Sandvik manages compliance risks through a compliance program with a collective oversight through a Group function in four areas: anti-bribery and corruption, competition law, trade compliance and data privacy. In 2020, the strategic work mainly focused on the roll-out of a compliance tool, the Compliance House. The Compliance House is a tool which enables all levels of the company, from each individual business unit to the Board of Directors, to get an overview of the requirements in the four compliance programs that are relevant to them, the respective risk levels and the current status of their compliance activities. The purpose of the Compliance House is to further embed compliance into the business and allow entity level monitoring of risks and compliance status. Our 2020 target to implement the Compliance House at 25–50 percent of Sandvik entities was met.
Compliance training was offered to employees in different formats, including e-learning, webinars and classroom training. A total of 8,538 (3,800) participants received training.
There were extensive activities in the trade compliance program area in 2020 due to continued Brexit preparations, trade wars and a number of changes in customs tariffs and international sanctions imposed by the US government and other countries. For data privacy, anchoring of data privacy networks and formal processes as well as publication of formal governance documents, expanded awareness training, and work to begin scaling and leveraging the European GDPR program for a more global reach, were begun and underway.
Sandvik has zero tolerance for bribery and corruption. In 2020, the implementation of processes and systems to handle risks related to administrative intermediaries, such as customs agents, was in focus.
We have a competition law compliance program in place 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 2020, 3,583 (1,500) employees received training in competition law. Training in this area is repeated and updated every second year. Comprehensive competition law guidelines are available for all employees who are also encouraged to seek advice from Sandvik Legal Support teams in case of doubts about the legality of a business activity.
Sandvik received no significant fines or non-monetary sanctions for non-compliance with laws or regulations related to our four areas.