Hydro's Code of Conduct is approved by the board of directors. Based on this, 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 5000 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.
