Conducting responsible business
Acting in accordance with the law, following our Code of Business Conduct and any applicable policies forms the basis of the way we do business. We work with you through our compliance program, and we expect everyone affiliated with us to do the same. We recognise that working in the cement and mining industries implies operating in countries with compliance-related risks, which is why we constantly monitor our business and implement mitigating actions to reduce those risks.
We stress the importance of our Code of Business Conduct across the organisation, and each employee receives a guidebook along with training that explains how anti-corruption legislation applies in our business conduct and in our day-to-day operations.
For FLSmidth, compliance means focusing on four core areas of operation:
- Export control
- Human rights
- Competition law
Our activities involving compliance include the six elements of the UK Bribery Act’s guidance document: Risk assessment; policies and organisation; top-level commitment; due diligence; communication; and training, monitoring and review.
FLSmidth believes that broader coalitions can make the greatest impact in avoiding corruption. We are a founding member of Compliance in Mining Network (CiMN), which is a collaboration between companies in the mining industry. CiMN aims at improving compliance standards within the industry. In addition, FLSmidth is a member of the Fight Against Facilitation Payments Initiative (FAFPI), which is a collaboration between Danish companies aiming at fighting the use of facilitation payments.
FLSmidth maintains a global whistleblower hotline which allows employees, business partners and other relevant stakeholders to anonymously report potentially serious allegations concerning financial crimes, such as bribery or fraud, environmental violations, breaches of competition law and human rights violations. The whistleblower hotline is hosted by a third party and allows for fully anonymous and encrypted reporting in several languages.
- Risk assessment
- In our approach to compliance, we take risks to our business very seriously. This means that we regularly conduct assessments of the compliance-related risks, including human rights related ones, that we face, and adjust the focus and resources accordingly. We use an inclusive approach that engages our employees, focusing on data and adjusting our program as needed.
- Policies and organisation
- As an organisation, we must ensure that a clear direction is set and that our business is equipped with appropriate compliance tools. Our team of 13 regional compliance representatives are all company lawyers trained in key compliance skills, and they are responsible for the implementation of compliance skills in their respective regions. Further, a group of key finance and HR managers were identified and trained to be responsible for investigating relevant whistle-blower cases in their fields of work in certain regions of the world.
- Top-level commitment
- Our Board of Directors and Executive Management are highly engaged in the compliance programme. Their direct involvement has been expanded as has the level of reporting. Group Compliance reports on a regular basis to the Audit Committee, the Board of Directors and the Group CEO.
- Due diligence
- Due diligence is one of our major focus areas. For many years, we have had a policy of screening all business partners, and our due diligence programme provides a framework for doing so. All sales agents as well as many customers and contractors go through a rigorous due diligence screening and approval procedure. The screening covers trade sanctions, corruption, human rights violations, environmental issues, litigation cases, adverse media, basic company registration documentation, and much more. Due diligence is an integrated part of the sales process in FLSmidth. All projects over a certain threshold undergo a due diligence screening, with a strong focus on human rights violations. The process involves a presentation of the findings and reaching an agreement with the relevant business colleagues in FLSmidth on mitigating or remedial actions.
- Good communication is key to the successful implementation of compliance initiatives and to ensuring that the whole company understands the need for them. Further, communication can also help employees maintain a positive work environment. Our whistle-blower hotline is a tool for employees to report concerns in a confidential manner. It strengthens our ability to conduct internal investigations. More people feel comfortable using the formal hotline rather than email or similar channels, and the whistle-blower policy protects reporters against retaliation. It is a priority to us that our employees feel comfortable at work, and that includes feeling comfortable speaking up about any concerns they may have.
- Training, monitoring and review
- Training continues to be one of the top priorities for us. Approximately 95% of all white-collar employees have been trained in the Code of Business Conduct in-person, and key employees train in export control procedures on a continuous basis. When training new employees, we are able to maintain awareness about compliance.