Description Comment Reference Sustainability report 2017 (page) Question no. 4.1 Limitations

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1 NCAB Group s answers to the 77 questions in SIS Specification 2:2015 Social responsibility - systematic self-declaration (Original title in Swedish: SIS-SP 2:2015 Systematisk egendeklaration Socialt ansvarstagande). Question no 4.1 Limitations Description Comment Reference report 2017 (page) 1 What areas of the organization, unit or group of people are encompassed by the self-declaration, and if delimitations have been imposed, what is the reason for this? The self-declaration covers the whole organization. NCAB Group has a varying degree of influence and leverage over different stakeholder groups; main factories (higher influence), suppliers of transportation services (lower influence) and customers (varying influence). Pages 22 (own organization) 9, 10-13, 18-20, (relation to other stakeholders along the supply chain) 4.2 Management responsibility 2 How and where does the organization describe its overall position on social responsibility in relation to its vision/policy, business concept/operational concept, strategies, objectives and organizational culture (ethics and values) in the aim of maximizing its contribution to sustainable development? Our values, policies and approach to sustainability are described on our web page, om/. Further information is found in our annual sustainability report, which is also found on the web page. Whole sustainability report. Overall description and introduction to our approach on pages 4, Where and at what level of the organization was this position established? Group management 4 How have the seven principles for social responsibility (responsibility, transparency, ethical behavior, respect for stakeholder interests, respect for legal principles, respect for international rules of conduct and respect for human rights) been integrated in the organization s steering documents? 4.3 Operational control 5 How does the organization ensure that the necessary resources are available The principles were used in the process to develop the sustainability strategy. Further, the principles are integrated in our Code of Conduct and core values. Resources needed for the sustainability Pages 4, 8, 9, 11. Pages 9, 11.

2 (in terms of responsibility, budget and schedule, for example)? 6 How is responsibility and authority delegated and communicated within the organization? 7 What processes and procedures are used to ensure that the organization achieves its intended results? 8 How is the need for competence development within the organization identified and documented? strategy and actions followed thereof, are decided in management meetings for the annual plan. Group Functions have the overall responsibility. Each manager is responsible for sustainability goals related to his/her function. This is described in the Management Goals & Activities. That means sustainability is not separated from our overall management. Responsible for coordinating NCAB Group s sustainability strategy and report is strategic purchasing manager. In 2017 a new role was established for developing the approach to sustainability in the China office. Permanent topic of monthly management meetings and board meetings. To make sure all new employees get a good platform for the job we have an onboarding program This program was implemented in our new HR-system during It allows all employees to easily follow what steps they have completed, and make sure they get all information needed. A three year competence development plan including all employees, established The Global HR Manager Page 8, 9, 11. Page 15, 16

3 4.4 Identification and involvement of stakeholders 9 At what level in the organization has an identification of stakeholders been carried out? 10 What was the structure of the identification process that resulted in the selected stakeholders? 11 How has the process to identify stakeholders taken the value chain into consideration? keeps track of its implementation and follow-up. Managers can initiate other training elements as needed. During 2017 we developed a two-day program for leadership. Our leaders are evaluated according to the NCAB Group Leadership Recipe in dialogue with their employees. We perform PDAs (Performance and Development Appraisal), sales assessments and use own or external HR expertise to review training processes. In 2017 we compiled a catalogue containing all of our training programs for an easy overview. The identification was carried out by the steering group of the sustainability strategy project (members of Group Functions). Discussions based on existing dialogues and business intelligence: - with the steering group of the sustainability strategy project - external advisors - during the interviews mapping sustainability impact Our sustainability focus areas have been categorized in accordance to prioritized stakeholder groups: customers, employees and factories, covering report 2014, pages 7-8. report 2014, page 8.

4 12 What stakeholders have been identified as relevant for the organization? 13 What factors have determined the identification of stakeholders? 14 What consideration has been/is being taken into account in terms of stakeholder groups that may have trouble being heard and could thus demand special consideration? 15 What stakeholder groups represent society and the environment? the whole of our value chain. Owners, Employees, Customers, Suppliers and Factories, NGO:s. Those that affect and are affected most by the organization and those who are in the frontline regarding hot topics. Included NGOs in stakeholder dialogue - representing the environment and the interests further down in the supply chain (Swedwatch and KEMI (Swedish Chemicals Agency)). NGOs and authorities (Swedwatch and KEMI (Swedish Chemicals Agency)). Page 8. report 2015, page 8. report 2015, page 8. report 2015, page How have the company s social responsibility efforts influenced major collaborations and partnerships? 17 What procedures are in place to identify new stakeholders during new circumstances (such as a crisis) or in a new project? Relations with factories, suppliers of transportation services, and customers. Close dialogue internally: Monthly management meetings, regular meetings with MDs, contingency plan. Pages 10-13, In what way are the identified stakeholders prioritized, and what forms the basis for these prioritizations? 19 How does the organization gather expectations and opinions from stakeholders? During interviews for the sustainability strategy. Those that affect and are affected most by the organization. Interviews for the sustainability strategy and sustainability report, survey for the report 2015, page 8. Page 8.

5 20 How does the organization go about gathering opinions from stakeholders that are not organized or that have a particular difficulty articulating their interests? 21 On what scheduled occasions in the organization s day-to-day management and planning are the stakeholder s expectations and opinions addressed (and by whom)? 22 How does the organization handle the balance between society s needs for transparency and the organization s need for integrity? sustainability report, channels for regular stakeholder communication: customer satisfaction survey, customer seminars and meetings, factory meetings, followups and audits, employee engagement survey and PDAs (Performance and Development Appraisal), board meetings. Included NGOs in stakeholder dialogue for sustainability strategy - representing the environment and the interests further down in the supply chain. Internal management processes include monthly management meetings, regular meetings with MDs and PDAs (Performance and Development Appraisal). Dialogue with stakeholders take place through factory meetings, customer meetings, a well-defined product complaint process, performance and development appraisals, employee engagement survey, customer seminars, factory meetings, followups and advertisement and an annual customer satisfaction survey. Transparency is a motto. Apart from customer information and business secrets most information is communicated openly. report 2015, page 8. Pages 9, 10-11, 13,15-16, Whole report

6 23 How does the organization handle opinions and expectations from stakeholders throughout the value chain? 24 How does the organization handle potential conflicts of interest between the various stakeholder groups? Our sustainability report is one of the ways we communicate transparently about challenges and opportunities. NCAB Group is an Integrated PCB producer, working in close collaboration with both our customers and our factories. Stakeholder dialogue takes place through factory meetings, customer meetings and annual customer satisfaction survey, employee satisfaction survey and PDAs (Performance and Development Appraisal).. NGO s Swedwatch and KEMI were interviewed during the process of developing our sustainability strategy in Discussed in management meetings, decision based on values. Pages 8-9, 11, 15, 19 Page How has the organization used its stakeholder dialogues to strengthen the communication/reporting of its responsibility efforts? Stakeholder input is a basis for the sustainability strategy and for the content in the sustainability report. 4.5 Identification and prioritization of areas and principles under SS-ISO What type of business does the organization conduct? Integrated PCB producer. Whole sustainability report. Specific dialogue to improve sustainability report page 8. Pages What is the scope, size and structure of the organization? Global business with 345 employees in 14 countries and revenue of 145 million Euro in Pages 4-5.

7 28 In what countries/locations/areas is the organization active? China, Denmark, Finland, France, Germany, Italy, Macedonia, Norway, Poland, Russia, Spain, Sweden, UK, USA. Page What has the organization previously achieved and what is it currently doing in the area of social responsibility? 30 What policy documents, values, principles and codes of conduct, etc., related to social responsibility, does the organization have in place? 31 What is the scope of the organization s sphere of influence? 32 What decisions and activities from the organizations within the identified sphere of influence can impact the organization s social responsibility? 33 What core areas and sub-areas under section 6 of SS-ISO are deemed relevant to the organization and why? 34 What method was used to conduct the assessment referred to in question 33? See sustainability report Values, Code of conduct, Environmental Policy, Quality Policy, Policy, HR Policy, Health & Safety Policy. Conflict mineral policy. Integrated PCB producer: Suppliers, Employees, Customers. Employees living the values and follow the Code of Conduct. Factories integrating demands in their business and cooperating transparently. Factories own sustainability work and strategies. Customers posing demands and value NCAB Group s products and sustainability performance. Customers following NCAB Group s design guidelines. Summarized in overview of sustainability strategy. Method used: interviews and workshops. More described in report Whole report. Previous actions summarized on pages 6-7. Pages 4, 11, 16. Whole report Pages 8-9. report 2014,

8 2014 page How have the stakeholders been involved in the aim of helping the organization understand the relevance and significance of various areas? 36 What are the stakeholders needs and requests concerning the relevant subareas and how did this influence the prioritizations? 37 What impact do the relevant sub-areas have on the organization s ability to comply with legislation, international standards and rules of conduct to which they are subject? 38 What impact do the seven principles (in section 4 of SS-ISO 26000) have on the prioritizations? 39 What reasoning in terms of risk, opportunities and consequences has been taken into account in the Interviewed in the process to develop the sustainability strategy. Continuous dialogue through customer meetings and annual customer satisfaction survey, employee satisfaction survey. Stakeholder requests summarized used in process to develop strategy. Improved our systematic approach to law compliance. The strategy as a whole also helps us to be proactive in the different focus areas (the work with conflict minerals and our Global introduction including business ethics are examples of this). The NCAB Group Code of Conduct is based on UN s Universal Declaration of Human Rights, ISO and UN Global Compact The principles were evaluated separately and the two principles that were not fully implemented Ethical behavior and Respect for the rule of law were included in the prioritization of issues (governance, equal opportunities, anticorruption) Stakeholder perspectives and Impact on NCAB Pages 8-9, 15, Pages 8-9 report 2014, page 7 Pages 11, 15. Pages 6-7, 8-9.

9 prioritization of the core areas and subareas in the aim of ensuring long term sustainable commitment? Group were two dimensions in the prioritization of the sustainability issues. Business drivers summarized in overview of sustainability strategy. 40 How are the prioritizations followed up on, in intervals suitable for the organization? 4.6 Integration of social responsibility 41 What goals and action plans have been selected based on the prioritized subareas? 42 How have the goals been integrated into the organization s other goals and business plan? 43 How is the delegation of responsibility for the goals structured, related to the relevant functions and levels in the organization? 44 What resources (e.g. human resources, financial resources) have been provisioned for achieving the goals in accordance to action plans? More possibilities than risks. Strong and responsible relationships with our suppliers, employees and customers to gain sustainable business, growth and profitability for all. Follow-up in management and board meetings. Overview of sustainability strategy. In addition there is a more detailed action plan. Process for follow-up and evaluation in management meetings. Group Functions has the overall responsibility. Each manager is responsible for sustainability goals related to his/her function. This is described in the Management Goals and Activities. That means sustainability is not separated from our overall management. Clear ownership/ responsible person of each activity in the Management Goals & Activities. External help and internal resources to develop strategy and Page 9 Page 9, 10, 14, 18. Pages 8-9, 11

10 sustainability report. Decision on more resources for sustainability audits and sustainability work in the China office, starting from Feb Have any additional activities related to social responsibility, been carried out? If yes, please indicate. 46 What methods were used to measure, indicate, assess and follow up the existing and proposed prioritizations and goals? 47 How are the measurement methods evaluated? 48 What methods are used to track the results over time? 49 How does the organization report results on social responsibility in a manner that is comparable over time? 50 What qualitative and quantitative indicators are used to provide information about results and cases related to the organization and that are comparable and illustrate changes over time? Local initiatives by our companies within the areas of community involvement and charity, healthy and happy employees, healthy and happy workplace, and internal environmental work. Several goals and statistics/figures are indicated in the sustainability report, such as: share of audited factories, scores in employee engagement survey, gender balance, score in customer satisfaction survey, environmental footprint from transports Projects followed up in management meetings. Dialogue with concerned stakeholders, annual management review. Annual review of targets in parallel with the development of the sustainability report. Annual sustainability report. See above question 46 and data in report, e.g. number of audits, diversity statistics, quality statistics, customer satisfaction, employee engagement, CO2 emissions. Additional metrics are Pages 5, 11, 15, 16, 19, 20. Whole report. Pages 5, 11, 15, 16, 19, 20.

11 51 Are there external guidelines for reporting on social responsibility? If yes, please indicate the name and how the organization uses them. 52 What verification processes or certification systems, in which facts and details can be traced back to a reliable source to ensure the accuracy of the facts and details, are used? 53 How are the results of the social responsibility efforts evaluated? 54 How is the documentation for the communication of social responsibility prepared? 55 How are the organization s efforts for taking social responsibility communicated? being developed. Yes, the GRI Standards: Core option are used to prepare the sustainability report. ISO 14001, ISO 9001 and SIS Specification 2:2015 Social responsibility - systematic selfdeclaration (Original title in Swedish: SIS- SP2:2015 Systematisk egendeklaration Socialt ansvarstagande) (ISO 26000) third party assured. report according to GRI, not third party assured. Monthly management meetings The sustainability report covers the topics in the strategy. The sustainability report is prepared in dialogue with external advisors, according to GRI and ISO guidelines. A survey was conducted in November 2017 to get input to improve the sustainability report. report basis for further sustainability communication. report, MD meetings, management meetings, board meetings, annual conference, newsletter, web page, factory meetings, customer seminars and meetings, global introduction for new employees. Page 22. Pages 6-7, 8-9, 22-23, web page. Pages 8, Pages 6, 7, 8, 9, 11, 15, 16, 19, 20.

12 Branding of sustainability initiative Conscious component. 56 Has the organization chosen to omit certain topics in its communications and, if so, why? 57 How is the organization s selfdeclaration communicated? 58 How have policies/laws/norms been communicated in the organization? 59 What work methods apply for internal audits and internal reviews, and what results are available from these audits and reviews? 60 What results are available from external stakeholders audits and reviews of the operation or the organization s goods/services? No. The self-declaration is available on Intranet and on RISE website (former SP).The verification/statement from auditor (RISE Certification (former SP)) and information regarding the verification and self-declaration is available on NCAB Group website. Values have been developed jointly and signed by everyone and are included in our recruitment processes. Policies are available through intranet and web page. report is on the web page and is sent to all employees. is part of the local/global introduction of new employees. Monthly management meetings, PDAs (Performance and Development Appraisal), internal audits on ISO 14001,ISO 9001 and ISO Factory audits: quality audit and sustainability audit. External audits on ISO 14001, ISO 9001, SIS Specification 2:2015 Social responsibility - systematic selfdeclaration (Original title in Swedish: SIS- SP2:2015 Systematisk Pages 8-9, and website: bgroup.com/se /sustainability/ Pages 16. Pages 8, 9, 11, 12, 15, 19. Pages 6-7, 8-9.

13 61 How are complaints and damage claims from consumers and customers handled? 62 How are complaints from other stakeholders handled? 63 What methods are used to assess goals, the follow-up action plans and activities, and in what intervals are these assessments conducted? 64 What were the results achieved in relation to the goals? egendeklaration Socialt ansvarstagande) (ISO 26000), Customer audits. Thorough complainthandling process. Customers: Customer survey and meetings. Employees PDAs (Performance and Development Appraisal), and open culture. Raise issues to manager. Yearly employee engagement survey (started in 2016). In monthly management meetings. We have defined longterm goals for all the areas of our strategy. We are on track or have completed most of our goals. The area where least improvement was made was in reducing our environmental footprint. Pages 19, 20. Pages Whole report, overview see page Were the goals suitable and, if so, why? 66 What is the link between the organizations s overriding strategies and goals? 67 What changes from the predetermined action plans were made during the period? 68 Have decided activities been conducted? If not, why? The goals are suitable, challenging but realistic, and in line with our strategy and achieving sustainable progress and business. See sustainability strategy overview. The actions to reduce environmental footprint will be revised in Yes, mainly. See above question 67 for Whole report. Page 7. Whole report, examples

14 reference to topic where activities are considered in need of revision on pages How does the organization remain up-todate on all of its legal obligations? 70 How does the organization determine whether it is in compliance with legislation, requirements and international rules of conduct? 71 Are there any remarks from authorities or judicial verdicts citing legal noncompliance? 4.7 Continuous improvement 72 What methods were used to identify, manage and follow up the improvements? 73 What improvements were made during the period? Examples can be based on complaints, target fulfillment, legislative amendments and strategy decisions. 74 What improvements have been made in comparison with the reference year? Group common legislation is the responsibility of Group Functions. National legislation is handled by each local company. (Supported by external service for law/regulations updates/changes). Existing process for environmental legislation was reviewed and improved in Group common legislation is the responsibility of Group Functions, and national legislation is handled by each local company, following the processes in our management system. Existing process for environmental legislation was reviewed and improved in No In monthly management and board meetings. Preparations for the meetings done by each responsible manager. Yearly sustainability report. See our development, achievements and targets fulfilments in the report. See improvements for 2017 in question 73 above. Reference year is Page 11 Whole report, examples on page 2-3, summary on page 9. Whole report, examples on page 2-3, summary on

15 75 How has the past period s work with social responsibility impacted the organization s steering documents (strategies, policies, etc.)? 76 Have new prioritizations been made in the area and regarding principles and, if so, why? 77 What new overriding goals, detailed goals, action plans and activities in social responsibility have been established for the new period? Bromma, Sweden, 27 April 2018 Implemented a separate Environmental Policy (before Quality and Environmental Policy), Policy, separated our Code of Conduct into two Codes; one internal and one for suppliers. No new priorities except for the ones in the sustainability strategy developed in No new goals except for the ones in the sustainability strategy. New detailed factory sustainability audit plan. page 9, more trends on pages 11, 12, 15, 19, 20. Pages 8-9. Pages 8-9, 11.