Legal framework and compliance

The Group Ethics & Compliance function is organized within Boliden’s Corporate Responsibility department and supports Boliden to conduct its operations in accordance with relevant national and international laws and regulations within several areas. The function ensures that relevant internal policies and instructions are in place and oversees the compliance with these. It regularly reports to the Group Management Team and the Audit Committee of the Board.

The Ethics & Compliance function is responsible for the areas of anti-corruption, competition law, protection of personal data, trade sanctions, human rights, anti-money laundering and anti-terrorist financing. Additional areas of responsibility are the Boliden Code of Conduct and Business Partner Code of Conduct as well as handling and investigating cases received via certain grievance channels. Ethics & Compliance supports the purchasing and sales functions to evaluate business partners from an ethics and compliance perspective. The Ethics & Compliance function also holds trainings as well as provides advice and recommendations on specific issues to management teams and other parts of the business.

Boliden’s Code of Conduct provides a non-exhaustive framework for responsible conduct at work. It is based on our values – Care, Courage and Responsibility – which should guide Boliden employees in their daily decisions. The code covers topics such as health and safety, diversity and inclusion, environment, conflicts of interest, fair competition, anti-bribery and corruption, insider information and market abuse. It has been approved by Boliden’s Board of Directors and applies to all Boliden employees, including temporary personnel, worldwide, as well as to members of the Boards of Directors of Boliden AB and its subsidiaries.

Line managers are responsible for making the policy known and for promoting and monitoring compliance. Violations of the Code of Conduct are not tolerated and may lead to internal disciplinary action, dismissal, or even criminal prosecution. Should an improper practice or incident occur within Boliden, the company is committed to make the necessary corrections and will take remedial action to prevent recurrence.

A handbook on Boliden's Code of Conduct is under development. The handbook will provide detailed and practical guidance on acceptable conduct when working for, or with, Boliden. It will lay out the expectations regarding behavior towards colleagues, how to do business and Boliden’s role in society. The handbook will be used as a complement to the Code of Conduct policy document that already exists today and will be published and rolled out during 2023.

The Code of Conduct is supplemented by the Business Partner Code of Conduct, which must be adhered to by all customers, subcontractors, suppliers, consultants, agents, and exploration partners. It is included in agreements with these parties and outlines our minimum expectations on them regarding ethics and compliance. The Business Partner Code of Conduct covers topics such as fair working conditions, discrimination and harassment, anti-bribery and corruption, and fair competition.

The business partner evaluation process is continuously developed. We also regularly update compliance related standard contract clauses that are incorporated into contractual agreements with our business partners.

The Code of Conduct and the Business Partner Code of Conduct can be found on www.boliden.com. Read more about our Business Partner Risk Management Program here.

We recognize that we have an impact on human rights throughout our operations and beyond. We conduct business in complex markets, are the largest private sector employer in some regions, and some of our operations are located in areas that are important to indigenous peoples. We know that the way we do business affects our employees, contractors, the communities we work in and workers in the value chain, as well as others affected by Boliden’s activities and business relationships. Respecting and promoting human rights has been a natural part of how we do business for many years, which is why human rights principles are embedded in several of our internal policy documents.

Our Business Partner Code of Conduct sets out a clear expectation that those we do business with, including both customers and suppliers, must respect human rights. This includes providing fair remuneration and an adequate living wage, respecting the right of workers to form and join trade unions, and a zero tolerance to forced, compulsory and child labor.

Under no circumstances may child labor be employed or used in our operations – either directly or indirectly through our business partners. All business partners must comply with this by agreeing to Boliden’s Business Partner Code of Conduct. Any business partner may be subject to visits or third-party audits at the business partner sites to ensure compliance.

We take human rights seriously and have begun work to define a Group-wide framework on human rights and to further develop our due diligence processes.

In 2022, we followed up and reviewed our Group-wide risk screening of the company’s direct and indirect impacts on human rights in line with the UN Guiding Principles on Business and Human Rights. The screening identified potential risks as the work did not take internal policies, processes, and other safeguards into account. The final report showed a total of 17 heightened human rights risks, including seven that were deemed salient (at higher risk). The majority of the risks were related to our supply chain. During the year, a Human Rights Commitment was published that compliments the previously published Indigenous People Commitment.

Boliden adheres to the UN Declaration of Human Rights and the ILO’s fundamental conventions. If human rights are suspected to have been violated in connection to our business, any stakeholder is encouraged to report it to their contact person at Boliden, the local management or via Boliden’s whistleblowing function or local grievance mechanisms.

Our whistleblowing function enables employees, business partners and other stakeholders to raise concerns on actual or suspected serious wrongdoings within the Boliden Group. Cases can be reported 24 hours a day, all year round through our online channel via Boliden’s intranet or external website.

The whistleblowing system is hosted by an independent and external third party. All information received through the whistleblowing function is treated with confidentiality and all messages are encrypted. A whistleblower can submit a report anonymously and follow the status of the case without disclosing their identity. A whistleblower does not need to have firm evidence to report their suspicion but the report must have been made in good faith. Boliden applies zero tolerance for retaliation against anyone who reports wrongdoings in good faith.

The whistleblower function is managed by the Group Ethics & Compliance function, with support from a cross-functional team of senior staff. During 2022, there were 16 reports filed, where four were in regards to health & safety, three to environment, one to HR, four to harassments, three to fraud and one to conflicts of interest.