Like many other companies that do business in many parts of the world, Saab sometimes comes across attitudes that are inconsistent with its ethical values. For this reason, Saab has built up an extensive organisation, processes and tools for risk management.
RULES AND PROCESSES
Saab is guided by its fundamental values, the company’s Code of Conduct, current laws, industry-wide codes of conduct and clearly defined internal processes to prevent corruption risks. The basic rule is simple: Saab has zero tolerance for corruption.
In 2015, Saab conducted a review of its Code of Conduct and launched a separate supplier code of conduct. Saab also reviewed and updated its internal rules on gifts and entertainment as well as sponsorships.
Exporters are often exposed to corruption risks. Saab therefore requires that a corruption risk analysis is performed prior to each deal. Among the factors that affect the risk are where a deal takes place, who the customer is, how the procurement is handled, how Saab found out about it, the business model and the contract value. If the risks that are identified cannot be minimised and managed satisfactorily, Saab will withdraw from the deal.
STRICT SCRUTINY OF MARKETING CONSULTANTS
To gain entry to new markets, multinational companies often hire marketing consultants and other partners in the selling process. Saab does as well. Hiring of third parties in the sales process is sometimes important in order to understand how a market works, but can also result in increased exposure to corruption risks. Saab therefore applies a strict process whereby co-operations with marketing consultants and other partners in the selling process must be evaluated and approved by a central function that handles all such relationships. These partners also have to undergo special training and pledge to abide by Saab’s ethical values and guidelines. Contracts contain specific commitments with regard to business ethics and permit continuous monitoring of the partners through reporting requirements and audit rights. The company implemented a programme in 2015 where Internal Audit reviews a number of randomly selected contractual relationships each year to verify compliance with the process and that the patrner is operating in line with Saab’s values and current contractual terms. Saab’s long-term aim is to reduce the number of marketing consultants and other partners in the selling process and instead increase its own staff in selected markets.
In addition to training on the Code of Conduct, all employees receive separate, web-based anti-corruption training. At year-end 2015, 9,507 employees had completed the training. Employees in the marketing and sales organisation also receive mandatory in-depth training covering, among other things, general risk awareness, internal processes and the company's tools for managing corruption risks.
Starting in autumn 2013, a new inventory was performed with the aim of broadening the target group to include employees from other parts of the organisation, e.g., Project Management, Commercial and Procurement. This inventory added another 300 employees. This training will continue in 2016.In total, over 1,000 employees have completed the in-depth training on around 90 occasions since June 2011.
Business ethics and risks are a recurring theme at board and management team meetings, Group-wide management conferences and meetings at the business area level.
Employees who become aware of or suspect non-compliance with laws or Saab’s Code of Conduct are expected to report this through the whistleblowing system. In early 2015, Saab launched a new system to complement ordinary line reporting and provide the option of reporting online or by phone. The system is managed by an independent party and guarantees the employee’s anonymity. Complaints submitted to the system are handled by a team of representatives from Ethics and Compliance, Human Resources, Security and Internal Audit.
Saab actively participates in international industry associations to develop common anti-corruption
rules, share experiences, and evaluate and improve their work.
Saab’s corruption prevention efforts are constantly developing, and a number of functions are involved in the work.
Through the Audit Committee, the Board of Directors is responsible for overseeing Saab’s Code of Conduct and has ultimate responsibility for monitoring and evaluating business ethics work.
The Ethics and Compliance Board leads and draws up guidelines for the work, makes decisions on ethical issues and follows up whistleblowing cases. The board meets at least eight times a year and largely consists of members of Group Management.
The Ethics and Compliance function is responsible for monitoring, co-ordinating and developing
corruption prevention work and contributing expertise in the area. At year-end 2015, the function
consisted of two people.
Market Network Management (MNM) is a function consisting of around ten employees that
collaborates with the market and product functions to manage marketing consultants and other third parties.
This process includes corruption risk analysis, due diligence, contracting and training for business
partners. MNM also provides training and develops tools for Saab’s anti-corruption work.
Saab’s Internal Audit monitors implementation of the company’s corruption prevention processes.
Last updated: 16 February 2015 • 10:02