Anti-corruption

Aspect Specific DMA

Boliden’s Code of Conduct provides a framework for what Boliden considers to be responsible conduct – it is not exhaustive. Our employees should always strive to exercise good judgement, care and consideration in their work for Boliden.

The Code of Conduct applies to all employees throughout the Group, to the members of the Board of Directors of Boliden AB, and to its subsidiaries. Business ethics are covered in Boliden’s Code of Conduct, but recent legislation has imposed new demands on Boliden and thereby generated a need to provide a more focused anti-corruption policy and guidelines. As a starting point, a group-wide risk survey was carried out in 2012 to identify any potential corruption-related risks. Functions with external contacts were prioritised. Based on the outcome of the survey, Boliden revised its anti-corruption policy and guidelines and the new version was adopted by the Board of Directors. The organisation’s anti-corruption policy and guidelines, and the new competition law policy and guidelines, added 2015, form an inherent part of the Code but are included in separate documents.

 

SO4 Training in anti-corruption policies and procedures

Boliden´s line managers are responsible for making the Code of Conduct and the Anti Corruption policy known, promoting and monitoring compliance within their respective organizations.

All managers and other employees, whose work involves extensive external contacts with business partners, in particular with suppliers or agents, are subject to anti-corruption training appropriate for their area of responsibility, starting with the Management Development Programme – a training programme for Boliden’s top 130 managers.

All of our employees, together with agents, suppliers and other third parties acting on Boliden’s behalf, must comply with the Group’s Anti-Corruption Policy and Guidelines. These documents are available as part of Boliden’s Management Manual on the intranet. All white-collar employees (1,588 employees in September 2013) were invited to a mandatory e-learning training session in September 2013 in order to increase their knowledge of our anti-corruption and anti-bribery work. The training was available in Swedish, Norwegian, Finnish and English, depending on where the participants were based. Boliden is in the process of developing, updating and renewing training sessions and completion of a new e-learning course to be launched in 2017, which will be mandatory for all whiteh collar employees.

Boliden has a whistle-blower function which can be used to anonymously report suspected cases of criminal activities or other serious misconduct.

SO5 Incidents of corruption

There are no confirmed incidents to report. During the latter part of 2016 an investigation into a whistle-blower case was initiated. The investigation is not finished at the time of reporting.