Why it matters
Integrity is a core value for Nutrien. Operating with integrity enables us to achieve our Purpose in our everyday interactions and proactively prevent, manage and mitigate risks. Ethics, integrity and a respect for human rights relate to how we conduct business and enable us to grow our world by striving to do the right thing every day.
We promote trust, ethics, teamwork and professionalism, across our operations and across partnerships.
Our work on integrity supports the following United Nations Sustainable Development Goals
We are committed to the principles of fair competition and compliance with all global antitrust and competition laws applicable to our operations. Anti-competitive behaviors with competitors or customers and other third parties (for example, governments) are prohibited. 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.
Bribery and corruption:
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.
Across the organization, various committees facilitate discussions that identify and address issues to uphold our value of integrity. These include our Audit Committee of the Board of Directors, our ELT, and our network of Integrity Officer-led committees at global, regional or country levels, supported by our Integrity Group.
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.
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 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).
Our efforts with respect to human rights include:
- A Code of Conduct and annual training for all of our employees globally. Individuals working in higher risk areas and jurisdictions receive additional online and in-person training on key legal and compliance risks.
- A confidential, externally administered Integrity Helpline that employees, suppliers, customers or anyone else can access via telephone or web portal and in their preferred language, anonymously if desired. Nutrien’s investigations process is a key part of our Integrity Program.
- Nutrien’s external auditor conducts independent auditing of our Code of Conduct training and Integrity Helpline records.
- Ethics that all of our suppliers must comply with, including requirements covering:
Health and safety of employees
No toleration for abuse, harassment or discrimination
Commitment to not participate in forced compulsory labor or human trafficking
Commitment to reflect the diversity of the communities in which their business operates to grow opportunities for Aboriginal, minority and women-owned businesses
Not to employ persons below the minimum age permitted by local law and the core conventions of the ILO including ILO Convention 138 and in no circumstances engage in the “worst forms of child labor” contrary to ILO Convention 182.
Procurement Diversity and Inclusion Procedures designed to ensure fair consideration to all potential suppliers, giving diverse suppliers and their communities opportunity and support. This includes our Indigenous Content Playbook.
In each of the above and other practices, we put special emphasis on the rights of the most vulnerable groups that may be impacted by our operations, including Indigenous peoples, women, and children. Wherever we operate, we engage with communities to build strong and healthy relationships with the goal that communities are better off as a result of our presence.
Nutrien's Integrity Program provides the knowledge and tools for all employees to achieve business results the right way – with integrity. This program consists of risk intelligence, learning, speaking up and investigations.
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.
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.
In 2021, we launched an integrity culture questionnaire initiative that reaches out to a representative sample of employees across the entire company. Employees remain anonymous but the responses enable us to understand what we are doing well and where we have room to improve in particular geographies, business units and functions.
All employees, directors and officers must complete mandatory Code of Conduct training annually. The 2021 training included Nutrien’s purpose and values; fostering our speaking up culture; cybersecurity; data privacy; respect in the workplace (including EDI and anti-harassment); conflicts of interest; anticorruption; fair competition; fair purchasing practices; insider trading; and safety. We update and rotate topics from year to year as part of our risk-based training strategy. We also provide refresher training on a periodic basis to address new or changing legal and compliance risks.
Integrity Moments involve sharing personal or other examples or stories about integrity in action at the start of meetings, including at Nutrien Board meetings. This approach helps 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 meetings, through memos, during integrity and safety shares, and via training. Leaders are also expected to adhere to and promote our “open door” policy. We always strive to protect the anonymity of anyone who raises a concern regarding suspected misconduct. There is zero tolerance for any retaliation against someone who raises a concern or otherwise participates in the investigation process in good faith.
Read more on page 114 of the 2022 ESG Report.
We 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. All necessary and appropriate actions are taken based on investigation findings.