3. Labor and human rights

It is of great importance that our suppliers treat their employees fairly, with dignity and respect, and that they respect human rights and avoid causing, contributing to or being linked to other parties' involvement in abuse of or adverse impact on labor and universally recognized human rights.

Suppliers shall:

Child labor

3.1.1 Not use, or support any use of, child labor and child exploitation. Establish a system to ensure that no childrenare employed, including systematically checking and maintaining copies of age verification documentation for all new employees.The minimum age for admission to work is 15 years old (or 14 if allowed by national law), or the legal age for employment if that is higher than 15. Ensure that all new employees have completed compulsory school before entering into employment.

3.1.2 Develop written procedures for child labor remediation in case children are found to be working at a company site.Ensure that such procedures are established in the best interest of the child, including adequate financial and other support to enable children to attend and remain in school.

3.1.3 Protect all young workers (below 18 years old)from performing any work that may be harmful to their health or their physical, mental, social, spiritual or moral development, and do not allow them to perform night shift work.

3.1.4 Comply with all laws and regulations governing apprenticeship programs.

3.2 Forced labor

3.2.1 Not engage in or support the use of any form of forced, compulsory or illegal labor, including trafficking, prison labor or bonded labor.

3.2.2 Ensure that all overtime work is consensual, unless necessary and mandated according to local laws.Allow employees the right to leave their accommodation and workplace freely duringtheir leisure time.

3.2.3 Not require that employees surrender original personal certificates or identification documents such as government-issued identification, passports or work permits, as a condition of employment at any time.

3.2.4 Not use unlawful disciplinary practices, for example, financial penalties such as unfair or illegal deductions from wages, withholding wages or discontinuing benefits as a disciplinary measure.

3.2.5 Not use any deposits, fees, fines, loans or repayment agreements to prevent employees from leaving their employment upon providing reasonable notice. Ensure that repayment agreements shall be foreseeable, reasonable and limited in time.

3.2.6 Ensure that migrant workers are treated fairly and on an equal basis with local employees.

3.3 Harassment, harsh or inhumane treatment

Not tolerate any physical or mental harassment or abuse, expressed verbally or non-verbally through gestures, including harsh or inhumane treatment, coercion, detention, or unwanted sexual advances, nor tolerate any threats of such treatment. Prohibit public warnings and punishment systems.

3.4 Discrimination

3.4.1 Not discriminate in hiring and employment practices.This includes, for example, promotion, benefits, access to training, layoffs, contract terminations, whether active or by means of passive support on the grounds of age, ethnicity, national or social origin, religion, gender, sexual orientation, marital or parental status, pregnancy, disability, union membership, political affiliation, serious illness or any other condition that could give rise to discrimination protected by applicable law or ILO Conventions.

3.4.2 Ensure that employees with the same experience and qualifications receive equal pay for equal work and equal opportunities.

3.5 Working hours

3.5.1 Divide working hours into normal working hours and overtime hours.

3.5.2 Record all working hours accurately and ina comprehensible manner.

3.5.3 Comply with applicable laws and industry standards on working hours.In any event, employees shall not, on a regular basis, be required to work in excess of 8 hours per day or 48 hours per week as normal working hours.

3.5.4 Not request overtime on a regular basis. All employees shall be provided with at least one day off for every seven-day period, and have sufficient time to rest between shifts.Ensure that overtime work does not exceed local legal limits or 12 hours per week.

3.6 Compensation and benefits

3.6.1 Comply, at a minimum, with all laws and regulations relating to wages, including minimum wages, overtime wages, piece rates and other elements of compensation, and provide legally mandated benefits, including social insurance.

3.6.2 Ensure that all employees are paid at least the statutory minimum wage.

3.6.3 Pay wages regularly, directly to the employee, at the agreed time, and in full.

3.6.4 Record all wages accurately, and provide all employees with a payslip clearly stating all parts of the salary in a comprehensible manner, including overtime compensation, hours worked, benefits, legal deductions, bonuses and other relevant posts.

3.6.5 Ensure that all employees have the right to paid statutory holidays and legally stipulated leaves, including paid sick leave and parental leave, without any negative consequences.

3.7 Emploment conditions

Inform all employees of their employment conditions, including rights and obligations, in the employee's native language or a language they understand, for example in a written labor contract.

3.8 Freedom of association and collective bargaining

Recognize and respect the right of employees to freely associate, organize and bargain collectively in accordance with the laws of the countries in which they are employed. Recognize the importance of open communication and direct engagement between employees and management. Allow employees to appoint independent work representatives and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal. Reversely, those employees who choose not to participate in workers' associations shall be respected for their choice.

3.9 Right to report concerns

Ensure that all employees have the right to report concerns regarding compliance with legal requirements or company policy/rules to their employer without fear of reprisal.

3.10 Right to property

3.10.1 Be the legal and rightful owner/user of the property on which they operate, according to local laws.

3.10.2 Avoid any negative social, environmental or economic impacts from land acquisition, involuntary resettlement or restrictions on land use.

3.10.3 In the event of expropriation or imposed relocation, ensure that adequate compensation is negotiated in a transparent manner, with the goal to maintain the livelihoods and standards of living of the persons concerned.

3.11 Conflict-free origin of minerals

3.11.1 Sourcing of minerals from conflict-affected and high-risk areas

  • Be conscious of the possible link between the production of raw materials and armed conflict or gross violation of human rights. Supply chains that either directly or indirectly contribute to conflicts are unacceptable. This applies to all stages of the supply chain.
  • When sourcing from conflict-affected or high-risk areas, follow the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affectedand High-Risk Areas.
  • Depending on your position in the supply chain, source raw materials from responsible sources only, or undertake reasonable measures to understand, and when necessary, influence your supply chains towards responsible sourcing.

Since arbitrary disengagement from conflict areas may cause negative consequences to the local population, Sandvik encourages ethical sourcing of minerals from these areas.

3.11.2 Compliance with Section 1502 of the Dodd-Frank Act

  • In order to help our customers comply with the provisions of the SEC1 Conflict Minerals Rule with respect to the supply chains of products containing tin, tantalum, tungsten or gold as covered by the Dodd-Frank Act, and in addition to what has been outlined above, conduct a reasonable country of origin inquiry and follow internationally accepted due diligence guidelines to assure that supplies to Sandvik qualify as "DRC2 conflict free" according to the SEC rule.
  • Ensure that these minerals are traceable to smelter level at a minimum, and only conflict-free smelters as defined by CFSI3 and TI-CMC4 or, where applicable, other established industry schemes are used.
  • Be aware that additional requirements may apply with respect to the supply of products containing conflict minerals according to the SEC rule.

3.11.3

Ensure that all efforts made pursuant to 3.11.1 and 3.11.2 are documented and made available to Sandvik upon request. Traceability data must be recorded and maintained for five years.

1) U.S. Securities and Exchange Commission

2) Democratic Republic of the Congo

3) Conflict-Free Sourcing Initiative

4) Tungsten Industry – Conflict Minerals Council