Business ethics and anti-corruption
By providing a framework for business ethics and compliance, SSAB continues to focus on creating a mature organizational culture that encourages ethical conduct.
SSAB has an Ethics and Compliance function, which includes strategic responsibility for business ethics, anti-corruption and human rights, as well as for implementing new legislation and international guidelines in this area. Essential components of the ethics and compliance program are risk assessments and employee training to prevent and detect corruption and mitigate legal and ethical risks. How we measure progress:
SSAB has several documents that support the ethics and compliance program:
During 2018, SSAB launched a web-based course on competition law aimed primarily at the sales and procurement organization with the purpose of raising awareness of competition issues and to explaining the basics of SSAB’s governing documents on competition rules. By year-end, 82% of targeted employees had completed the training.
SSAB works actively to prevent corruption in our business. SSAB’s governing document for anti-corruption defines SSAB’s zero tolerance approach to bribery and corruption, and sets out guidance for our daily operations.
All employees are expected to comply with SSAB’s Code of Conduct, the governing document for anti-corruption, and to have knowledge of how to report non-compliances through the Ethics Line. Communication and training are organized through a global e-learning module reaching out to all employees in order to provide training, available in six languages, in business ethics and to implement anti-corruption efforts. By the end of 2018, 89% (91%) of the employees (14,313 employees, including both white and blue collar employees) had completed the training module. 90% of employees in Sweden, 88% in Finland and 87% in North America had completed the training. All 11 members of the Group Executive Committee had completed the training.
Employee engagement starts on day one. SSAB has an onboarding program for new employees who are expected to complete the e-learning in business ethics and sign a Code of Conduct statement within the first few weeks of employment. This provides new employees with an understanding of our governing documents and expectations of our employees. By the end of the year, 74% (61%) of 2018 new employees had started the process to sign the Code of Conduct statement and to take the e-learning in business ethics.
Internal training in business ethics is ongoing and is mainly provided to employees in management, sales and procurement, those who are most at risk of being exposed to corruption and bribery risks. Training is based on SSAB’s values and governing documents and teaches participants what is meant by corruption and bribery, and how SSAB’s ethics and compliance program is structured. This is followed by a discussion focused on practical, real-life examples and dilemma discussions. Training requirements are continuously monitored and evaluated based on business needs and the legal and ethical risk context.
In some situations, SSAB reviews the integrity of our business partners more closely. SSAB has an instruction for business ethics reviews that mainly covers agents and distributors in high risk areas. The instruction means that SSAB may not enter into or renew agreements with business partners that are within the typical risk areas for corruption, before an initial assessment showing that such partners respect our fundamental rules of business ethics.
Contracts with suppliers refer to the Supplier Sustainability Policy, which states that all forms of corruption and bribery are unacceptable and that suppliers should work against all forms of corruption and bribery. SSAB entered into or renewed 40 raw material contracts during 2017–2018 and 31 (78%) of these contracts refer to the Supplier Sustainability Policy and the other contracts contain similar wording (data refers to the Nordic part of the procurement organization).