20 BIOGAIA SUSTAINABILITY REPORT 2021 Materiality and risks Corruption is universally regarded as one of the major threats to both social and economic development. Corruption leads to the misallocation of resources, as well as undermining the rule of law and trust among stakeholders. BioGaia works with different companies in more than 100 countries where there are varying degrees of corruption risk.1) The main risks of corruption and bribery arise in connection with the sale of products to distributors, major purchases and insufficient independence of researchers and doctors. It is therefore essential that employees are aware of and prepared to manage these risks. How work is conducted To guide employees, BioGaia has a policy for anti-bribery and anti-corruption that covers the whole Group. The policy includes the company’s definitions of bribes, corruption and conflict of interest as well as overall guidelines for what is acceptable behaviour and channels for incident reporting. Anti-corruption is highly prioritised and is therefore the operational responsibility of a member of Executive Management. The Board of Directors bears the ultimate responsibility for business ethics and anti-corruption in the organisation. Training for employees in anti-corruption is held annually. This includes information on the impact of corruption on societies, BioGaia’s anti-corruption policy and existing laws and regulations. The training also draws attention to BioGaia’s whistleblower function, which plays an important part in anti-corruption efforts as this guarantees anonymity. After training, all participants complete a test to ensure they have adequate knowledge in the area. BioGaia’s target is that all employees in the Group should receive this annual training. During 2021, 97% (100) of the Parent Company and 92% (100) of employees in the Group received training. No corruption incidents were brought to the company’s attention in 2021. BioGaia’s whistleblower system is provided by an external party where employees and others can report perceived anomalies anonymously. The system is available through BioGaia’s external website in Swedish and English. The company’s guidelines for the whistleblower function are communicated in the anti-corruption policy, during training and for new employees during on-boarding. The anti- corruption policy is available for all employees. The team responsible for managing reported incidents in the system includes a representative from the Board of Directors and representatives from HR and Corporate Governance. BioGaia undertakes to comply with the EU directive to protect whistleblowers. No incidents were reported to the whistleblower system during 2021. Anti-corruption and anti-bribery (GRI 3-3) Anti-corruption work (GRI 205-2) Total number and percentage of employees that have received training in the company's anti-corruption policies by employee category 20211) 2020 2019 BioGaia AB 97% (93) 100% (96) 100% (94) Management team 100% (9) 100% (10) 100% (10) Employees 96% (81) 100% (86) 100% (84) BioGaia Group 92% (119) 100% (160) 86% (135) Management2) 100% (13) 100% (18) 100% (12) Employees 91% (106) 100% (142) 78% (123) 1) 2021 does not include employees who were on leave of absence or parental leave during the period as well as employees in Japan at Group level. 2) Management in BioGaia Group is Executive Management at BioGaia AB (9), Managing Directors at BioGaia Pharma (1), MetaboGen (1), BioGaia Production (1) and BioGaia Finland (1). A healthy business Progress and priorities going forward BioGaia’s annual training on anti-corruption and anti-bribery was updated during the year and launched in an online format. The training is interactive and information is mixed with questions and concludes with a mandatory questionnaire when users can test their knowledge. Over the next year, the training will be translated into Japanese to offer BioGaia Japan access to the information in their mother tongue. Therefore, employees in Japan (28) did not complete the training in 2021 but will do so in 2022 when the material has been translated. Every year, the Board reviews and approves all policies. The management of BioGaia Group has been trained in company anti-corruption policies and procedures. Of employees outside Sweden, five of six individuals in Singapore, the US and Finland have completed training. See data on suppliers, distributors and partners that have signed BioGaia’s external Code of Conduct, including anti-corruption clauses, in the section on healthy networks on pages 26–27. In addition, BioGaia has anti-corruption clauses in the standard contract templates. 1) BioGaia does not have any revenue from government contracts. CONTENTS
RkJQdWJsaXNoZXIy NjAyMDA=