Neville Tiffen (Global Head of Compliance, Rio Tinto) - Presentation at the United Nations Association of Australia (Victorian Division) Corporate Sustainability Leadership Seminar ‘Building Business Integrity, Preventing Corruption’ held on Wednesday 27 February 2013, in partnership with ANZ. The seminar explored some of the key issues facing Australian businesses operating in high-risk environments and provide examples of how different companies have addressed these challenges through anti-corruption programs and transparency mechanisms. Guest Speakers included: • Michael Ahrens (Executive Director, Transparency International Australia) • Neville Tiffen (Global Head of Compliance, Rio Tinto) • Mathew Bastianon (Manager, Anti-Money Laundering, Bribery and Corruption, ANZ) • Dean Newlan (Partner, McgrathNicol and Former Chair of Standards Australia’s Fraud and Corruption Control Standard and Whistleblower Protection Standard Working Parties). • Rachel Nicolson (Director, UN Global Compact Networks Australia and Senior Associate, Allens) Facilitator: • Rosemary Sainty (Adviser, Corporate Engagement, Transparency International Australia and Former Head, Secretariat, UN Global Compact Network Australia) The panel discussion addressed: • Implementing corporate anti-corruption programs: challenges and opportunities; • Key issues for the extractive industry, financial and professional services, and SMEs; • Opportunities for collective action, sectoral initiatives and engaging suppliers and business partners; • Beyond compliance: building business integrity and transparency; • Transparency International’s Business Principles for Countering Bribery: revision and update, and 2012 report on Transparency in Corporate Reporting; • UN Convention Against Corruption; • UN Global Compact Principal 10 on Anti-Corruption; and the • B20 Task Force on Improving Transparency and Anti-Corruption. More information available at: http://www.unaavictoria.org.au/education-advocacy/masterclasses/building-business-integrity-preventing-corruption-seminar/

1. Corporate Sustainability Leadership:
Building business integrity,
Preventing corruption
Neville Tiffen
Global Head of Compliance
ntcompliance@gmail.com
February 2013

2. Global spread of operations
Key Aluminium
Mines and mining projects Copper
Diamonds & Minerals
Smelters, refineries, power
facilities and processing Energy
plants remote from mine Iron Ore
North
America Europe
Asia
Africa
South
America
Australasia

3. Corruption perception index by location

4. Collective action
• Transparency International
• Business Principles
• Transparency in Reporting on
Anti-Corruption
• WEF’s PACI
• Anti-corruption principles
• Mongolia project
• G20/B20
• UN Global Compact Principle 10

5. Transparency International
Business Principles
• Continuing risk assessment
• Conflicts of interest
• Lobbyists
• Facilitation payments prohibition
• Board commitment
• Business relationships
• Independent assurance
TRAC
 Standards on website
 SD and Global Compact reports on
website
 Country reporting
 Reporting on monitoring
 Transparency: stakeholders’
understanding of how we work

6. Partnering Against Corruption Initiative
Principles
• Based on TI principles
Mongolia
• Local company participation
B20
• Public procurement
• SMEs
• Collective action
• High level reporting
mechanisms

7. Designing the programme
“The Age”

8. Designing the programme
• Bribery laws – Australia, UK, US
• US Federal sentencing
guidelines/FCPA guidance
• Morgan Stanley
• UK Bribery Act guidance
• “corporate culture”
• Sarbanes Oxley
• Dodd Frank
• Australian and British standards
• TI Business Principles
• PACI principles

9. The way we work
Our global Code of Business Conduct
• Each of us has a responsibility to
work with integrity when acting
on behalf of Rio Tinto…
• In every country in which we
operate, all Rio Tinto personnel
are expected to comply with the
law, The way we work and Rio
Tinto policies and standards.

10. Our 9 Standards

11. Our 9 standards

12. Compliance Standard Overview
Compliance
obligations &
risks
Risk
Group business
reduction
audit forums
training
Compliance
Standard
Monitoring
Communication
&
(incl portal)
review
Speak-OUT Investigations

13. Investigations standard – serious wrongdoing

14. 14
Speaking up
Various options:
– Your manager or supervisor
– Human Resources
– Senior management
– Rio Tinto Compliance
or
Speak-OUT

15. Speak-OUT
• Toll free numbers 24/7
• Translation available
• Confidential
• Anonymous option
 EU restrictions
• Operated by independent 3rd
party
• Calls answered by trained
interviewers
• Managed by Compliance Team
• No recrimination
• 50% of calls result in some
action

16. Morgan Stanley
• Updated policies
• Frequent training
• Due diligence and
transaction monitoring
• State owned enterprises
• Reminders about the
code of conduct and
related matters
• Certifications
• Conflicts of interest

17. Questions/Comments

18. Neville Tiffen
ntcompliance@gmail.com