The Sandvik Compliance System includes four areas: Anti-Bribery and Corruption, Competition Law, Third-Party Management and Data Privacy. To emphasize the importance of a fully embedded and agile Compliance System within the business, the Compliance System is part of our 2030 Sustainability goals. The purpose is to ensure a well-functioning structure with control over our international business and to manage compliance risks in all countries in which Sandvik operates. The compliance program requirements are set by Group Compliance, including compliance risk identification, policies, applicable training, controls, audits, reporting and monitoring etc., and are implemented by each business area. The Group Compliance function reports to the Sandvik Group General Counsel and the Audit Committee.
To coordinate work, identify synergies and drive continuous improvements, a Compliance Functional Council, consisting of representatives from Group and business areas, has been established. The Council has been in operation for several years and normally meets quarterly.
Sandvik is active in countries and industries with a high risk from a corruption perspective and as such could potentially have a significant impact on both people and environment. Sandvik has an anti-corruption compliance program based on zero-tolerance for corruption. Steering documents include the Code of Conduct, an anti-corruption policy, procedures for commercial intermediaries, administrative intermediaries and gifts, hospitality, travel and entertainment. Requirements designed to identify and prevent corruption are also embedded in other steering documents such as the Sponsorship and Community Involvement procedure and M&A procedure. The Speak Up policy and the underlying investigation procedure are other important parts of the program.
All operational entities are required to assess and, together with the compliance organization, work with its own compliance risks and thus identify and prevent potential negative impacts. Actions taken are reviewed by both internal and external audit. Negative impacts and weaknesses are also identified and remediated through the Speak Up process. Targets and indicators to evaluate progress are set annually through the Compliance Functional Council and have included, for example, yearly self-assessments, including anti-corruption, to create action plans to close identified gaps and to complete those within deadlines.