We endorse the United Nations Global Compact with respect to human rights. The compact’s 10 principles provide that businesses should support and respect the protection of internationally proclaimed human rights and ensure that they are not complicit in human rights abuses.
In our work environment, we respect human rights primarily by providing safe and healthy working conditions for our employees and ensuring non-discrimination in human resource practices. In our communities, we respect human rights by contributing our time to the well-being of the communities in which we operate and in striving to do no harm. We believe we influence the standards of conduct in these communities by living our Values.
Our ability to directly influence the standards of conduct of people we do not employ occurs where a supplier or contractor is working in, or delivering products or materials directly to, our facilities. In those cases, we mandate practices, such as compliance with our environmental, health, and safety standards and our human rights standards. We also conduct audits of new suppliers to ensure they meet our safety standards and Values before they supply materials to our company.
In late 2014, we began implementing a third-party supplier due-diligence program with our supplier base. This program includes specific survey questions related to child labor and human trafficking and is expected to be introduced to the majority of our suppliers in 2015.
We also audit existing suppliers to ensure that they comply with our human rights requirements. These audits are focused in regions of the world where risks regarding human rights concerns are greatest. (See the Supply Chain section of our annual sustainability report.)
Our suppliers typically provide raw materials that we use to manufacture our products, or they supply maintenance, repair, and operating materials that we use to maintain our manufacturing and processing facilities. We do not outsource manufacturing, where many of the known human rights issues have arisen.
Within our operations, we strive to implement our Human Rights Policy while operating in many diverse locations. In Juruti, Brazil, for example, we are working with local traditional communities in acquiring basic living needs, such as clean water, health care, and urban and rural infrastructure, that are not only necessary for a higher quality of life, but also for the development of small and micro businesses in those communities.
For new major projects, we conduct environmental, social, and health impact studies in the earliest stages of development. Among other things, these studies investigate how the project could potentially affect the livelihoods and health of local communities. We then implement mitigation strategies that help ensure we are not complicit in human rights abuses.
Some mitigation strategies from past projects include the following:
- Creating a communication and grievance mechanism to ensure community and individual concerns are adequately addressed;
- Having a code of conduct for workers and contractors that outlines behavior that is prohibited during and outside of work;
- Providing cultural sensitivity training for our workers;
- Having a zero alcohol/drug use policy at work;
- Providing health education programs for the community and our workforce; and
- Investing in infrastructure to support the health of communities and to alleviate any potential burden on communities caused by our actions.
One of our key challenges regarding human rights is ensuring our policy is integrated throughout our global operations, and we have created numerous methods to first instill compliance and then identify incidents of non-compliance.
Human Rights Training
In 2014, we continued to offer a 45-minute human rights course to managers and professional employees that educates them about the human rights principles of the United Nations Global Compact and emphasizes that all actions taken on behalf of the company must respect and support human rights.
The course consists of the following lessons:
- Global business standards of the United Nations Global Compact and its fundamental principles;
- Equality of opportunity and non-discriminatory treatment;
- The need to ensure company policies and business processes—such as recruitment, termination, pay, promotion, and training—are non-discriminatory;
- The rights of employees to fair working conditions;
- Recognition of, and respect for, the rights of the local communities in which we operate; and
- Third-party management and our responsibility to ensure that our business partners share our respect for human rights and compliance with global laws and regulations governing protection of the environment, occupational health and safety, and labor and employment practices.
More than 6,300 employees have completed the course since its initial deployment in late 2010.
Hotlines, Certifications, and Audits
In 2014, we deployed to every employee an updated, comprehensive code of conduct available in 19 languages. The new code, Advancing with Integrity, provides clear and easy-to-navigate information and guidance on ethics, compliance, and human rights. It publicly communicates our Human Rights Policy and provides links to our supplier sustainability organization. The code is also available on alcoa.com, enabling stakeholders worldwide to alert us to potential issues with this policy.
Our internal systems also support compliance with our policy. For example, we have a robust and mature Integrity Line for employees and external stakeholders to report alleged violations of laws and our policies on a confidential basis and in their own language. Along with the Integrity Line, our Integrity Help Chain is available to all employees who want to seek advice or raise a concern if the right choice is not clear.
Annually, we conduct a Business Conduct and Conflict of Interest Survey that requires certification of compliance with all business conduct (including applicable laws and regulations), anti-corruption, and conflict of interest policies. In the jurisdictions in which we employ a majority of our employees, there are laws applicable to many of the areas dealt with in our Human Rights Policy, including child labor, freedom of engagement, equality of opportunity, and compensation.
We also have a rigorous internal audit system that includes, as part of a site visit, interviews with all key location managers on compliance with local laws.
Slavery and Human Trafficking
California (USA) law requires companies like Alcoa that conduct business in that state to disclose the efforts they have taken to eliminate slavery and human trafficking from their supply chains. As such, the following description of the efforts we have taken is intended to meet this requirement:
- As stated in our Supplier Standards and demonstrated by our support of the United Nations Global Compact, Alcoa strictly prohibits the use of slave labor and engagement in human trafficking and requires all suppliers to acknowledge and comply with our prohibition. Alcoa requires that all of our suppliers conduct business in a manner that respects human rights.
- In addition, we require every supplier to comply with all applicable laws, rules, regulations, orders, conventions, ordinances or standards. This requirement includes complying with all laws related to the prohibition of human trafficking and slave labor.
- We are in the process of deploying a formal supplier due-diligence platform that specifically addresses child labor and human trafficking. The program, which launched in 2014, will be disseminated to the vast majority of Alcoa suppliers throughout 2015.
- In highest risk regions, we also survey and audit a portion of our suppliers each year to assess their adherence to our overall supplier standards. We take appropriate action to increase our scrutiny of our supply partners operating in those areas.
- We do not require our direct suppliers to certify that materials incorporated into their products comply with slavery and human trafficking laws of the country or countries in which they do business.
- If a supplier fails to comply with any of our requirements, including those regarding slavery and human trafficking, we will take appropriate action. This can include canceling all contracts and alerting local authorities of any suspected or confirmed illegal activity.
- All Alcoa employees with direct responsibility for supply chain management have been presented with Alcoa’s Human Rights Policy and are highly knowledgeable about our Supplier Standards. Every Alcoa employee is required to comply with all of the laws and regulations of the jurisdictions in which we operate, including those related to the prohibition of human trafficking and slave labor.