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Due diligence in the sales process

We have integrated human rights due diligence into our sales process to help us assess, prevent and mitigate potential negative impacts on the right to freedom of expression and the right to privacy – two of our most salient human rights issues. Specifically, we aim to reduce the risk that third-parties use our technology, services and knowledge directly or indirectly in a way that impacts negatively on these human rights. We can see that technology evolution will require industry cooperation, which we discuss with different stakeholder groups such as the Global Network Initiative.

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.

Risk methodology

Sales opportunities are evaluated according to the following criteria:

  1. Portfolio: Whether the sale includes sensitive products, services and knowledge
  2. Purpose: The purpose and context in which the customer intends to use the product, service or knowledge
  3. Customer: The type and ownership structure
  4. Country: We use a third-party risk analytics firm to rank the countries according to risk and selected indices such as the Right to Privacy and Freedom of Speech, as well as Democratic Governance and Corruption. In addition, we routinely follow international developments.

Taking action

A sales opportunity can be rejected, approved, or approved with conditions. Our sales compliance process mitigates the risk for misuse through conditional approvals – that is, technical mitigations that prevent deployment of sensitive functionality and/or contractual mitigations that prevent misuse. These conditional approvals enable us to apply leverage to influence and potentially effect a positive change. The sales compliance process includes procedures to follow up on decisions and corresponding mitigation activities.

Leveraging automation

In 2017, we integrated our automated sales compliance tool into our global sales management system, which is fully integrated into our sales process. As a result, our sales compliance process covers sales and business engagements around the world, with every sales opportunity automatically screened for potential risks.

Outcome of cases in 2017

In 2017, 846 engagements were reviewed for sales compliance (see graphs below). This corresponds to an increase of 41% compared to 2016. The increase is due to a combination of a more robust system and the introduction of automated case handling since we first implemented the process. We also started including our “Entering into new country” evaluations as a formal component of the process.

Sales compliance cases 2013-2017

Sales compliance cases 2013-2017

Sales compliance cases 2017

Sales compliance cases 2017