Hydro's overall CSR strategy was reviewed in 2011. The strategy is built upon four pillars:
- Integrity and anti-corruption
- Community and stakeholder engagement
- Human rights
- Supply chain and product stewardship
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. 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.