Business partner Environmental, Social and Governance (ESG)Assessment

We evaluate potential business partners before entering into agreements with them, as well as during the business relationship. After onboarding, the business partners are monitored throughout the business relationship. Updated due diligence is performed regularly throughout the entire period of the business relationships.

We conduct systematic evaluations of our business partners – whether Boliden is a buyer or a seller – including customers, suppliers, and other business partners. The purpose is to ensure that we do business with ethical and responsible counterparties who share our values. We therefore have a robust process in place to identify and manage compliance and sustainability risks such as those related to sanctions, money-laundering, bribery and corruption, as well as human rights, labor rights, occupational health and safety, and environmental risks. Over many years, we have developed our evaluation process, which includes compliance controls and thorough due diligence procedures. Evaluations are risk-based and include background and ownership controls, sanctions screenings, self-assessment questionnaires, interviews, and audits of the business partners. If necessary, audits are performed on site at the business partner facilities to monitor compliance with our Business Partner Code of Conduct. We believe in supporting our business partners to improve their corporate responsibility performance. Deviations from the Business Partner Code of Conduct are therefore primarily handled by mutually agreeing on corrective action with our business partner.

If we assess that a risk cannot be accepted, our preferred course of action is to work together with the business partner to mitigate, cease or avoid the risk. If the business partner shows acceptable progress in relation to the risk and our requirements, a business agreement may be entered into or continued. If we believe it to be very difficult or not possible for the business partner to sufficiently improve within a reasonable time frame, the business agreement may not be entered into or can be terminated.

We want to be at the forefront when it comes to mitigating ethical risks in the value chain. We therefore continuously develop our internal competence and internal procedures for business partner evaluation. At Boliden, we have designated teams that participate in the evaluations. We aim to promote best practices among business partners by seeing beyond compliance requirements and ensuring responsible business throughout the entire value chain. We encourage our business partners to set the same requirements as those set out in Boliden’s Business Partner Code of Conduct – both up and down their own value chain.

In early 2022, we updated our Business Partner Code of Conduct. The changes were based on the United Nations Guiding Principles on Business and Human Rights, the upcoming EU directive on human rights, and our internal commitments to comply with various international standards, such as the International Council on Mining and Metals (ICMM). Business partners must approve our Business Partner Code of Conduct as well as Environmental, Social, and Governance (ESG) and sanctions clauses as part of the agreement. There is also a requirement to ensure that all legally required taxes, fees and royalties related to mineral extraction, trade and export are paid to governments, and to disclose such payments in accordance with the principles of the Extractive Industry Transparency Initiative (EITI). The Business Partner Code of Conduct is available on www.boliden.com.

Boliden sources raw materials, energy, services and equipment from various external suppliers around the world. We also sell our products to an international market. Operating in a global market with varied legislation, labor and environmental standards as well as business ethics, requires a comprehensive approach to risk management, throughout the entire value chain.

Our Business Partner Code of Conduct applies to all business partners, including customers and suppliers, and reflects the minimum requirements that we place on them. The Business Partner Code of Conduct specifically addresses areas within human rights, labor rights, health and safety, environment, responsible value chain, business ethics and anti-corruption, and it prohibits the use of conflict minerals. It requires that the same principles be applied throughout the business partner’s own supply chain. We also include the option of terminating the agreement in the event of a major breach of our Business Partner Code of Conduct.

From an environmental perspective, we require all major business partners to identify and document their risks and to be aware of and comply with environmental legislation and common practices. We expect our business partners to strive to minimize their environmental impact and the Boliden Business Partner Code of Conduct addresses areas such as a precautionary approach to environmental challenges, implementing environmental management systems, and minimizing the operational impact. More specifically these are related to energy, greenhouse gas emissions, waste and water consumption.

We comply with all national legislation and international guidelines such as the OECD guidelines for the trade in materials and waste, and the UN Globally Harmonized System of Hazard Classification and Labelling. When dealing with the sale of hazardous waste, we apply a policy that involves making no payments until the material has been properly handled by the business partner.

Visits and audits are carried out to ensure that the waste is handled correctly and to ensure compliance with all relevant laws, regulations, and best practices. The process also ensures that secondary and primary raw materials do not come from conflict areas by, among other things, requiring origin documentation for all raw materials purchased by Boliden.

Our Business Partner Code of Conduct prohibits Boliden’s business partners from using conflict minerals. We adhere to the London Bullion Market Association’s (LBMA) Responsible Gold & Silver Standard, and its internal evaluation processes are in line with the OECD Due Diligence Guidance for responsible supply chains of minerals from conflict-affected and high-risk areas. For example, the processes aim to ensure that secondary and primary raw material suppliers do not source conflict minerals. We promote transparency throughout the supply chain and always ask for country-of-origin documentation when purchasing raw materials to be able to verify that a purchased raw material does not originate from restricted or conflict regions.

Boliden Commercial is also included on the LBMA list of recommended gold and silver producers – the Good Delivery List – which requires us to comply with a set of standards and to have our compliance certified by the LBMA. This guidance aims “to help companies respect human rights and the environment and avoid contributing to conflict through their mineral sourcing practices.” Companies included on the list have implemented routines to ensure that the raw material supply chain complies with the OECD due diligence guidance for responsible supply chains of minerals from conflict-affected and high-risk areas.