Ethics and compliance function
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:
- Share of employees who have access to the Ethics Line
- Share of new employees covered by the onboarding process; including signing the Code of Conduct statement and e-learning in business ethics
- Share of employees who have completed global e-learning in business ethics
SSAB has several documents that support the ethics and compliance program:
- Company-wide Code of Conduct
- Instructions regarding anti-corruption providing information on how SSAB defines bribery and improper benefits, and how employees are expected to act in relation to suppliers, customers and other business partners
- Instructions for review of business partners describing the risk assessment process for reviewing business partners within risk areas for corruption
- Instructions regarding the Ethics Line defining complaint procedures and explain how a report is investigated
Competition law program
SSAB has a web-based learning course on competition law aimed primarily at management teams, employees who attend trade association meetings, and the sales and procurement organization with the purpose of raising awareness of competition issues and explaining the basics of SSAB’s governing documents on competition rules. By year-end, 93% (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.
E-learning in business ethics
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 for all employees in order to provide training, available in six languages, in business ethics and to implement anti-corruption efforts. By the end of 2019, 91% (89%) of the employees (14,110 employees, including both office and production employees) had completed the training module. 92% of employees in Sweden, 88% in Finland and 95% in North America had completed the training. All 11 members of the Group Executive Committee had completed the training.
Tone from the top
Ethics has everything to do with management and a clear tone from the top needs to be communicated to all employees. Each member of SSAB´s top management team has an important role to promote a corporate culture where ethics are embedded in all aspects of our business. In addition to the global e-learning in business ethics, these managers were also asked to sign a Code of Conduct statement in 2019. By the end of 2019, 98% of the 80 invited managers had completed the two activities.
New SSAB employees 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, 72% (74%) of new employees in 2019 had started the process to sign the Code of Conduct statement and take the e-learning in business ethics.
Face-to-face training 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.
Review of integrity of business partners
SSAB has an instruction document for business ethics reviews that mainly covers agents and distributors in high risk areas. 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 50 raw material contracts during 2018–2019 and 37 (74%) 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).
Hardox Wearparts Network
Contracts with companies in the Hardox Wearparts Network include an anti-corruption clause and reference to SSAB´s Code of Conduct and governing documents for anti-corruption. Companies confirm that they respect and complies with the principles laid out in these documents. SSAB updated the Hardox Wearparts contract during 2017 and entered into 290 Hardox Wearparts contracts (including the anti-corruption clause) during 2017 to 2019.