In our values we clearly state that we "must be honest in our business dealings, comply with applicable legislation and have zero tolerance to bribery and corruption". Corruption is a risk that could ruin our reputation and destroy our business. Corruption is a threat to democracy and stability in society. Every responsible company must shun all forms of corruption. We therefore educate our employees on how to act and demand that our business partners apply the same zero tolerance towards corruption as we do.
Corruption risks have been assessed locally. There is no aggregated data about corruption risks at Group level. NIBE has adopted a risk management tool to help its businesses manage their compliance risks. The next step is to launch systematic risk assessments to determine preventive measures in order to minimise corruption risks. That will give us access to statistics at Group level. We will also encourage improved incident reporting to further increase awareness of the risks.
By the end of 2016, 3,100 employees had completed our business and anti-corruption training. The training is now a mandatory part of the induction training for all employees exposed to corruption risks in any form.
Employees exposed to risks related to corruption or other unethical business behaviour are trained how to handle situations that might occur. They are also informed of their responsibility to seek advice and to report any situation that might occur.
The training programme is mandatory for every NIBE employee in every part of the organisation that has external contacts with suppliers, customers, authorities or other third parties. One part of the programme is an e-learning module where employees can train their behaviour in reality-based cases and get immediate feedback. One goal of the programme is to create awareness of the serious effects of unethical business behaviour - for the individual, the company and society.
No incidents related to corruption were reported during 2016.
In our values we clearly state that we "must be honest in our business dealings [and] comply with applicable legislation". If a situation of a complex nature should occur in connection with a business transaction with risks connected to anti-competitive behaviour, we seek advice from legal advisors specialised in this subject to make sure we make the correct decisions.
No legal actions for anti-competitive behaviour occurred during 2016.
There was however an investigation made by the Swedish Competition Authority in connection with the acquisition of a majority in British-owned Enertech Group. The acquisition was approved both by Swedish in February 2017 and previously by German authorities.
The agreement between NIBE Industrier AB (publ) (NIBE) and LSB Industries (LSB) on the sale and transfer of Climate Control Group (CCG) to NIBE was cleared by the U.S. Fedral Trade Commission during 2016 in accordance with the United States' Hart-Scott-Rodino Antitrust Improvements Act.
In our values we clearly state that we "must be honest in our business dealings [and] comply with applicable legislation".
There were no significant fines or non-monetary sanctions for legal non-compliance during 2016.
Our supply chain is global and consists of well over 10,000 suppliers whereof 3,500 direct material suppliers, which makes it a great challenge to be fully aware of the impact on society. We have however started to roll out new procedures and tools to the companies within the NIBE Group, to increase knowledge about our indirect impact. As the procurement organisation to a large extent is decentralised, it will take some years before this will be fully implemented. For existing suppliers we are planning assessment according to the same procedures and criteria as we use for new suppliers.
7% (percentage calculated on new suppliers of both direct and indirect material)