Zero tolerance for bribery and corruption

By providing a framework for business ethics and compliance, SSAB continues to focus on creating a mature organizational culture that encourages ethical conduct. This framework provides the required support and tools to meet SSAB’s expectation that each and every employee acts with honesty, integrity and responsibility in their job. The framework also ensures that we collaborate with business partners who share our ethical values.

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.

Zero tolerance for bribery and corruption

Sustainability strategy

SSAB has zero tolerance for bribery and corruption and this is clearly communicated from top management. One top priority is to ensure ethical conduct in line with SSAB`s corporate culture and increase knowledge about the Code of Conduct and the Ethics Line.

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

Governing documents

SSAB has several governing 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 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 regarding the Ethics Line defining complaint procedures and explaining how a report is investigated

Code of Conduct

The Code of Conduct is part of ”the SSAB Way” (see page 15), which is our way of describing the culture that has made and continues to make us successful. The Code of Conduct is described as the way we act. The Code of Conduct is SSAB’s ethical compass and outlines guidelines for SSAB’s behavior with stakeholders and in the market. It helps us translate our values into action and forms the basis for our ethical, environmental and social responsibility commitments. The Code of Conduct covers areas such as health and safety, environment, employee relations, human rights and business practices.

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, 95% (93%) of targeted employees had completed the training.

Anti-corruption

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.

During 2020 SSAB became a member of Transparency International´s Corporate Supporters Forum. This membership demonstrates SSAB´s top level commitment to anti-corruption and business integrity and gives an opportunity to collaborate with other members and share knowledge and expertise.

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 2020, 91% (91%) of the employees (13,226 employees, including both office and production employees) had completed the training module. 91% of employees in Sweden, 86% in Finland and 98% in North-America had completed the training. All 11 members of the Group Executive Committee 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 and 2020. By the end of 2020, 100% of the 62 invited managers had completed the two activities.

Onboarding process

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 75% (72 %) of new employees in 2020 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 on business ethics is ongoing and mainly is 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. During 2020 several training sessions were held for Ruukki Construction´s management and sales teams.

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.

Suppliers

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 70 raw material contracts during 2018-2020 and 55 (79%) 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 310 Hardox Wearparts contracts (including the anti-corruption clause) during 2017 to 2020.

Ethics Line

SSAB’s global reporting tool, Ethics Line, provides employees with an avenue to raise their concerns. All employees are urged to report suspected breaches of the Code of Conduct. Employees can file a report anonymously online or by calling a global hotline 24 hours a day, seven days a week. The Ethics Line has been implemented in 14 countries. Awareness of the Ethics Line has been promoted through employee communications and web-based training. By the end of 2020, 95% (95%) of our employees had access to the Ethics Line. In 2020, 9 (14) incidents where reported through the Ethics Line. The reports related to concerns including corruption, discrimination and harassment. Following investigation, actions were taken in 3 cases.