The Code of Conduct is applicable to all employees in the organization, regardless of position. All Swedish Match companies and employees shall comply with the Code of Conduct even if it stipulates a higher standard than required by national laws or regulations.
Swedish Match has an internal process where the Code of Conduct, along with all other Group policies, is distributed to managers in the countries where we operate. Every manager has an obligation to ensure that employees are informed about the Code of Conduct as well as a responsibility to foster a culture of compliance with the Code. Also, every employee has a personal responsibility to make sure that actions taken comply with both the words and the spirit of the Code of Conduct.
To ensure an ongoing high level of business ethics within the Group, the Code of Conduct is reviewed and approved annually by the Board of Directors. Various procedures are in place for monitoring and reviewing the policies stated in the Code of Conduct. The reviews are intended to ensure that employees and other stakeholders affected by the Code of Conduct are aware of, understand, and comply with its content.
Reviews, which are conducted by the external partner AON (an international risk management company), primarily comprise an examination of the Group’s operating units. Facilities are reviewed at least once every second year according to an established schedule. The reviews include implementation of the Code of Conduct as such, with evaluations in the areas of social responsibility, workplace practices, business ethics, communication, and the environment. Topic areas include human rights, child labor, forced labor, supplier contracts, as well as health and safety matters. Based on the results, the external partner presents recommendations if needed. Possible identified areas for improvement are re-evaluated the following year.
The conclusions of the reviews are reported to the operating units’ management teams and to the Corporate Communications and Sustainability function. The operating units’ management teams have operational responsibility for ensuring compliance with the Code of Conduct. The SVP Corporate Communications and Sustainability is responsible for further development and revision of the Code of Conduct.