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General requirements

Everyone who carries out work within LKAB's operations must be provided with basic protection according to labour law. The demands LKAB places on suppliers are described here.

Supplier Code of Conduct

LKAB’s must always comply with the most stringent requirements of relevant legislation or requirements corresponding to LKAB’s Basic Requirements, which are an introductory part of the Supplier Code of Conduct and are requirements for which we have a zero-tolerance policy for all of our suppliers/contractors. There are no exemptions from acceptance of the Basic Requirements, which must be met by all suppliers/contractors from the first instance of the delivery of a product or service. The supplier/contractor is responsible for ensuring that all suppliers/subcontractors hired by them comply with the Basic Requirements.

The other detailed requirements describe in greater detail the areas covered by the Basic Requirements and other requirements. LKAB expects that all suppliers/contractors will strive to comply with all other detailed requirements within the agreed period.

LKAB’s Supplier Code of Conduct ensures that we collaborate with suppliers who share our values with respect to sustainability and whose ambition is to develop in order to remain at the forefront in these areas. The requirements are based on the UN Global Compact, UNICEF’s Children’s Rights and Business Principles, the OECD’s Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and the UN Sustainable Development Goals.

LKAB also encourages suppliers/contractors, in turn, to work in a similar manner with their suppliers/subcontractors to ensure compliance with the detailed requirements. By working proactively in these areas and ensuring that the requirements are met, important steps are taken towards the development of our operations and the entire value chain. For more information concerning the Supplier Code of Conduct, acceptance of Basic Requirements and information concerning ongoing procurements, please see LKAB’s supplier portal at www.lkab.com/leverantor

SUBCONTRACTORS

Primary contractors may hire at most two levels of subcontractors. This means that the primary contractor can at most hire one first-tier subcontractor who, in turn, hires one second-tier subcontractor. A subcontractor is a party that is hired by the contractor to perform work within LKAB’s premises/operations. This also includes personnel from staffing companies and consultants who perform work within LKAB’s premises/operations. Contractors are responsible for informing LKAB of all subcontractors, and subcontractors thereof (second-tier contractors), which they assign to work at LKAB’s premises, and for ensuring that they comply with applicable laws and regulations. The contractor’s choice of first-tier and second-tier subcontractors must be approved by LKAB before the subcontractor begins work within LKAB’s premises.

Collective agreements and insurance rules

Everyone who carries out work within LKAB must be provided with basic protection according to labour law. The fundamental requirements that apply to suppliers carrying out work within LKAB are that the company must possess and be able to show:

  • F-tax certificate
  • Swedish collective agreement or substitute agreement with IF Metall (Mining agreement/ME-Mining agreement depending on operation), Byggnads or corresponding trade union.
  • Requisite liability insurance

Safe and effective work

Safe, enjoyable, cost-effective work is achieved in part by taking responsibility. Safe actions involve taking individual responsibility, showing consideration and highlighting deficiencies. The right attitude is decisive when it comes to preventing ill health and accidents. Dangerous working methods and risky behaviour are never acceptable! The goal is zero accidents and for nobody to be affected by ill health or illness in their work.

Reporting of risks, incidents, accidents and quality deviations must be performed by all suppliers who carry out work within LKAB's operations. Reporting is conducted via LKAB's deviation management system. Contact your appointed contact person to apply for users.

The role and responsibility of the works management are decisive in all work. It is important for representatives of the works management frequently to be present in the work area to ensure compliance with the rules and a positive working situation for the personnel. The employer always has the principal responsibility for its employees' working situation and performance.

Individual responsibility means that everyone takes responsibility for their own efforts, complies with applicable regulations and participates in remedying any deficiencies.

Safety First is the collective name for LKAB's work regarding safety at our workplaces. Collaboration, job satisfaction and a good working environment are principal ingredients for effective, successful work.

In order to ensure safe and effective work, activities must be permeated by a systematic approach to work and by keeping things in good order.

A systematic approach to work means that all those who carry out work:

  • Are aware of the risks (working environment, fire, environment, etc.) in the work that is to be carried out, by means of risk assessments being drawn up, updated and communicated.
  • Are aware of how risks, incidents, accidents and quality deviations should be reported.
  • Know how they should act in the event of an emergency.
  • Have access to correct information.
  • Have work-related decisions communicated in a clear and descriptive manner.
  • Possess the required permits and expertise to carry out the work, and can confirm this.
  • Use work equipment that has been checked, approved, adapted and is in good condition.
  • Have access to and, if necessary, use personal protective equipment that is adapted, approved and in good condition.
  • Receive information about implemented safety and environmental rounds, as well as measures based on these.
  • Have access to a work area that is well arranged in relation to the work that is to be carried out (landfill, chemical handling and parking, for instance).

Keeping things in good order means that:

  • Good order is maintained within the work area – the right thing in the right place.
  • Machines, tools and equipment are adapted for their areas of application.
  • Procedures are in place for keeping premises, machines, tools, equipment, etc., in good condition.
  • The work area is cleaned and restored to its original condition when the work is completed.

Reporting suspected breaches

Suppliers should primarily get in touch with their contact at LKAB or with the purchasing unit, HR and sustainability unit, finance unit, or legal unit to report suspected breaches. SpeakUp should be used when normal contact channels are insufficient.
The SpeakUp whistleblower system can be used when you know or suspect that the following is happening at LKAB:

  • financial crimes such as bribery, corruption, fraud or forgery
  • significant safety failings in the workplace
  • significant breaches of environmental regulations or pollution
  • serious forms of discrimination and harassment.

More information about this can be found on LKAB's information about sustainability.

Communication

There are general provisions regarding communication within LKAB's operations which entail the following:

  • Always endeavour to achieve personal contact when it comes to providing information or giving feedback at work. All communication should take place in Swedish in the first instance. Other languages may be used, if it has been ascertained that the provider and recipient of the information can understand each other.
  • Communication by telephone and radio should take place in Swedish in the first instance. Telephones and radio receivers must be checked and maintained recurrently to ensure that the equipment is in good condition and good working order.
  • The supplier must safeguard communications with the outside world by having at least one person working in the work area who can speak Swedish or English. In emergencies, communication by telephone and radio must take place in Swedish or English, so that the recipient of the message understands the information.
  • Only Swedish-speaking or English-speaking individuals may work alone, to ensure communication with the outside world. Courier deliveries to Material supplies may however be allowed with the permission of the industrial guard.

Photography

There is a general ban on photography within LKAB's industrial areas and premises, unless photography is part of the assignment from LKAB. This ban also applies to the publication of images and film from LKAB's areas in external channels (mass media, social media, marketing, political messages, etc.) without a special permit. A special permit can be obtained through LKAB's contact person in accordance with LKAB's procedures.

Press visits and media productions

Prior to press visits and visits by external stakeholders' media producers (photographers, film-makers, etc.) to LKAB's operations, the Information Department must always be contacted for an assessment and handling. The Information Department always contacts the party concerned in the operation that is to be visited, before any decision regarding the visit is made.

Alcohol and drugs

LKAB has a policy regarding alcohol and drugs. Work within LKAB's operations may not be carried out under the influence of alcohol, drugs or other non-medicinal preparations.

For this reason, random alcohol and drugs tests are performed on everyone who works within LKAB. In addition to the random tests, test are also carried out if there is a suspicion that a person is under the influence and in conjunction with serious accidents/incidents. The tests are performed by an external drug testing company. If it is demonstrated that a person is under the influence, that individual will immediately lose their entry permit to LKAB. If a breath test indicates that a person is under the influence of alcohol when driving a vehicle, the police will be notified if there is any suspicion of a traffic offence.

When staff are called in for drugs tests, the works management must ensure that the individuals in question present themselves immediately along with valid ID. If the person does not turn up, their entry permit will immediately be withdrawn.

If a person is found to be under the influence of alcohol or drugs, LKAB will contact the relevant supplier and the person's entry permit will be withdrawn. In such cases, the supplier has an obligation to implement comprehensive measures in order for the person to regain their entry permit. The entry permit is regained if the person, on the basis of the measures implemented by the supplier, is no longer deemed to constitute a safety risk to LKAB.

Smoking

All smoking indoors is prohibited. When smoking outdoors, consideration must be given to people and ongoing work in the immediate vicinity.

Insufficient compliance with requirements

Non-compliance is normally dealt with by LKAB’s designated contact person in consultation with the contractor’s supervisor. The most important thing is to act when non-compliance is noted, so that serious incidents or repeated non-compliance can be prevented.

Contractors are responsible for informing LKAB of all subcontractors, and subcontractors thereof (second-tier contractors), which they assign to work at LKAB’s premises, and for ensuring that they comply with applicable laws and regulations. Failure to comply with applicable regulations may result in sanctions and contract renegotiation. Further information is available from LKAB’s Purchasing Department.

The sanctioning system can be applied if an employee has acted in contravention of applicable regulations:

  • Traffic infringements
  • The use of violence or the threat of violence, persecution, victimisation or extortion.
  • Damage to property owned by LKAB or another party.
  • Incorrect operation or driving of works equipment or vehicles.
  • Incorrectly maintained or equipped vehicle. See Vehicle requirements for penalty amounts.
  • Incorrect use or absence of personal protective equipment.
  • Non-approved removal or damage to safety devices.
  • Incorrectly erected cordons, protective railings, scaffolding, non-permitted entry into an area that has been cordoned off, or infringement of Lockout & Tagout.
  • Use of non-permitted equipment or equipment that is in poor condition.
  • Blocking of evacuation routes.
  • Other transgressions that are obviously in breach of laws/regulations, LKAB's internal regulations or LKAB's basic requirements.

All transgressions must be reported rapidly to the nearest works management which, if possible, must act to prevent a repeat. The works management is responsible for reporting transgressions to the contact person.

  • The degree of severity increases in the event that:
  • The supplier has been engaged on a number of occasions and the individual making the transgression is judged to have committed a conscious error.
  • The supplier's transgression has entailed that their own personnel and the personnel of others are exposed to an obvious risk.
  • The supplier has an extended responsibility within Safety First based on the size and scope of the company.
  • The supplier has breached the above on repeated occasions.

The sanctioning system is applied as follows:

  • Verbal reminder from the appointed contact person within LKAB – The supplier has carried out a minor transgression.
  • Written reminder from the appointed contact person within LKAB – The supplier has carried out a significant transgression.
  • Sanctions based on applicable contract (handled by LKAB's Purchasing department) – The supplier has carried out a serious or repeated transgression.

Clarification regarding traffic infringements:

Infringement Low Medium High Unacceptable
Speed infringements 1-15 kph over signposted speed limit. 1-10 kph over signposted speed limit in 30-kph zone. 16-30 kph over signposted speed limit or repeated instances of violations over a 12-month period. 11-10 kph over signposted speed limit in 30-kph zone. 31-35 kph over signposted speed limit. Repeated instances of violations over a 12-month period. 21-10 kph over signposted speed limit in 30-kph zone. More than 36 kph over signposted speed limit. More than 26 kph over signposted speed limit in 30-kph zone.
Incorrect parking, engine idling, use of mobile telephone while driving, failure to wear seatbelt. First occasion Second occasion Third occasion > 3 occasions over a 12-month period
Sanction: revocation of vehicle access permit. Letter to contractor. The contractor must present an action plan for safety work with respect to traffic issues. Contractor’s vehicle operator: 1 month revocation of vehicle access permit + Letter to contractor. Contractor’s vehicle operator: 2 months revocation of vehicle access permit + Letter to contractor. Sanction is determined depending on the nature of the violation. Contractor’s vehicle operator:  minimum 3 months revocation of vehicle access permit . Managed by Purchasing.

Sanctions is handed to the driver of the vehicle if violations has been made regarding incorrect parking or idling. The owner of the vehicle is responsible to investigate who has committed the violation if no person is present.

NOTE! - The driver is not allowed to drive within LKAB operations if the entry permit is withdrawn.

GDPR (The General Data Protection Regulation)

LKAB must process the personal data of suppliers' employees. Processing of such data is in compliance with the General Data Protection Regulation (GDPR). LKAB processes personal data in situations such as:

  • Authorization for access to LKAB's industrial sites, based on the balancing of interests.
  • Authorization for access to mines, based on safety requirements.
  • Processing of applications for access permits.
  • Drug testing on LKAB's premises, with the balancing of legitimate interests and employment law as the legal basis.
  • Authorization for various types of work, such as hot work and lifting, based on legal requirements.
  • If necessary, to be able to manage invoicing.
  • For contact lists for projects, etc., based on legal requirements.
  • In the event of sanctions.

Suppliers are obliged to inform their employees of LKAB's processing of personal data and of the relevant systems and areas in this regard.