Elkem does not permit or tolerate any form of corruption. Elkem’s policy on anti-corruption applies group-wide and worldwide. Along with our EHS focus, anti-corruption is a top priority. The policy explains and elaborates on the content and implications of the anti-corruption policy for Elkem’s employees, representatives and partners. All Elkem personnel exposed to corruption risks must sign the anti-corruption policy and manual.
Elkem is present in several countries with high corruption-risk. Elkem also sells products to companies located in countries ranked in the bottom tier (i.e. very high levels of corruption) of the Transparency International’s Corruption Perception Index. Elkem conducts risk assessments on all operations group-wide and globally while the aforementioned high-risk countries receive particular scrutiny. All new suppliers of raw materials, goods and services are subject to pre-qualification based on corporate requirements within environment, health and safety, social responsibility, anti-corruption and compliance with laws and regulations. Examples of corruption risk includes the use of consultants regarding receiving public approvals, use of agents and joint ventures including local partners.
Risk assessments are typically conducted when entering into business arrangements in a new country where corruption is viewed as a major concern. Elkem will perform an integrity due diligence to assess the different risks related to corporate social responsibility, including corruption. The assessments may be done by relying on external specialists and will be regularly revisited. Elkem did not enter any new countries in 2018.
Elkem also undertakes a group-wide mapping of sales to companies located in countries with high corruption risk. The mapping ensures that the marketing departments have high-awareness to potential risks of unethical behaviour in these countries. This includes questions relate specifically to customer evaluation, CSR policy communication, documentation of sales, transaction transparency, and the application of Elkem’s standards when using agents and distributors.
All Elkem personnel exposed to corruption risks must sign the anti-corruption policy and document e-learning. This relates to the following personnel:
- Corporate management
- Division management teams
- Divisional finance managers
- Plant finance managers & controllers
- Treasury and credit management personnel
- Corporate business support personnel
- Technology management team / department leaders
- All project managers
- All managers in research and product development
- All sales and marketing personnel
- All procurement personnel
- Production managers
- General managers of subsidiaries
- Key managers in logistics/supply chain/raw materials
Each Elkem business unit is responsible for understanding the specific challenges regarding anti-corruption, the anti-corruption regulations applicable to its operations and for adopting adequate anti-corruption guidance and measures.
The target is that 100% of personnel in the target group should be trained within the first year of employment. For 2018 the target was met except for a few individuals that recently joined Elkem and have since been trained.
Elkem’s anti-corruption policy, as part of our CSR principles, is communicated and to a large extent forms part of the contracts with agents, distributors, partners, vendors and customers. They are also available on our website. All new suppliers must sign that they have understood and accept Elkem’s CSR principles.
Incidents in 2019:
There were no identified incidents of corruption in 2019.