Material Topic: Anti-Corruption

205–1  Operations assessed for risks related to corruption

Business ethics are covered in Boliden’s Code of Conduct. ­Corruption and conflicts of interest are, furthermore, addressed in Boliden’s anti-corruption policy and guidelines. These governing documents set out appropriate measures to prevent corrupt behavior and improper influencing. The documents are based on Group-wide risk assessment surveys in order to ensure their ­appropriateness for the business operations in question, particularly within procurement, and to address and mitigate any risk factors. Efforts to combat bribery and corruption are an important part of Boliden’s sustainability work and Boliden applies a zero tolerance policy in this respect. No form of bribery or corruption is acceptable, and conflicts of interest must be reported and addressed. Boliden’s anti-corruption program applies to both the Board of Directors and employees of the Boliden Group. This anti-corruption policy also applies to companies and joint ventures in which Boliden has an interest, and to third parties who act for or on behalf of Boliden. Great emphasis is, in addition to the anti-corruption work, placed on compliance with applicable competition regulation and Boliden has adopted a policy addressing this issue.

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, and for 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. All white-collar employees can carry out e-learning training sessions from time to time in the fields of ­anti-corruption and anti-bribery, and during the year 2,063 employees were offered the chance to participate in an e-learning course in this subject. The courses are normally offered in Swedish, Norwegian, Finnish, and English, depending on where the participants are based.

205–3  Confirmed incidents of corruption and actions taken

Boliden has a whistle-blower function that can be used to report suspected cases of economic crime anonymously in order to discover potential misconduct.

Any instances of discrimination, harassment, corruption, regulatory breaches, or other inappropriate conduct shall also be reported. The issue shall, initially, be addressed by means of discussion with the individual’s immediate superior, and secondarily with the company’s HR function or via the whistle-blower function. Boliden’s whistle-blower function offers an anonymous channel for reporting suspicions of certain types of economic crimes and other types of misconduct. Nine cases were reported in 2018 through Boliden’s internal whistle-blowing function. Eight of these were not, however, classified as Whistle-blowing cases, as defined by Boliden. The definition states that only concerns regarding serious wrongdoings committed by people in leading positions or key personnel within the group should be reported through the whistle-blower channel. One case submitted via Boliden’s whistle-blower function was investigated with the help of an external party during 2018. The investigation, which concerned alleged improprieties in respect of procurement at one of the production units, led to a further tightening of the rules regarding employees’ relationships with suppliers.