We take a comprehensive approach to human rights considerations in the sales process.

Integrating a human rights perspective into the sales process is essential for our commitment to respect human rights throughout our operations, particularly for the assessment, prevention and mitigation of potential impacts related freedom of expression and privacy. We have a fully operational sales compliance process to ensure consideration of human rights.

The Sales Compliance Process regularly reviews human rights impacts in the sales process and examines specific sales requests. A Sales Compliance Board, represented by various departments and functions, has ultimate responsibility for the process, and may approve sales with conditions or reject them outright. In some cases, it may recommend human rights impacts assessment for specific countries. When necessary, the Sales Compliance Process determines whether mitigation actions should be undertaken.

Taking action

As noted above, the Sales Compliance Board decides about mitigating conditions as applicable. The Sales Compliance pro­cess includes procedures to follow up decisions and corresponding mitigation activities. In 2016, we put particular focus on the possibility to strengthen contractual mitigation and use leverage within the sales compliance process.

Criteria for evaluation

Sales that trigger one or more of the following criteria are evaluated in the sales compliance process:

  • Portfolio: Whether the sale includes sensitive products, services and know-how.
  • Purpose: This concerns understanding the purpose and context in which the product, service or know-how will likely be used.
  • Customer: To whom we sell/deliver.
  • Country: Insights into the country to which we deliver, based on the risk indices of a global risk analytics firm in areas such as human rights risks; corruption; democratic governance; freedom of opinion and expression. Countries under sanctions as well as those ranked as a high risk require special attention. We understand that this is an ongoing process, thus we continuously monitor international developments.

Outcome of cases in 2016

In 2016, more than 600 cases were reviewed in the Sales Compliance Process (see graph). This implies an increase of 37% compared to 2015. We continually work to improve both the sales compliance process and adherence to it.

Sales compliance risk methodology