Ensure ethical business practices

At Swedish Match, we will take the necessary steps to ensure that ethical business practices are maintained within our own company and in our ­relationships with all outside parties.

The scope of this focus area is our own operations as well as our ­relationships with third parties; suppliers, distributors, and retail customers.

Our commitment

Swedish Match is committed to sound business ethics in all our business activities and relations with stakeholders, both within our own operations and with regard to outside parties. We build relationships through honesty and integrity and we respect the laws and regulations in the countries in which we operate. We believe that business relationships, when built on common values, mutual respect and trust, become valuable and dynamic.

Our Code of Conduct

Our Code of Conduct (the Code) represents the commitment of Swedish Match and of all employees to conduct business activities in a responsible manner, consistent with applicable laws and regulations. It applies to all employees within the Swedish Match Group, regardless of location or role. The Code is reviewed internally and approved by the Swedish Match Board of Directors annually.

Through employee opinion surveys, we keep track of our employees’ awareness of the Code and whether the employees have reviewed or been informed about the Code. Mandatory training on the Code has taken place through e-learning to supplement town hall meetings and similar events. During 2016, 60 percent of the workforce completed this e-learning. The target is 100 percent participation and we will follow up on this during 2017. Ongoing communication on matters referred to in the Code is communicated to employees primarily through the Company’s intranet and also in conjunction with performance reviews and development discussions.

Supplier Code of Conduct

Our Supplier Code of Conduct reflects Swedish Match’s Code of Conduct and specifies what we expect and require from our sup­pliers. Swedish Match strives to work with suppliers who have a healthy long term financial position and chooses suppliers who also support Swedish Match’s requirements regarding business ethics and other sustainability aspects. Our end goal is to have confirmation from all our significant suppliers that we share the same values and efforts within this field. We believe that we share the same values as the majority of our suppliers today already and we will continue our efforts to develop a more structured approach to follow up on commitment to our Supplier Code of Conduct.

Raising concerns and the whistleblower function

To further secure sound business ethics within the Company, we encourage all employees to speak up if they become aware of ­behavior that is not in line with the Code. When raising a concern, employees can always contact their managers, the heads of the operating units, the HR or legal departments. Swedish Match also has a whistleblower function that provides every employee with the opportunity to report suspicion of non-compliance with the Code to the Chairman of the Audit Committee. A concern can be raised anonymously. All raised concerns are treated seriously and investigated, taking into account the integrity of the reporting person. Suitable actions are taken in cases of misconduct. All raised concerns and actions are reported to the Audit Committee. External auditors are also present at the time of these reports. During 2016, twelve issues have been raised and evaluated. Some of these issues required actions and new routines put in place, while others were found unsubstantiated and required no further actions. None of the issues have resulted in the Company bringing criminal charges against any employees.

Corruption and bribery

At Swedish Match we have zero tolerance towards corruption and bribery. The Code states that Swedish Match shall not participate in, or through third parties, endorse any corrupt practices. The Code also provides clear guidelines on acceptable and unacceptable behavior. In addition to our current efforts with educating our personnel within this field, we will launch a tailor-made e-learning program on corruption and bribery throughout the organization, targeting all employees who operate in areas and countries where there is generally a higher risk of occurrence.

Fair competition

Swedish Match’s belief is that healthy competition contributes to increased business opportunities, improvement of economic performance and the reduction of cost for products and services. ­Competition between competitors shall be conducted in a fair ­manner and in compliance with competition laws. Our legal departments support the heads of the operating units on compliance with the relevant legislation when entering into agreements with counterparties and performing market activities. All employees within sales and marketing as well as management teams throughout the organization are continuously educated within this area through face-to-face training. E-learning programs and tailor-made com­pliance manuals are also used to educate personnel within this area and will continue to be used targeting employees within e.g. sales and marketing, procurement and research and development.