Note 40. Compliance

Sandvik manages risks in four compliance areas: anti-bribery and corruption, competition law, trade compliance and data privacy. During 2019, the strategic work mainly focused on developing a new compliance tool, the Compliance House. The Compliance House is a tool which the business can use to get an overview of the requirements in the four compliance programs that are relevant to them, the respective risk levels and the current status of their compliance activities. The purpose of the Compliance House is to further embed compliance into the business and allow entity level monitoring of risks and compliance status. Our 2020 target is to implement the Compliance House at 25-50 percent of Sandvik entities.

Compliance training was offered to employees in different formats, including e-learning, webinars and classroom training. A total of 3,800 participants received training.

There were extensive activities in the trade compliance program area in 2019 due to Brexit preparations, as well as a number of changes in customs tariffs and international sanctions imposed by the US government and other countries. For data privacy, implementation of the GDPR requirements continued during 2019. Specific focus is now on building a sustainable and effective governance structure.

Sandvik has zero tolerance for bribery and corruption. In 2019, the implementation of anti-bribery and anti-corruption internal controls was in focus, as well as the adjustment of our processes and systems to handle risks related to administrative intermediaries, such as customs agents.

We have a competition law compliance program in place to mitigate risks associated with competition or antitrust laws in all countries where Sandvik operates. The program relies on frequent e-learning and in-person training for employees who may be exposed to competition law risks in their work. In 2019, about 1,500 employees received training in competition law. Training in this area is repeated and updated every second year. Comprehensive competition law guidelines are available for all employees who are also encouraged to seek advice from Sandvik Legal Support teams in case of doubts about the legality of a business activity.

Sandvik received no (no) significant fines or non-monetary sanctions for non-compliance with laws or regulations related to our four areas.