Respect in the workplace is the foundation for doing business with integrity. This is important both for our employees as well as our business partners, such as our suppliers. We are committed to respecting and observing all human rights, in accordance with applicable law and the principles set forth in applicable international standards, including the Voluntary Principles on Security and Human Rights and the core conventions of the International Labor Organization (“ILO”) and the United Nations (“UN”), such as the UN’s Universal Declaration of Human Rights, the UN’s Declaration on the Rights of Indigenous Peoples, and the UN’s Guiding Principles on Business and Human Rights.

For a business the size and scale of Nutrien, anti-competitive behavior can expose individuals and our business to significant penalties and impair our reputation in the marketplace. We are committed to the principles of fair competition and compliance with all antitrust and competition laws applicable to our operations around the world. Anti-competitive behaviors with competitors or customers and other third parties (for example, governments) are prohibited, including price fixing, agreements to limit production, exchanging competitive information and predatory pricing. Our Competition Law Policy outlines Nutrien’s strict expectations of all employees, officers and directors, as well as third parties such as distributors, agents, resellers and contractors.

Nutrien conducts business around the world, including in geographies that face higher levels of corruption. We are committed to doing business the right way. Our Anti-Corruption Policy sets forth the acceptable behaviors for interacting with government officials and commercial partners. We have a zero-tolerance policy for bribery, whether our own employees are involved or third parties who are acting on our behalf.

Nutrien’s risk intelligence activities include assessment and mitigation tools for human rights, compliance, integrity and legal factors that are available to employees on a risk basis considering their specific role and, sometimes, location. These tools include trade sanctions due diligence, customer and supplier reputation due diligence, and our Enterprise Risk Management (“ERM”) program. 

Human rights and anti-corruption

Nutrien identifies and assesses human rights-related risks annually as part of our global ERM process and through our ESG material topic analysis. Nutrien has no fertilizer production operations in countries with high levels of corruption risk as determined by Transparency International’s Corruption Perception Index (that is, the countries that are part of the 20 lowest rankings). 

Mergers and acquisitions

Nutrien continues to grow through acquisitions. We integrate compliance and integrity assessments and training into our due diligence and integration process for new acquisitions to verify that our growing Company continues to build and maintain a culture of integrity in line with our core values. These activities also serve to mitigate legal and financial risks as the business grows, such as those related to bribery and corruption. Compliance and integrity integration activities are risk-based and range from deployment of Nutrien policies, alignment of key processes with Nutrien’s programs and provision of training. 

Third-party due diligence

In 2022, we developed updated legal and compliance risk assessment tools that are being further integrated into the supplier evaluation, onboarding and monitoring processes across the Company. Our Integrity Group also worked closely with Nutrien’s operating segments and provided guidance on the often-fluid changes in trade sanctions regarding Russia and Belarus due to the war in Ukraine. 

Integrity culture questionnaire

In 2022, we continued an initiative started in 2021 that regularly and anonymously surveys a representative sample of employees across Nutrien about our integrity culture, including psychological safety. The monthly survey responses enable us to understand what we are doing well and where we have room to improve by region, operating segment and corporate function. The results are used to create a dashboard for our Integrity Group, Human Resources and SHE function to take action, such as to deploy targeted training that addresses emerging issues.
 

Training and communications

All employees, directors and officers must complete mandatory Code of Conduct training annually. The 2022 training included Nutrien’s purpose and values; fostering our “speaking up” culture; cybersecurity; data privacy; respect in the workplace (including anti-harassment, discrimination, inclusion, unconscious bias, microaggressions and psychological safety); conflicts of interest; gifts and entertainment; careful communications; and safety. We update and rotate topics from year to year as part of our risk-based training strategy. 

Integrity Moments

Integrity Moments involve sharing stories that show integrity in action (personal or otherwise) at the start of meetings. Integrity Moments help to foster and normalize discussions about our core value of integrity in our everyday work. 
 

One of the most important ways to do business with integrity is to speak up by asking questions and reporting concerns about situations that may violate the Code or an associated policy. Among several other options for speaking up (for example, in-person, email, instant messaging, direct phone calls), Nutrien also provides an externally administered Integrity Helpline for employees and anyone outside Nutrien to ask questions and report integrity concerns, with service available in seven languages. 

Speaking up is promoted throughout the year with various communications on Nutrien’s intranet, in townhall sessions, through memos, during integrity and safety shares, and via training. Leaders are also expected to adhere to and promote our “open door” policy. This means that they are available to anyone with integrity concerns, questions or complaints, and they encourage an environment where our employees feel comfortable speaking up. We always strive to protect the identity of anyone who raises a concern regarding suspected misconduct. A reporter can choose to remain anonymous when they report a concern, whether through the Integrity Helpline or any of our other reporting methods. There is zero tolerance for any retaliation against someone who raises a concern or otherwise participates in the investigation process in good faith. 
 

We strive to maintain a speaking up culture where all concerns related to the Code (as well as an associated policy) will be investigated under the oversight of the Integrity Group. All questions and concerns are taken seriously and handled promptly, confidentially and professionally, in accordance with our compliance investigation principles, which include:

• Maintain independence to preserve the integrity of the investigation process.
• Efficiently use resources to conduct the investigation in a time-and cost-sensitive manner, as well as avoiding unreasonable disruption to business operations from the investigation process.
• Remain mindful and avoid duplication of other processes for resolving employee concerns (for example, union grievance process).
• Utilize an effective and thorough process for gathering facts and reaching reasonable conclusions regarding substantiation and any disciplinary and/or corrective action.
• Treat information received and generated as strictly confidential – only share with authorized people who need to act in direct support of the investigation.
• Maintain sensitivity to protecting the identity of the person raising the allegation and the person against whom the allegation was raised.
• Treat everyone involved in an investigation with respect and dignity.
• Keep an open mind – do not seek to prove or disprove the allegation – simply determine what happened and address it appropriately.
• Separately investigate any allegations of retaliation.

All necessary and appropriate actions are taken based on investigation findings.

Learn more on pages 88-91 of the 2023 ESG Report