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.