OECD Guidance as it relates to “downstream” purchasers of products and components. The due diligence processes have been described below under sub-headings corresponding to the five-step framework of the OECD Guidance. Ericsson’s Conflict Minerals Program focuses on identifying the origin of 3TG and cobalt; however, Ericsson acknowledges that other human rights and environmental risks, such as forced labor and child labor, health and safety, land-related rights and community rights are also salient relating to sourcing of 3TG and cobalt. Ericsson is currently engaged in industry dialogues relating to these issues.
3.1 | Maintain strong management systems |
The first step of the OECD Guidance relates to strong management systems. As mentioned above, Ericsson has established a Conflict Minerals Program for reporting on 3TG and cobalt and compliance with the Rule. Controls include, but are not limited to, our Code of Business Ethics and Code of Conduct for Business Partners, which outline required behaviors for all Ericsson’s employees and suppliers (https://www.ericsson.com/en/about
-us/sustainability-and-corporate-responsibility/responsible-business/responsible-sourcing/supplier-requirements-related-to-responsible-sourcing ), and the Ericsson Lists of Banned and Restricted Substances, which include supplier requirements to have diligence processes in place to identify the source and chain of custody of 3TG and are integrated in our template supplier agreements.
With respect to 2021, identification of smelters and refiners in our supply chain was made via the use of due diligence tools created by the RMI, including the Conflict Minerals Reporting Template 6.1 and the Cobalt Reporting Template (the “Templates”). The Templates are standardized supply chain surveys designed to gather information regarding the smelters and refiners that process 3TG and cobalt used in our supply chain. The information from our suppliers, in combination with information from the RMI, helps Ericsson to obtain information on the origin of minerals processed. Data obtained was reviewed, analyzed and retained by Ericsson.
In Ericsson’s Code of Conduct for Business Partners, the topic of responsible sourcing of raw materials is included with clear requirements of suppliers to exercise due diligence in accordance with the OECD Guidance.
Employees are encouraged to report conduct that could violate law, the Code of Business Ethics or the Code of Conduct for Business Partners to their manager, and if due to circumstances, this is not an option, there are other channels that an employee may use, including reporting to the superior of a manager or to Group Functions People or Legal Affairs and Compliance. Such conduct may relate to corruption, fraud, auditing, questionable accounting, deficiencies in the internal controls, personal health and safety, environmental issues, human right matters, workplace respect and fairness or other matters that could constitute a breach of law, or that could harm the sustainability, or the reputation of Ericsson, its employees and shareholders. In addition, Ericsson has a whistle-blower tool, Ericsson Compliance Line, operated by a third party, for the reporting of alleged violations of laws, the Code of Business Ethics or the Code of Conduct for Business Partners. Ericsson Compliance Line is available 24/7, 365 days per year for both Ericsson employees, suppliers and other external parties. Ericsson recognizes that Ericsson Compliance Line might not be the most effective way of capturing issues related to sourcing of 3TG or cobalt and intends to further explore
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