The Code of Conduct consists of a number of policies related to employees and workplace practices, social responsibility, and the environment.
Employees and workplace practices
- Workplace practices (including health and safety, recruitment, remuneration).
- Business ethics (including corruption and fraud, gifts, loans, related party transactions, honest and ethical conduct, conflict of interest, and compliance with laws). Read the Fraud Response Policy in PDF.
- Communication (including designated spokespersons, public reporting and communication, internal reporting of critical information). Read the Corporate Communications Policy.
Social responsibility
- Relationships with suppliers, supplier contracts, child labor and human rights, and issues specific to tobacco.
Environment
- Guidelines and policy to ensure continual environmental improvement and prevention/reduction of pollution in the Group’s activities. Read the Group Environmental Policy in PDF
Read the Swedish Match Code of Conduct in PDF. The Company policies comply with international conventions and guidelines on human rights and labor conditions. The international conventions and guidelines referred to here are the UN’s Universal Declaration of Human Rights, the UN Convention on the Rights of the Child, the central ILO conventions, and the OECD’s Guidelines for Multinational Enterprises.
Compliance with the Code of Conduct
Swedish Match is an international group of companies. As such, it must comply with the national laws and regulations of the countries in which it operates and demonstrate respect for indigenous cultures and traditions in these countries.
The Code of Conduct is applicable to all Group employees, 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. 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. Management has an additional responsibility to foster a culture of compliance with the Code. Every manager in the Group has an obligation to ensure that employees are informed about the Code of Conduct. Individual company policies in the business must always conform to the principles stated in the Code. Violations of the Code of Conduct will lead to disciplinary actions deemed appropriate.
Reviews
The Code of Conduct, approved by the Board of Directors, is reviewed annually to ensure a high level of business ethics within the Group. Various procedures are in place for monitoring and reviewing the policies 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.
The reviews are conducted by an external partner, AON, an international risk management company, and primarily comprise an examination of the Group’s own operating units. The operating units are reviewed every other year according to an established schedule. The reviews include implementation of the Code as such, social responsibility, workplace practices, business ethics, communication as well as environment. Operating units are evaluated in areas such as human rights, child labor, forced labor, supplier contracts, health and safety matters among others. Based on the results, the external partner presents recommendations if needed. Areas for improvement are re-evaluated the following year.
The conclusions of the reviews are reported to the operating unit’s management team and to the Corporate Communications and Sustainability function. Operating unit’s management has operational responsibility for ensuring compliance with the Code. The SVP Corporate Communications and Sustainability is responsible for further development and revision of the Code.
Whistleblower function
To further secure sound business ethics within the Company, consistent with the Code of Conduct, Swedish Match has established a “whistleblower” function that provides every employee in the Group with the opportunity to report any suspicion of infringement of Group policies. Such suspicions can be submitted – anonymously – to an appropriate manager, or the Chairman of the Audit Committee. The “whistleblower” function can easily be accessed through the Swedish Match Intranet site.