We are committed to honest, respectful and ethical conduct

Compliance with laws, regulations and Alfa Laval Business Principles

It is important for Alfa Laval to conduct its business with honesty, integrity, and respect for others. This means that Alfa Laval not only follows its Business Principles and the applicable laws and regulations in the countries in which it operates, but is also determined to follow the highest ethical standards of business conduct. Alfa Laval carefully monitors the development of international legislation, social standards, and voluntary initiatives, including anti-bribery, anti-corruption, and conflict of interest.

During 2022, Alfa Laval reinforced and continued the development of a compliance and ethics programme, which includes the Alfa Laval Business Principles, governing documents, and compliance framework. The governing documents are policies, directives, and procedures. Adherence to the governing documents is mandatory for all employees in the Alfa Laval Group. The compliance framework is a set of standards that are to be implemented by local companies.

Governance

During 2022, the development of the three lines of defence concept continued. This is a model to secure compliance and a good working environment, identify gaps and secure that remedial actions are taken on discovered deficiencies. The concept is used to ensure good governance and secure compliance across the company. The first line is managers at a global level, and the second line is corporate functions, which represent oversight functions. The third line of defence are internal audits, external auditors, and external regulators.

The way the three lines of defence are set up is so that the second line creates compliance demands, checks and controls called Minimal Internal Control Requirements (MICR). These requirements are sent to the first line of defence. The first line of defence is responsible for answering the requirements by explaining how they act to comply. This information is collected by the second line of defence and analysed and used as a tool for risk assessment. Based on this risk assessment, internal audit programmes are compiled. Internal audits then challenge both the first and second line of defence by making sure that the first line of defence is compliant and that the second line of defence use controls that are effective. Securing compliance is thus made both by acting on deficiencies in the first line or by keeping ­governing documents created by the second line of defence updated.

The Risk and Compliance Board is the corporate oversight body. This board is appointed by Group Management to be responsible for reviewing the effectiveness of risk management and compliance processes within the company. The Board secures identification, assessment, mitigation, and monitoring of enterprise-wide risks. They also ensure implementation and administration of the company’s policies, directives, and ethical programmes, including the Business Principles.

All managers are responsible for ensuring compliance with Alfa Laval’s policies, including the ABAC Policy and the implementation of local guidelines. Line managers are continuously trained to keep up their awareness of the latest developments in Alfa Laval corporate policies and global compliance programmes.

Reporting breaches

Alfa Laval encourages its people to report any concern about actual or potential violation of the Business Principles or the law, and any unethical conduct. A company-wide whistleblowing system which is called Speak up!, enables both internal and external stake­holders to report suspected breaches anonymously. Alfa Laval’s whistleblowing system is a secure and efficient tool that enables employees to combat fraud and uphold the good reputation of the company. The system complies with the EU data privacy regulation (GDPR) as well as EU Whistleblower Protection Directive.

During 2022, Alfa Laval focused on further developing the work with the EU whistleblower directive. Informing people about Alfa Laval’s whistleblowing system and encouraging people to report has been an important part of the work. In some countries, Alfa Laval have established a hotline for Whistle-blower Support, along with a web-based supporting system.

Anti-bribery and anti-corruption

Alfa Laval has zero-tolerance for any form of bribery and corruption. The international scope of Alfa Laval’s sales organization means that Alfa Laval is active in several countries where there is a high risk of corruption. One of many tools used by Alfa Laval in assessing risk is Transparency International.

Corruption Perception Index. Alfa Laval’s Anti-Bribery and Anti-­Corruption (ABAC) policy outlines the expectations the company has on all employees. Alfa Laval has built its work with anti-bribery and anti-corruption based on the six steps outlined in the UK Bribery Act, and is based on the ‘prevent, detect and correct’ methodology. Risk assessments are made on a global level. No public legal cases regarding corruption have been brought against the organization or its employees during the reporting period.

Training in focus

Proportion of employees trained in anti-corruption:

The anti-corruption training is an e-learning that can be taken by all employees. In addition to this training, class-room trainings are held based on risk assessments and on demand from the organization. In these trainings the participants get the chance to get deeper knowledge and involve in discussion on the subject.

For 2022, the percentage of white collars having taken the training went down two percentage points. This is not in accordance with the target on trainings (see p. 58). The reason for this are two larger acquisitions during the year, adding to the number of white collars in the organization. Work to get these new employees trained in the subject is ongoing.

Responsible Trading

In 2022, compliance with Responsible Trading requirement of Business Principles came up as the top priority. Alfa Laval put significant effort in securing full compliance in a complex and rapidly changing environment of trade restrictions and sanctions.

Responsible sourcing

When sourcing materials and resources, Alfa Laval has a responsibility to ensure it meets the company’s ethical standards and its suppliers must be in line with Alfa Laval’s sustainability commitments.

A global supply chain with strong regional presence

Alfa Laval has more than 40 production sites and distribution centres in Europe, Asia and America. Its global sourcing organization defines the strategy for supply and supplier management, while the responsibility for the sourcing of products and services is executed locally. We are organized around eight commodities: raw ­material, casting & forging, machining & process, electric & ­components, proprietary parts, indirect production, machinery ­& equipment, and indirect & services. We define1) a supplier as any business, company, corporation, person, or other entity that sells, or seeks to sell, any kind of goods or services to Alfa Laval, including the supplier’s employees, agents, and other representatives.

Responsible sourcing

The foundation of the sourcing process is the Alfa Laval Business Principles. Implementation and follow up of Alfa Laval’s Business Principles for Suppliers Policy is carried out throughout our sourcing organization, where the Alfa Laval Supplier Risk and Compliance Council plays an integral role in following up results and enabling continuous improvements. Our current sustainable sourcing programme steering committee sets sourcing focus areas for deliveries to Alfa Laval’s sustainability agenda.

To have a responsible and sustainable value chain, collaboration with suppliers is needed. Through clear expectations, risk management and a structured way of working with mitigation and follow-up, risk exposure is reduced. Through increased knowledge about sustainability risks, it is possible to become more proactive and to work together with suppliers towards sustainable business growth and innovation.

Expectations

The Alfa Laval Business Principles for Suppliers Policy together with our supplier agreements, form the basis of our sustainability expectations on our supplier base. Suppliers are expected to acknowledge the policy and they are accountable for following and fully incorporating the Business Principles into their supply chain.

Sustainability is an objective for our strategic supplier programmes and in all our commodity strategies. During 2022, climate action was a sustainability focus area for the sourcing organization. Alfa Laval has a responsibility to not only help our customers reduce emissions, but also make the same effort ourselves and achieve the same targets we expect of our suppliers.​

Evaluation

Alfa Laval’s sourcing process outlines how we select and evaluate potential suppliers across our organization. It is important for Alfa Laval to not only onboard suppliers that can deliver to our expectations but also share our sustainability ambitions. In order to evaluate new suppliers and to ensure we know who we do business with, we use evaluation tools such as questionnaires, evaluations of sustainability programmes and if required, audits.

Risk analysis and mitigation

For us, risk management means understanding and mitigating supply chain risks. To identify risk focus areas, the sourcing organization uses macro risk trend reports, external insights for critical risk indicators, for example anti-corruption, environmental and working conditions indexes, and internal data and insights. Performed audits and supplier dialogues will give valuable input into the improvement of the risk screening process.

A supplier risk assessment includes an initial screening to ensure prioritization of the suppliers with the highest risk of breaches of the Business Principles.

Depending on the characteristics of an identified risk, the sourcing team will mitigate the risk in different ways. Mitigation activities are individually developed with a case-by-case approach supported by Alfa Laval Supplier Risk and Compliance Council and an action plan including a close follow-up programme.

Follow-up

Alfa Laval has a robust follow-up programme including business reviews of sub-commodity strategies, workshops for suppliers, a supplier award for best sustainability practices, to mention a few. We also have an audit programme where Alfa Laval’s internally certified auditor performs different audits with our suppliers. Suppliers’ overall capabilities to deliver products and material according to Alfa Laval requirements are assessed, specific manufacturing processes are audited and there are Business Principles audits for suppliers. The Business Principles audits are sustainability audits including areas like environment, health and safety, human and labour rights, and social practices at the supplier.

Alfa Laval’s sourcing organization has two sustainability KPIs, Business Principles audits and climate projects. After two years of travel restrictions due to Covid, the number of on-site audits increased again in 2022 and our auditors conducted a total of 74 Business Principles audits to assess suppliers’ social and environmental performance and compliance with our Business Principles, mainly in China, India and Mexico.

Corrective action

If non-compliance is found through a supplier evaluation activity, a reported incident, a risk analysis or a follow-up activity such as an audit, the agreed improvement action plan is handled by the supplier responsible. Suppliers with serious breaches get a limited time to implement the necessary improvements with the support of an effective supplier development programme, while the case is escalated and monitored. If an approved supplier does not fulfill Alfa Laval´s expectations on performance or compliance after assistance from Alfa Laval, an escalation to the Supplier Risk Council is done. An escalation will, if not solved, lead to a decision to put business on hold or even phase out and terminate the agreement between Alfa Laval and the supplier.

Alfa Laval follows up all Business Principles audit cases of identified potential or actual negative impacts with an improvement action plan. The Business Principles audits highlight six critical areas: child labour, young labour, forced labour, freedom of association, health and safety, fire protection and environment. Deviations in any of these areas require immediate correction, both from new and established suppliers.

The most common deviations in recent years have been in the areas of health and safety, overtime/low payment, emergency preparedness and environmental protection.

Continuous improvement

Alfa Laval’s work with its supply chain is continuously improved to ensure alignment with new sustainability requirements and legislation as well as developing good practices, and we recognize the need to work with our development areas. Several responsible sourcing development projects are ongoing and related to process and system development, data collection, report development, communication and more. For latest updates, please refer to AlfaLaval.com.

US Dodd-Frank Act

The US Dodd-Frank Act requires US companies to conduct due diligence to ensure that the minerals used in their products are not sourced from mines that finance armed groups guilty of human rights violations. Since 2013, Alfa Laval has been following the company-wide policy on conflict minerals available on www.alfalaval.com. A supplier assessment platform is used to increase transparency and visibility in order to identify suppliers that require an assessment. In 2022, Alfa Laval assessed and initiated dialogue with 432 suppliers to ensure compliance.

Modern Slavery Act

Forced labour and human trafficking are severe global issues. Alfa Laval has zero tolerance of these violations within its organization and supply chain. Modern slavery is included in learning programmes for employees and suppliers, as well as in the monitoring, auditing, and follow-up activities with suppliers. Read more in Alfa Laval’s Modern Slavery Act Statement, available on our website.