Anti-corruption and fair competition

We work against corruption in all its forms, including extortion and bribery. Efforts to combat bribery and corruption are an important part of our ethics and sustainability work and we apply a zero-tolerance approach.

Compliance with anti-bribery and anti-corruption regulations is one of the key focus areas within Boliden’s Group Ethics & Compliance function. Our Anti-Corruption Policy, Code of Conduct and Business Partner Code of Conduct set out measures to prevent corrupt behavior and improper influence. We apply zero-tolerance for bribery and corruption, including the facilitation of payments, and conflicts of interest shall be reported and addressed. Detailed guidance on prohibited behavior as well as gifts, hospitality, benefits, and conflicts of interest are addressed in Boliden’s Anti-Corruption guidelines.

Boliden’s Anti-Corruption Policy has been approved by the Board of Directors and applies to all individuals acting in Boliden’s name or on Boliden’s behalf including employees, management, members of the Board, consultants, and agents of the Boliden Group. The Anti-Corruption Policy also applies to companies and joint ventures in which Boliden has an interest, and to third parties that act for or on behalf of Boliden.

The Boliden Anti-Corruption Policy is based on Group-wide risk assessments and compliance controls to ensure its relevance and mitigate any risk factors. We have identified three major areas to focus on: agents, suppliers in high-risk countries and training.

We have sanctions controls in place for all parties that we intends to enter into agreements with. Regular screenings are also conducted on our existing supplier, customer and business partner base.

Since Russia's invasion of Ukraine in 2022, it has become increasingly important for companies to keep up to date with the latest international sanctions and to have good knowledge of all business partners and their potential connections with sanctioned parties.

In 2022, we updated our Sanctions Policy, which includes instructions for sanctions controls and contractual sanctions clauses to reflect the increased risk during the year. We conducted control activities to verify the good management of our business partner relations and we implemented broader and more frequent monitoring of high-risk business partners. The Ethics & Compliance and Legal department together with selected managers joined an information and Q&A session with our external law firm that supports Boliden on sanctions related matters to listen in on important updates about the sanctions landscape and to raise questions. General trainings for affected groups are planned for 2023. We keep updated on the latest legislation and their potential impact on our business, and we expect sanctions to increase in importance going forward along with the need for comprehensive monitoring.

In 2022, we ensured that local routines and instructions related to our Anti-Money Laundering Policy had been implemented to further support the business to comply with the policy. This was followed by training for everyone working with payments at Boliden. To verify that each Business Unit is in compliance with the policy, internal audit routines were developed and implemented.

Boliden’s employees and Members of the Board must comply with all applicable anti-trust and competition laws, Boliden’s Code of Conduct, and Boliden’s competition law policy. Sharing, discussing, or disclosing information that may be sensitive from a competition viewpoint is prohibited.

In 2022, Group Legal completed training on competition law for relevant employees. An update of distribution agreements was also completed and a training on the EU's new Vertical Guidelines and its impact on Boliden’s distribution agreements was developed but not completed for relevant employees within the Smelters Business Area.