At Sandvik, we are committed to conducting our business with honesty, integrity and high ethical standards to meet legal requirements as well as stakeholder expectations. Our compliance programs, addressing anti-bribery and corruption, competition law, trade compliance and data privacy, are an important part of our work.
Sandvik’s compliance programs are designed based on guidance provided by major regulators and organizations. Sandvik manages risks in four compliance areas – anti-bribery and corruption, competition law, trade compliance and data privacy – by formulating measures to prevent, detect and respond to breaches of law. These measures are implemented in the business with the advice and assistance of the compliance functions. One example is that employees and other stakeholders are encouraged to report any deficiencies or breaches of compliance through Sandvik’s Speak Up system (see Doing things right). During 2018, the strategic work has mainly focused on improving the assurance through increased follow-up and reporting as well as having better integration of Sandvik’s assurance functions. Different compliance training was offered to employees in the form of e-learning, webinars or classroom training. A total of 10,000 participants received training.
The trade compliance program addresses customs, sanctions and export controls. This area was demanding in 2018 due to Brexit preparations, as well as a number of changes in customs tariffs and international sanctions imposed by the US government and other countries.
Anti-bribery and corruption
Sandvik has zero tolerance for bribery and corruption. In addition to regular operational work such as training and due diligence, a new IT system was implemented during the year to support the anti-bribery due diligence and management of commercial intermediaries. A revised procedure for handling gifts and entertainment was also introduced.
Each of the compliance programs comprise the following elements:
- Identification and assessment of risks
- Controls (including policies, procedures and record keeping)
- Enabling and enforcing
- Follow up, reporting and improvement
- The organization
With our competition law compliance program, we aim to mitigate risks associated with competition or antitrust laws in all countries where Sandvik operates. The program relies on frequent e-learning and in-person training for employees who may be exposed to competition law risks in their work. In 2018, about 4,000 employees received training in competition law. Training in this area is repeated and updated every two years. Comprehensive competition law guidelines are available for all employees who are also encouraged to seek advice from Sandvik Legal Support teams should they have any doubts about the legality of a business activity.