Committed
Committed to ethical business conduct
Alfa Laval is committed to doing business in an ethical and transparent way and also expects this of business partners. The Alfa Laval Business Principles set out fundamental rules of behaviour that all employees should adhere to when conducting business. By aspiring to our Business Principles, we can also find many opportunities to contribute to a more sustainable future and accelerate success for our customers, people and planet.
The Business Principles apply to all companies in the Alfa Laval Group and apply to all employees, including temporary employees and consultants. They also guide the relationships with business partners, such as suppliers and customers.
There are internal guidelines available to help employees interpret the Business Principles, with concrete examples for how they should be implemented in everyday work life for everyone at Alfa Laval.
In 2023, a new Business Principles training was rolled out to improve employee awareness and increase knowledge on the Business Principles.
Alfa Laval’s Business Principles incorporate the ‘Protect, Respect and Remedy’ concept of the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for multi-national enterprises and the concepts in the UK Modern Slavery Act. The Business Principles are approved by the Alfa Laval Board.
Alfa Laval Business Principles
There are four fundamental Business Principles – Caring, Committed, Transparency, Planet – that cover a number of topics that are essential to responsible and sustainable business conduct.
Caring
We care about every individual’s rights and opportunities including their safety and well-being. We are a global company, and we firmly believe that diversity maximizes
the potential of every employee and we care about every individual’s rights and opportunities.
The Business Principle covers:
- Human rights
- Inclusion and diversity
- Health and safety
- Freedom of association
- Child and forced labour
- Working conditions
Committed
We are committed to ethical conduct within our organization and in all external business relationships. High ethical standards guide our behaviour, and honesty, integrity and respect for others are values that we live and work by.
The Business Principle covers:
- Anti-bribery and anti-corruption
- Non-complicity
- Conflict of interest
- Fair competition
- Export control and trade sanctions
- Political contributions
Transparency
We engage in open dialogue with all our stakeholders to develop business relationships built on trust. Trust also requires that we are careful not to reveal or communicate confidential information.
The Business Principle covers:
- Protection of personal data
- Confidential information
- Accounting and verification
- Company assets
Planet
We are in a unique position because our products make a significant contribution to reducing the environmental impact of industrial processes. We also have a responsibility to continuously reduce our environmental impact in all areas of our value chain.
The Business Principle covers:
- Environmental impact
- Continuous improvement
- Precautionary principle
Ensuring compliance with laws, regulations and Alfa Laval Business Principles
Conducting business with honesty, integrity, and respect for others is fundamental for Alfa Laval. This means that we not only follow the applicable laws and regulations in the countries in which we operate, but we are 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 those concerning anti-bribery, anti-corruption, and conflicts of interest.
The compliance and ethics program has been furthered developed in 2023, and a Three Lines of Defence model has been implemented to clarify roles and responsibilities in applying the Alfa Laval Business Principles and underlying governing documents. The governing documents are policies, directives, and procedures. Adherence to the governing documents is mandatory for all employees in the Alfa Laval Group.
Governance
The Three Lines of Defence concept is the cornerstone of good governance. 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 first line of defence includes managers at a global level and the second line is corporate functions with an oversight role. The third line of defence involves internal audits, external auditors, and external regulators.
At Alfa Laval, the three lines of defence are set up 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, who shall explain how they intend to act to comply. This information is collected by the second line of defence and used as a tool for risk assessment. Based on this risk assessment, internal audit programmes are compiled. Internal audits 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 Anti-Bribery and Anti-Corruption (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. Reporting concerns to your manager is always the first step. If this is not an option, Alfa Laval has a company-wide whistleblowing system, which 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) and EU Whistleblower Protection Directive.
Informing people about Alfa Laval’s whistleblowing system and encouraging people to report is an ongoing process . In some countries, Alfa Laval has established a hotline for whistleblower 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 the Transparency International Corruption Perception Index.
In 2023, Alfa Laval launched an updated ABAC policy which outlines the expectations the company has on all employees. The new policy is aligned with the ISO 37001 on Anti-bribery management systems to prepare for possible future certification of Alfa Laval’s anti-bribery and anti-corruption program. The launch of the updated policy was accompanied by several ABAC webinars attended by more than 2,000 people. A new ABAC e-learning course was also launched during the year – it is available to all employees and the expectation is that every employee takes this training at least every second year to maintain awareness.
Training in focus
Proportion of employees trained in anti-corruption (as of July 2023) presented below. New courses were introduced during the year and will be reported in 2024.
80% Group Management
77% White collars
48% Blue collars
Besides the ABAC e-learning, there are also class-room trainings held for certain groups of employees 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 discussions on the subject.
Anti-bribery and anti-corruption process
Top level commitment
- Group ABAC Policy
- Risk Compliance Board
- Corporate self-assessment
Risk assessment
- Enterprise Risk Management
- Risk assessment in supply chain
Proportionate procedures
- Risk management actions
- Supplier contracts include ABAC clause
Communication & training
- ABAC information available on the intranet
- ABAC training for employees
- ABAC training for suppliers
Due diligence
- Third parties screening, compliance screening
- Due diligence on mergers and acquisitions
Monitoring & review
- Internal audit
- Whistleblowing function
- Annual Sustainability Reporting
Responsible sourcing
Alfa Laval has the responsibility to ensure that sourced materials and resources meet the company’s ethical standards. Alfa Laval’s sustainability commitments also apply to our suppliers.
Global sourcing with a local presence
Alfa Laval has more than 40 production sites and distribution centres in Europe, Asia, and Americas. Each of these is supplied with raw materials, components, services and other inputs from global and local suppliers.
The central sourcing organization defines the strategy for supply and supplier management, while the responsibility for the sourcing of products and services is executed locally. Sustainability is an integral part of the commodity strategies and strategic supplier programmes.
Responsible sourcing
The sustainability expectations on our suppliers are based on the Alfa Laval Business Principles for Suppliers and clearly stated in our supplier agreements. Suppliers are expected to acknowledge the Business Principles and are accountable for following and fully incorporating the Business Principles into their own supply chain.
The Responsible Sourcing Programme steering committee sets the focus areas for delivering on Alfa Laval’s overall sustainability agenda in respect to activities that require collaboration with suppliers.
Climate action was a sustainability focus area for the sourcing organization in 2023. Alfa Laval has a responsibility to help our customers reduce emissions, we make the same effort ourselves and expect climate actions to be taken also by our suppliers.
The Supplier Risk and Compliance Council sets the direction for targeted initiatives to secure governance. They also play an integral role in following up results to enable continuous improvements.
Risk analysis and mitigation
Responsible sourcing includes identifying, assessing, and managing supply chain risks. Risk exposure is reduced through clear expectations, risk management and a structured way of working with mitigation and follow-up.
To identify risk 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. Risks can also be identified continuously through supplier evaluation activities, reported incidents, risk analysis, the whistleblower mechanism or follow-up activities such as audits.
Supplier risk assessment includes an initial screening of new suppliers and annual screening of existing suppliers to identify suppliers with the highest risk of breaches of the Business Principles for targeted actions.
Risks are managed depending on the characteristics of the identified risk. A corrective action plan is created, and preventive actions include targeted activities and a follow-up programme. Mitigation activities are developed with a case-by-case approach supported by the Supplier Risk and Compliance Council.
Risk analysis is not only about mitigating risks for the company. Through increased knowledge about sustainability risks, it is possible to become more proactive and work together with suppliers towards innovation and sustainable business growth that can create benefits in the entire value chain.
Supplier evaluation and engagement
Alfa Laval’s sourcing process outlines how we develop our existing supplier base and evaluate potential suppliers across our organization. It is important for Alfa Laval to onboard suppliers that can deliver to our expectations and share our sustainability ambitions.
Evaluation tools such as questionnaires, sustainability programme evaluation and audits are used to assess new and existing suppliers. Supplier engagement to promote sustainable sourcing also includes activities such as workshops for suppliers, and a supplier award recognizing outstanding sustainability practices.
Supplier audits
Alfa Laval has clear sourcing KPIs and a robust follow-up programme including three types of audits for the supply chain, Business Principles and special processes.
In a supply chain audit, Alfa Laval’s internally certified auditor verifies supplier capabilities to deliver products and material according to Alfa Laval’s requirements. Special process audits typically target the suppliers’ manufacturing methods.
Business Principles audits are an important part of the Responsible Sourcing Programme and include areas such as environment, health and safety, human and labour rights, and anti-corruption efforts.
In particular, 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.
Suppliers with serious breaches have a limited time to implement the necessary improvements, supported by an effective supplier development programme, while the case is escalated and monitored. Non-compliance without corrective action can lead to phase-out or termination of the supplier agreement with Alfa Laval.
A total of 73 Business Principles audits were performed in 2023, mainly in China, India and Mexico, countries with a large supplier base and many manufacturing units. Suppliers targeted for Business Principles audits are selected based on the risk assessment process.
The most common deviations discovered in the Business Principles audits in recent years have been in the areas of health and safety, overtime/low payment, emergency preparedness and environmental protection.
Continuous improvement
Alfa Laval believes in continuous improvement as a dynamic rather than a static process. We recognize the need to work with our development areas and stay informed about coming sustainability directives and legislation.
In 2023, some 60 sourcing employees participated in the supplier auditor courses in Lund, Richmond, Jiangyin, and Kunshan, to take the first steps toward becoming internally certified auditors and secure the audit process regionally. An audit app was also released to support the audit process.
The Alfa Laval Business Principles for Suppliers is continuously reviewed to secure alignment with legislation and other directives. In 2023, a review of the documentation was initiated to align with the updated OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. We expect our suppliers to show the same dedication to continuous improvements and to show progress in all areas covered by our Business Principles for Suppliers.
Conflict minerals
Alfa Laval has a policy specifically targeting conflict minerals to secure that the minerals used are not sourced from mines that finance armed groups guilty of human rights violations. A supplier assessment platform is used to increase transparency.
Climate action in focus
In 2023, several sourcing activities were initiated to contribute to the Alfa Laval scope 3 climate target to reduce greenhouse gas emissions by 50 percent by 2030 (with a 2020 baseline).
As an example, an impact-based project was initiated with suppliers specifically targeting greenhouse gas reductions. A questionnaire was sent out to 50 focus suppliers representing about 70 percent of the emissions from purchased goods and services. The intention was to collect supplier-specific data on emissions and enquire about any activities to reduce emissions, emphasizing that this would be an important contribution to reducing Alfa Laval’s carbon footprint.
Another example of climate action during 2023 is our sourcing managers in the distribution centres working with customers and suppliers to change air freight orders to sea or rail transport with the aim of reducing greenhouse gas emissions. Short-term initiatives target close collaboration with customers and suppliers to change existing air freight orders to sea or rail, if possible. The long-term goal is to reach more sustainable solutions for freight already when placing the order and avoid transport modes with a high climate impact.
Assessing supplier risk
The following three areas guide our risk assessment of suppliers
Country risk
Risk related to human rights breaches or bribery/corruption in the country where the supplier is based.
Product & production process risk
Risk related to occupational health and safety or environmental impacts associated with supplier production processes.
Governance & policies
Risk based on analyses and screenings of the supplier’s available documentation of policies and governance.
Biodiversity impacts and dependencies
Taking account of the recently released recommendations from the Taskforce on Nature-related Financial Disclosures (TNFD). Alfa Laval is taking steps to better understand our biodiversity impacts and dependencies on natural capital assets.
An initial evaluation using the publicly available ENCORE database shows that while Alfa Laval’s direct dependencies on ecosystem services are limited, our operations may have material impacts on biodiversity loss, for instance through water use, greenhouse gas emissions and waste from production. Impacts in the supply chain are even more significant, particularly beyond tier 1, for instance in mining operations.
Based on the initial analysis, Alfa Laval has developed a roadmap for addressing biodiversity impacts in the coming years. Starting with the direct impacts from operations, most of these are already addressed in our sustainability strategy with reduction targets to 2023 and beyond in place. We will continue to take action to reduce water use, increase recycling of waste, and limit greenhouse gas emissions.
In the value chain, many Alfa Laval products have a potential positive biodiversity impact downstream by helping customers improve energy and resource efficiency. In the upstream value chain, we are working closely with suppliers to source materials with lower environmental and biodiversity impacts, and in the longer term will consider more explicit supplier requirements for example on water use and waste management.