NF5 Compliance
In 2024, the focus was on a review of the compliance program and identification of improvement areas. Risk-based efforts to counteract Russian entities from accessing Sandvik products through third parties outside of Russia also remained high on the agenda.
In addition to the external risk assessment referred to above, the Compliance House serves as a tool allowing, among other things, each Sandvik entity to understand and address its compliance risks to increase transparency in control implementation. At year-end 2024, the Compliance House included all business entities, except for a few recently acquired entities that underwent compliance-risk assessment during the due diligence process. Additionally, certain entities, primarily engaged in administrative tasks and internal services, deemed low risk, were excluded. 81 percent of the operational units in the tool conducted a self-assessment review during the year.
The Compliance House requires that each entity communicates annually with its employees in four compliance areas. As of December 31, 2024, 69 percent of the entities had reported during 2024 that they had communicated about anti-corruption compliance in the last 12 months. The corresponding figures for competition law, trade compliance and data privacy communication were 65 percent, 54 percent and 64 percent, respectively.
Compliance training was provided to employees through various formats, including e-learning, webinars, and classroom sessions. Over 20,603 training records were generated, with 6,296 focusing on anti-corruption, 5,825 on competition law, 6,708 on data privacy and 1,774 on trade compliance. The Group Executive Management team participated in a workshop on compliance risks, which has been substantially replicated in the business areas.
Sandvik has zero tolerance for bribery and corruption. The Anti-bribery and corruption policy mandates all employees, managers and directors to identify and disclose any conflicts of interest. No members of the Board of Directors have declared any conflict of interest with respect to cross-shareholding with suppliers and other stakeholders. The risk assessment conducted through the Compliance House, including action plans and existing controls, did not reveal any significant residual corruption risks. Sandvik requires its business partners to adhere to its supplier/business partner Code of Conduct. It requires suppliers/business partners to comply with relevant rules and principles concerning anti-corruption, competition law, data privacy, and international sanctions.
Sandvik also requires that relevant commercial intermediaries sign an anti-corruption and export control/trade clause in the contract. The use of the anti-corruption clause and the Business Partner Code of Conduct is followed up through Compliance House. Out of the entities during 2024 who responded that they were using commercial intermediaries, 82 percent responded that all their commercial intermediaries had signed the Sandvik Business Partner Code of Conduct and 67 percent that all commercial intermediaries had signed a contract including an anti-corruption clause. The entities’ responses are audited and confirmed by the internal and external Audit functions as part of the regular audit programs.
In 2024, there were no major public legal cases regarding potential non-compliance with laws and regulations brought against Sandvik and neither did Sandvik receive any significant fines or non-monetary sanctions for non-compliance with laws or regulations.