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 meet the most stringent requirements in relevant legislation, rules and regulations, or requirements corresponding to those stated in LKAB’s Supplier Code of Conduct.
The Supplier Code of Conduct comprises two sections: Basic Requirements and Other Detailed Requirements.
The Basic Requirements 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’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 and information concerning ongoing procurements, see LKAB’s supplier portal. Please refer to www.lkab.com/leverantor
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 bargaining agreements and insurance regulations
In accordance with collective bargaining agreements that are applicable throughout Sweden within the industry in question, all contractors and vendors who perform work within LKAB's operations/premises must ensure terms and conditions for their employees with respect to pay, working time and vacation periods. These terms and conditions must, as a minimum, correspond to what is specified in current legislation. This requirement applies to contractors' employees who perform work under contract with LKAB, as well as to employees of subcontractors who participate directly in the contract work. The contractor must also hold an F-tax certificate and provide requisite liability insurance for the work that is to be performed.
Requirement for F-tax registration
As of 1 January 2021, the Swedish payer is required to deduct tax (30%) for all payment for work performed in Sweden if the recipient is not F-tax certified in Sweden.
However, LKAB requires that non-Swedish companies that perform work, or who are intended to perform work, for LKAB in Sweden, immediately register for F-tax and can present a Swedish F-tax certificate, unless the Swedish Tax Agency has decided otherwise and has approved an exemption. https://www.skatteverket.se/
Labour law and insurance rules
Suppliers who perform work within LKAB´s operations must ensure their employees conditions regarding salary, working hours and annual leave in accordance with collective agreements that are applied throughout Sweden in the current industry. The conditions must always at least correspond to current legislation. This requirement applies to the supplier’s employees who perform work under contract with LKAB and employees of any subcontractors who directly are part in the contract. The supplier must also hold an F-tax certificate and the requisite liability insurance for the work to be performed.
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.
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.
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 an alcohol and drug policy. Work may not be performed within LKAB’s operations, within or outside of LKAB’s industrial sites, by persons under the influence of alcohol, drugs or other controlled substances.
The supplier must have a drug policy or similar control document, of which the purpose is to prohibit work under the influence of all forms of alcohol and drugs (controlled substances). This policy must be implemented and all co-workers must be familiar with it. The document must be written in a language that is understood by all personnel.
The supplier must always work proactively to minimize the risk of work being carried out under the influence of alcohol and drugs. The supplier must, at the request of LKAB, give an account of measures taken by the supplier to prevent the incidence of work being conducted under the influence of alcohol and drugs, for example, by carrying out random alcohol and drug testing of personnel who perform work on behalf of the supplier.
All persons who work on LKAB’s premises may be subjected to random drug and alcohol testing. In addition to drug and alcohol testing through random checks, testing is also carried out in cases of suspicion and in cases of accidents/incidents. These tests are carried out by an external drug testing company. Personnel who test positive on alcohol or narcotic testing will have their LKAB access permits revoked. If a vehicle operator tests positive in a breath alcohol test, the police will be contacted in the event of suspicion of traffic violation. When a person is summoned for drug testing, the supervisor must ensure that the party in question presents himself/herself forthwith and shows valid identification.
If the person does not show up for testing, their LKAB access card will be immediately revoked. If it is evident that a person is under the influence of alcohol or drugs, LKAB will contact the contractor/employer and the person’s access card will be revoked. The contractor will in this case be obliged to take extensive measures to have the person’s access card reinstated. The access card will be reinstated if the person, owing to the contractor’s measures, can no longer be deemed to constitute a safety risk for LKAB.
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.