205–1 Operations assessed for risks related to corruption
During 2020, Boliden conducted a group-wide risk assessment specifically targeting anti-bribery and corruption, supported by an external law firm. The assessment addressed Boliden’s entire operations and followed a structured approach including employee interviews, a document review and a desktop review of static risks. The report will lay the foundation for Boliden’s future work with anti-bribery and corruption throughout the whole company. Certain high risk areas such as agents, distributors and logistics providers will be addressed more carefully in the compliance work going forward.
205–2 Communication and training in anti-corruption policies and procedures
Boliden’s line managers are responsible for making the Code of Conduct and the anti-corruption policy and guidelines known to all employees, and for promoting and monitoring compliance. All employees whose work involves more regular contact with external business partners, in particular with competitors, suppliers, customers, or agents, are subject to anti-bribery and anti-corruption training appropriate for their area of responsibility.
The anti-bribery and anti-corruption training program has been reccurring every three years. The courses target a selected group of employees, normally those dealing with or having contact with potential competitors. The last e-learning was given to 2063 white collar workers. In 2020, Boliden engaged in a number of additional steps to communicate and train employees in its existing anti-bribery and corruption compliance program. For example, in-depth interviews with personnel throughout the risk assessment work, presentations of Boliden’s ethics and compliance function for senior management, external legal advice on risks presented by specific raw material suppliers, and a roll-out of updated resources in relation to Boliden’s due diligence process of business partners. Further, 159 persons initiated an anti-money laundering training which will be completed in early 2021.
205–3 Confirmed incidents of corruption and actions taken
Boliden is committed to the highest standards of ethical business conduct. Actual or suspected incidents of bribery or corruption can be reported anonymously or openly via Boliden’s whistleblower reporting system. There were no confirmed cases of corruption during 2020.