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 to manage risks.
RULES AND PROCESSES
We are guided by our fundamental values, the Code of Conduct, current laws, industry codes of conduct and clearly defined internal processes to prevent corruption risks.
In 2016, we launched an updated version of the Code of Conduct in which human rights and social media have been given a more prominent section and a responsible supply chain has been given its own section linked to the supplier code of conduct introduced in 2015. The new code contains forewords by the Chairman of the Board and the CEO. Saab's CEO presented the most important changes in a video to all employees.
Exporters are often exposed to corruption risks. Saab therefore requires a corruption risk analysis 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.
We therefore apply a strict process in which cooperations with marketing consultants and other partners in the selling process are 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.
Since 2015, Saab’s Internal Audit has reviewed a number of randomly selected contractual relationships each year to verify compliance with the process and that the partner is acting in line with our values and current contractual terms. Our long-term aim is to reduce the number of marketing consultants and other partners in the selling process and instead increase the presence of our 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 2016, around 10,000 employees had completed the training.
Employees in positions at particular risk, such as marketing and sales, industrial cooperations and project management, also receive mandatory in-depth training covering, among other things, general risk awareness, internal processes and the tools available to manage corruption risks. This training will continue in 2017. In total, over 1,000 employees have completed the in-depth training on around 90 occasions since June 2011.
In 2016, Saab’s Board of Directors received special training on business ethics. The training was provided in connection with the Board's meeting in October under the direction of the company's General Counsel and Chief Compliance Officer. It was based on case studies and was a continuation of the initial programme completed in 2013. The aim going forward is that the Board will receive training at least once every three years. Business ethics training with a focus on procurement-related issues was provided for Saab’s procurement organisation in the spring of 2016.
Employees who become aware of or suspect non-compliance with laws or Saab’s Code of Conduct are expected to report this through our whistleblowing system.
We introduced a new whistleblowing system in 2015 that complements ordinary line reporting and provides the option of reporting online or by phone. The system is managed by an independent party and guarantees the employee’s anonymity. Complaintssubmitted to the system are handled by a team of representatives from Ethics and Compliance, Human Resources, Security and Internal Audit.
We actively participate in international industry associations to develop standardised anti-corruption rules, share experiences, and evaluate and improve the work they do.
Saab was one of the companies that helped to produce a set of Common Industry Standards for the Aerospace and Defence Industries Association of Europe (ASD) in 2007. Saab is also a member of the steering committee for Global Principles, a similar agreement produced by trade organisations in Europe and North America. Companies that have signed the code of conduct pledge to comply with a number of rules on everything from entertaining potential customers to payment forms and which risk analyses should be conducted if marketing consultants or agents are brought in as intermediaries.
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