Relevant GRI Indicators

NF6 Compliance

Sandvik manages compliance risks through a Sandvik Compliance program and in 2021 we performed a 90-day review of the program. Subject to the review was the Group Compliance structure and organization, a new Group Compliance functional structure and a new Group Compliance strategy. A new functional structure that will strengthen the governance between Group requirements, Business Area execution and the Group Compliance monitoring and reporting was introduced. The compliance areas of Anti-Bribery and Corruption, Competition Law, Trade Compliance and Data Privacy will remain, but they will be integrated into and managed through four new functions – a Compliance Program Office, Third-Party Management, Global Compliance Technology and Projects, and Culture and Business Ethics. The purpose is to support further program integration and efficiency with the business areas, establish a group compliance program reporting structure and, together with Internal Control, Internal Audit and External Audit, clarify, test and review requirements and increase transparency. The Trade Compliance function was renamed Third-Party Management and its scope was expanded to also include due diligence and Know-Your-Customer. Within Data Privacy we focused on data privacy networks, formal processes and publication of formal governance documents, expanded awareness training, and scaling and leveraging the European GDPR program for a more global reach. The new Schrems II requirements (personal data transfers from EEA to non-EEA countries and new standard contractual clauses, SCC) and the implementation of cookie-compliant websites were other focus areas.

The Compliance House continued to be highly prioritized as a cornerstone of our Group Compliance program. Our 2021 target to implement the Compliance House within 100 percent of Sandvik entities was achieved. We prepared for operationalization of the Compliance House in 2022, including the introduction of new guiding principles on how to use, maintain and continuously update the Compliance House as the business operations, risks and requirements changes.

Compliance training was offered to employees in different formats, including e-learning, webinars and classroom training. A total of 11,593 (8,538) participants received training.

Sandvik has zero tolerance for bribery and corruption. In 2021 there was a continued focus on the roll out of processes and systems for affiliated and commercial intermediaries across the business areas.

The compliance program relies on frequent training online and in-person for employees exposed to the respective risks. In 2021 we targeted training within the Anti-Corruption and Bribery and Data Privacy areas with 3,490 (1,480) employees receiving training in ABC and 4,261 (1,389) having received training in Data Privacy. We have a competition law compliance program in place to mitigate risks associated with competition or antitrust laws in all countries where Sandvik operates. Comprehensive competition law guidelines are available for all employees who are also encouraged to seek advice from Group Compliance in case of doubts about the legality of a business activity. The program relies on frequent e-learning and in-person training for employees who may be exposed to competition law risks in their work. For competition law 273 (3,583) employees received training. The latter is repeated every second year and therefore subject to a refresher in 2022.

Sandvik received no significant fines or non-monetary sanctions for non-compliance with laws or regulations related to our four areas.