaches of
Hydro’s requirements through the whistleblower channel. A
small number of cases were reported in 2011, and all cases
were investigated. In two of the incidents investigated by
Hydro’s internal audit unit, the investigated persons chose to
leave Hydro. During the first quarter of 2012, Hydro will
launch a new “alertline” served by an external company where
all permanent and temporary employees can report their concerns
at any time and in their own language through toll-free
phone numbers or the Internet. The alertline replaces the former
whistleblower channel. The aim is to make it easier for
employees to report their concerns related to behavior that
may conflict with Hydro’s values or threaten our reputation.
As required, it is possible to report anonymously. At least once
a year, Hydro’s internal auditor informs corporate management
about utilization of the channel.
Information about the alertline will be given through bulletin
boards and Hydro’s intranet. Together with anti-corruption
and basic employee rights, information is also given through
“you and Hydro” – a brochure and an e-learning program
available to all employees in 12 languages.
It has been decided to strengthen Hydro’s internal audit by a
hub in Brazil, reporting to the main function at the head office
in Oslo. The new units in Brazil have gone through internal
and external audits related to financial and non-financial topics
in 2011. These efforts will continue in 2012.
Hydro’s internal audit unit reports to the company’s board of
directors through the board audit committee.
In Hydro, compliance is defined as adherence with external
laws and regulations as well as internal steering documents.
The compliance system comprises measures to reduce the risk
of non-compliance. These measures are grouped into four categories:
prevention, detection, reporting and responding.
Compliance is a line responsibility in Hydro. The corporate
staffs Legal and HSE & CSR have a support and advisory role
for non-financial compliance. In 2011, a compliance officer
function for Hydro was established to coordinate processes
and activities within the non-financial compliance system.
vIABIlItY perForMAnCe
Integrity and human rights
57
Risk mapping was performed in 2011 to identify major HSE
and other non-financial compliance risks. Based on this, several
activities were started and integrated in the 2011 business
plans.
Combating corruption and respecting human rights are both
included in our supplier requirements, see page 58.
Combating corruption
Hydro’s Code of Conduct is approved by the board of directors.
The Hydro Integrity Program is an important tool to prevent
corruption and human rights violations connected to our
activities. The program was last updated in 2009 and includes
risk mapping, tools and training. In 2011, about 1,800
employees were trained in the program. Of these, almost 1,000
are in Hydro Building Systems (HBS), which means that half
of the employees there have been through the training. HBS
pinpointed the most relevant information and developed
Q&As to illustrate the cases, with support in several languages.
In our new activities in Brazil, 120 leaders and specialists participated
in 2011. This includes all top leaders in Bauxite &
Alumina, and a large number of other relevant employees in
Paragominas. More employees at Alunorte will be included
early in 2012. Training includes dilemma discussions on combating
corruption and promoting human rights. About 5,000
employees have participated in the training program since
2006, in addition to 120 employees from joint-venture companies.
In addition, our Rolled Products business distributed
in 2011 information about the program in local language to
4,000 employees.
A fraud awareness and detection questionnaire forms part of
internal audit activities where relevant. Our accounting centers
are trained to ask relevant questions to reveal possible fraud or
other questionable accounts.
2011 target
• No instances of corruption
• No instances of human rights violations
• Implement CSR strategy for the new organization in Brazil
2011 result
• No known instances of corruption
• No known instances of human rights violations in Hydro
• Stakeholder dialogue related to the CSR strategy initiated.
Implementation continues in 2012
2012 target
• No instances of corruption
• No instances of human rights violations
• Develop risk analyses and action plan for human rights
Ambition
All important suppliers should comply with our supplier standards.
All our units should comply with our anti-corruption, human and
labor rights standards, and report their performance. Our ambition
is to be a preferred partner worldwide because of our responsible
business operations.