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 the law, Ericsson’s policies, including the Code of Business Ethics or the Code of Conduct for Business Partners, and related steering documents, to their respective manager. If the manager is unavailable, there are other channels that an employee may use to report such conduct, including reporting to the superior of a manager, Group Functions People, or Legal Affairs and Compliance. Reportable conduct may relate to corruption, fraud, auditing, questionable accounting, deficiencies in 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 reputation of Ericsson, its employees and shareholders. In addition, Ericsson provides employees and other external stakeholders a dedicated communication channel for reporting compliance concerns – the 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. The Ericsson Compliance Line is available 24 hours per day, seven days per week, 365 days per year. Ericsson recognizes that the 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 other mechanisms that may be more effective, like the Minerals Grievance Platform managed by RMI.
Ericsson has published a “Statement on sourcing of minerals from Conflict-Affected and High-Risk Areas” on its website (https://www.ericsson.com/49dadc/assets/local/about-ericsson/sustainability-and-corporate-responsibility/documents/2020/statement-on-sourcing-of-
minerals-from-cahra.pdf) that indicates Ericsson’s position and expected supplier activities in this area.
3.2 | Identify and assess risk in the supply chain |
In the second step of the OECD Guidance, risks are identified and assessed. For downstream companies such as Ericsson, the focus should be on the smelters and refiners. Downstream companies should, with help from their first-tier suppliers, identify smelters and refiners in the supply chain.
In Ericsson’s 2022 Conflict Minerals’ survey, first-tier suppliers identified to be in scope were requested by Ericsson to provide information on 3TG and cobalt in their supply chain through completing and submitting the Conflict Minerals Reporting Template and the Cobalt Reporting Template. Suppliers were provided with the Templates, support material, including the available instructions and training illustrating the use of the tool that is available on RMI’s website. To ensure quality, a high response rate and to minimize risks, the responses were analyzed and follow up questions were asked as deemed appropriate. Data obtained was saved, reviewed and analyzed by Ericsson. Supplier responses were reviewed against criteria developed to determine which responses required further engagement with our suppliers. In certain circumstances, suppliers were contacted via e-mail or telephone to improve the quality of responses (obtaining missing information, updating Templates’ formats to the required version) and increase the response rate (reminding supplier to provide information in the templates with extended deadlines).
3.3 | Design and implement a strategy to respond to identified risks |
Under the third step of the OECD Guidance, companies are encouraged to design and implement a strategy to respond to identified risks. Due diligence within Ericsson is an ongoing process. Ericsson publishes additional information about its commitment to responsible sourcing and engagement with its suppliers in its Sustainability and Corporate Responsibility Report, published together with the Annual Report.
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