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Vale recognizes and understands the myriad human rights challenges inherent in our operations, given the nature of the mining industry and the locations where we operate. Our commitment to Human Rights spans across every phase of the mining life cycle—from mineral exploration to mine closure and across all businesses.
Furthermore, public policies that guarantee the Human Rights of communities are not always fully present in these very remote regions.
When commencing mining activities in areas with these characteristics, there is a risk of heightening the social and economic vulnerability of local communities. This requires the company to have a robust Human Rights management and a cross-disciplinary approach to address the complex and systemic issues involved.
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Our approach
Vale’s approach to Human Rights is aligned with the UN Guiding Principles on Business and Human Rights, the UN Global Compact principles, the Universal Declaration of Human Rights, the principles and guidelines issued by the International Council on Mining and Metals (ICMM), and the International Finance Corporation’s (IFC) Performance Standards. This approach meshes directly with our strategic pillars, our Integrity agenda, our Ethics & Compliance Program and our ongoing cultural transformation.
The Human-Rights governance at Vale is based on respect, awareness raising, and promotion of Human Rights. It includes efforts to prevent, manage and, where necessary, mitigate and remediate adverse impacts and violations within our activities and throughout the value chain. We also value and recognize the importance of engaging with stakeholders on critical issues to improve processes and advance this agenda across the company.
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Governance
Everyone at Vale must respect the Company´s Human Rights commitments, starting with the Board of Directors and extending to all employees. The Board of Directors—our highest governance body—has been assigned responsibility for acting as guardian of our Human Rights commitment, which is stated in the Company bylaws.
Human Rights topics are monitored by our Sustainability Committee—which advises the Board of Directors—and at the executive level by the Executive Committees for Compliance and Operational & Compliance Risks, in accordance with Vale's Risk Management Policy. These committees take a preventive approach and are responsible for assisting executive vice presidents in monitoring business risks and making related decisions.
agenda across the company.
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Policy commitment
Our practices are guided by a global Code of Conduct that applies to all Group subsidiaries and affiliates and includes a chapter on Human Rights. Another core policy document is our Human Rights Policy, issued in 2009 and last revised in 2023. The previous revision in 2019 was informed by a public consultation hosted on Vale's website in both Portuguese and English. The consultation was published on social media and communicated by email to stakeholders. The consultation engaged 382 respondents from different sectors and social groups, providing important inputs.
To make the contents of the Policy more tangible and engaging for employees, Vale has a Human Rights Guide (now in its 3rd edition) along with guidelines addressing critical Human Rights issues in the mining industry.
Vale´s Archive
This set of documents guides Vale’s approach to and stance on issues such as diversity; ensuring political freedom and freedom of association; raising awareness about workplace and sexual harassment; combating the sexual exploitation of children and adolescents; fighting discrimination; combating child and forced labor; corporate security practices; community engagement (including Indigenous Peoples and Traditional Communities); involuntary resettlement; Listening and Response Mechanism; and our Whistleblowing Channel.
All contractors and joint ventures operated by Vale are required to be familiar with and abide by our Human Rights Policy. This Policy and our Principles of Conduct for Third Parties require suppliers and partners to apply equivalent principles in their own operations and supply chains.
Training
Vale actively provides Human Rights training to employees. This mandatory training is offered in Portuguese, English, Spanish, Japanese, Bahasa, French, Arabic, and Brazilian Sign Language (Libras) across the various countries where Vale operates.
Vale’s Human Rights team also carries out in-person and remote capacity building and programs, such as programs addressing business and Human Rights which have been developed for the Board of Directors, leadership and their teams. There is also capacity building for the Corporate Security team, such as specific training aligned with the Voluntary Principles on Security and Human Rights. A video training module is also available for contractors globally.
Vale´s Archive
In addition, Vale provides a range of content covering critical topics for employees, suppliers, joint ventures, and customers, including:
• Indigenous Peoples´ culture and way of life
• Gender relations
• Forced and child labor
• Sexual exploitation of children and adolescents
• Collective bargaining and freedom of association
• Diversity and Inclusion
Managing Human Rights risks and impacts
Vale’s approach to managing risks, including Human Rights risks, follows the Three Lines of Defense model. Operational departments have primary and direct responsibility for identifying, monitoring and managing risks in an integrated manner (1st line).
The Human Rights department, as specialists, develop and maintain risk management, internal controls, and compliance processes. They identify and monitor new/emerging risks and ensure continuous improvement and compliance with our risk management framework and applicable laws, regulations and standards (2nd line). This department also provides training and guidance to our operations in identifying risks, and reports on risk management results to the Risk Committee and executive vice presidents.
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Our approach to managing impacts is governed by our Global Human Rights Policy. At Vale, this process may be activated as a result of on site inspections, grievance mechanisms reports, allegations, external Human Rights due diligence findings, audit findings, Whistleblower Channel investigations, or due diligence preceding mergers, acquisitions, and joint ventures.
Human rights risks are included in Vale’s Global Integrated Risk Map, and all operations and critical projects assess and monitor Human Rights risks using a global risk management system. Human rights are also covered in risk and impact assessments for mineral exploration activities, mining operations, some non-operational departments, projects, and joint ventures.
In these assessments, potential risk causes are determined and grouped into Vale´s salient Human Rights issues: degrading working conditions and modern slavery; child labor and sexual exploitation of children and adolescents; Human Rights violations in labor relations; and large-scale Human Rights violations. Both preventive and mitigating measures are taken as part of our approach to risk management. The effectiveness of controls is monitored through periodic testing.
Monitoring results inform continuous improvement efforts aimed at identifying, preventing, mitigating and addressing Human Rights risks and negative impacts, with a focus on people, including employees and contractors and members of local, Indigenous Peoples and Traditional Communities.
In assessing the risks to which the company is exposed, whether operational or non-operational, the Social and Human Rights dimension is factored in determining the magnitude of impacts. This has been the company’s approach to integrating Human Rights aspects into risk assessments, alongside financial, reputational, environmental, and health and safety aspects.
In addition to Human Rights risk assessments, Vale also carries out Human Rights due diligence on all its operations and critical projects.
The due diligence process is conducted by specialized, independent consultants and includes desktop reviews, on-site assessments, interviews, and focus groups, sometimes grouped by gender. Participants include both direct employees and contractors, community members, and representatives from government, academia, and civil society.
The results are shared with Vale's Human Rights area and with each assessed site and its leadership. Recommendations are translated into controls and corrective actions to improve risk management and remediate identified negative impacts. The Human Rights Management team monitors the entire process and oversees the implementation of controls and corrective actions.
Between 2019 and 2020, an external due diligence pilot was conducted at four operations, including two international ones. In 2021, the now-improved due diligence methodology was rolled out at 14 operations and project sites within the North System in Brazil. In 2022, Vale conducted 22 additional due diligence assessments on Southeast and South System sites, completing the due diligence cycle for 100% of active operations in Brazil. In 2023, our due diligence procedures focused on halted mines and mines undergoing decommissioning in Brazil, in addition to Vale Malaysia.
In 2023, HRDD was completed across 100% of our operations in Brazil (including active, curtailed, and decommissioned assets), and in our iron ore operation in Malaysia. Our HRDD conducted in Brazil identified challenges related to contractor working conditions, infrastructure and facility management, property security, workplace and sexual harassment, discrimination, and diversity and inclusion. HRDD has action and mitigation plans that are continuously monitored by the company.
Click here to learn more about Vale's Human Rights due diligence methodology.
As part of our approach to assessing risks and impacts, we work with the Procurement team to manage Human Rights risks involving suppliers. This process spans the supplier’s entire journey within the company, from onboarding through contract management, including external Human Rights due diligence, capacity building, and development of the supply chain.
Prior to bidding processes, all suppliers undergo a background check based on public information and document submissions providing details on health, safety, and the environment (HSE), Human Rights, compliance and integrity considerations.
In Brazil, all Vale suppliers are screened against the federal government’s Slave Labor Dirty List.
Suppliers must commit to complying with our Principles of Conduct for Third Parties.
Supplier contracts contain provisions under which they agree to abide by expected behavioral standards in accordance to Vale’s policies. This includes providing decent working conditions, combating child labor and the sexual exploitation of children and adolescents, preventing and combating forced and slave labor and human trafficking, not tolerating discrimination and harassment, and respecting freedom of association and collective bargaining rights. Vale’s standard draft contract also includes anti-corruption and HSE clauses.
When classifying our suppliers on Human Rights risks, we consider, among other aspects, the supplier’s industry and location. We mitigate these risks through training, self-assessment questionnaires, document inspections, and on-site inspections. When necessary, we request that suppliers develop an action plan to address identified weaknesses.
Between 2019 and 2022, we conducted over 110 Human Rights due diligence assessments on suppliers in Brazil. Some of these suppliers were requested to develop action plans to address identified risks, which are being monitored.
Vale supports suppliers’ development by providing training to improve their performance in Human Rights. We actively share knowledge to build a more responsible supply chain and engage around salient issues. In 2022, more than 120 suppliers were engaged in training; In 2023, the number of engaged suppliers in Brazil and Malaysia exceeded 400.
We also encourage suppliers to implement compliance programs and enforce the same guidelines within their own supply chains.
The UK Modern Slavery Act 2015 requires companies to publish an annual statement describing their management of critical issues related to slavery and human trafficking.
In this document, you will find the statements from VALE S.A. subsidiaries Vale Canada and Vale Europe, submitted under the Modern Slavery Act. These statements outline their commitments to safety, sustainability, and respect for Human Rights in their value chains. Vale and its group companies stand against modern slavery and human trafficking in all their forms, and we expect our suppliers to actively combat these issues within their own supply chains and among their subcontractors.
To view these companies’ annual statements, click below:
Whistleblowing Channel and grievance mechanisms
Grievance mechanisms
Whistleblowing Channel
As part of our Ethics & Compliance Program, we operate a Whistleblowing Channel that can be accessed by any person, both within and outside the company, to report suspicions or instances of ethical misconduct.
In 2023, 64% of the reports investigated and confirmed by the Whistleblowing Channel involved interpersonal relationships, including inappropriate behavior, mismanagement, bullying, sexual harassment, and discrimination. To learn more about the primary concerns raised through our whistleblowing channels, refer to our Annual Ethics & Compliance Report.
Remediation
Vale’s commitment extends to addressing and remediating any Human Rights impacts we may cause, contribute to, or be directly associated with. These efforts are implemented either directly or in collaboration with partners. We also seek to engage stakeholders in designing and implementing remediation measures.
Vale places a strong emphasis on precautionary measures to prevent recurrence, and has reevaluated all aspects of the business as part of our strategy to improve sustainability performance. Following the dam breaches in Mariana and Brumadinho, we conducted a comprehensive review spanning areas such as governance, Human Rights management, health and safety processes, operational excellence, operational risk assessment, and remediation.
Vale´s Archive
Stakeholder engagement
Engaging with stakeholders on salient Human Rights issues is important to inform better initiatives and solutions and to advance this agenda across Vale.
We tailor our approach to the unique characteristics of each stakeholder group and the most sensitive issues, using a thematic matrix to guide the focus of our initiatives (see the table below).
Vale´s Archive
Special attention is given to the security teams responsible for protecting the physical integrity of individuals, preserving our assets and information, and ensuring operational continuity. While these teams must have their rights respected, they often deal with conflict situations and must make their best efforts to seek peaceful solutions that respect Human Rights.
Our approach to managing security teams encompasses multiple aspects, from employee selection based on technical competence and emotional stability, through training on Human Rights and the proportional use of force when necessary, to seeking peaceful solutions and treating vulnerable individuals and groups with care. Vale is a signatory of and has implemented the Voluntary Principles on Security and Human Rights (VPSHR), and we maintain an open communication with communities and local authorities for conflict resolution.
We actively engage in significant initiatives through strategic partnerships with organizations tackling salient Human Rights issues such as sexual exploitation of children and adolescents, modern slavery, artisanal and small-scale mining, and living wages. Through these partnerships, we also support the development of standards and procedures, share challenges and best practices, and anticipate and assess global trends.
Notable initiatives and partner institutions include: the Global Business Initiative on Human Rights (GBI); the Voluntary Principles on Security and Human Rights (VPSHR); Childhood Brazil; the Institute for the Brazilian National Pact to Eradicate Slave Labor (InPacto); the World Business Council for Sustainable Development (WBCSD); the Brazilian Business Council for Sustainable Development (CEBDS); BSR; and the International Council on Mining & Metals (ICMM).
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Commitments and targets
Vale has outlined a roadmap to foster continuous improvement in our Human Rights management processes by 2025. This roadmap covers our key operations stages and responsibilities, including:
Policy commitment and integration
- Policy commitment and integration;
- Disseminate our revised Global Human Rights Policy to all employees;
- Incorporate Human Rights content in existing standards;
- Provide Human Rights training to leaders and employees and contractors.
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Risk and impact assessment
• Maintain external Human Rights due diligence on operations and projects;
• Enhance supply chain risk management beyond Brazil.
Monitoring and reporting
• Monitoring action plans resulting from Human Rights assessments and due diligence;
• Track trends and developments in legal requirements and best practices in Human Rights.
Grievance mechanisms and Whistleblowing Channel
Continue to improve reporting mechanisms based on lessons learned and inputs from stakeholder engagement;
Implement reporting systems in all operations, ensuring core requirements are adapted to each site;
Address all allegations including 100% of those identified by the Business and Human Rights Resource Center.
Remediation – beyond priority reparation processes
- Ensure that Human Rights impacts are effectively remediated and, where any of our operations have contributed to or are linked to impacts, ensure that the company is part of the solution.
Partnerships
- Continue our Living Wage program for employees, providing decent wages consistent with global benchmarks.
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Initiatives
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Iniciativas
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Initiatives
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