205–1 Operations assessed for risks related to corruption
Business ethics are covered in Boliden’s Code of Conduct. In addition hereto, corruption and conflicts of interests are addressed in Boliden’s anti-corruption policy and guidelines. These governing documents set out appropriate measures to prevent corruptive behaviour and improper influencing. The documents are based on Group wide risk assessment surveys in order to be appropriate for business carried out,in paticular within procurement, and to address and mitigate any risk factors.
205–2 Communication and training in anti-corruption policies and procedures
Boliden’s line managers are responsible for making the Code of Conduct, the Anti Corruption, and competition policy known, promoting and monitoring compliance within their respective organizations and to their respective counterparties. All managers and other employees, whose work involves more regular external contacts with business partners, in particular with competitors, suppliers, customers, or agents, are subject to anti-corruption and competition training appropriate for their area of responsibility, starting with the Management Development Programme – a training programme for Boliden’s top 130 managers, including top management. All white-collar employees must carry out mandatory e-learning training sessions from time to time in the fields of anti-corruption and anti-bribery. The learning courses are normally offered in Swedish, Norwegian, Finnish, and English, depending on where the participants are based. During 2017, Boliden has updated its anti corruption policy and guidelines in order to make them even more user friendly. The launch of the new policy which is subject to board approval, is planned to the beginning of 2018, with renewed training sessions and e-learning to follow.
Boliden has a whistle-blower function which can be used to anonymously report suspected cases of economic crime in order to discover potential misconduct.
205–3 Confirmed incidents of corruption and actions taken
During 2017 an investigation was initiated based on allegations received through Boliden’s whistle-blower reporting channel the investigation was conducted with external assistance in addition to internal resource. There was no evidence of misconduct, nevertheless it was resolved to introduce additional enhanced routines for purchasing and procurement.