In the global business context, the importance of business ethics is growing continuously. To meet customers’ sharpened requirements, Tieto is putting emphasis on implementing its responsible business practices throughout the value chain. The company’s Code of Conduct training is mandatory for all employees on an annual basis.
Tieto sees implementation of ethical values and work practices as a vital part of the company's corporate responsibility, and has zero tolerance for any unethical behaviour. Tieto's ethical values are outlined in the company-wide Code of Conduct Policy and related Rules, which apply to all stakeholders. The Code of Conduct Policy is aligned with local legislation in Tieto's operating countries, such as the UK Bribery Act and US Foreign Corrupt Practices Act.
During 2017, the #MeToo movement generated widespread global discussion on sexual harassment. #MeToo has ultimately expanded into a wider, worldwide discussion on human rights and initiatives aimed at creating a more equal and value-based world. It also showcases the demands formore transparency and for corporations to take a more active role in driving positive change.
At Tieto, internal communications on the Code of Conduct Policy and Anti-Corruption Rule were strengthened during 2017. As result, the amount of Tieto employees who completed the Code of Conduct e-learning rose from the previous year to 88% of all employees. As Tieto aims at 100% e-learning coverage, efforts to reach this target will continue. Towards the end of 2017, updates to the mandatory Code of Conduct e-learning were initiated to highlight Tieto´s zero tolerance towards any kind of unethical behaviour, and to strengthen whistleblowing, harassment and conflict of interest aspects.
Policies and rules governing business ethics
Tieto’s Code of Conduct Policy is in accordance with the United Nations Global Compact and the OECD Guidelines for Multinational Enterprises. It defines such things as the company’s human rights and workplace practices regarding non-discrimination, equal opportunities and a safe working environment. The policy also specifies the business practices regarding, for instance, conflicts of interest, gifts and bribes, and the safeguarding of corporate assets. In addition, the policy states that Tieto does not take political stances, nor give financial or in-kind contributions to political parties or institutions.
Tieto's HR policy, and health and safety policy provide additional guidance regarding specific sections in the Code of Conduct Policy. Tieto also has separate rules with detailed guidance, such as the Supplier Code of Conduct Rule, which is implemented in all new supplier contracts with regular suppliers.
Another example is the Anti-Corruption Rule. Tieto recognizes that corruption is still an ethical problem in society globally, and needs to be addressed by all enterprises and organizations. The Anti-Corruption Rule provides practical guidelines on how to avoid unethical behaviour and advises employees on how to evaluate different types of situations they may encounter at work. The rule is tailored for Tieto’s type of business, and applies to all employees in all countries of operation.
Tieto’s Competition Law Compliance Rule provides guidance for employees to assess what kind of behaviour is considered appropriate when interacting with other companies on the market, and to recognize when to seek the advice of our Legal function.
The company also has an Environmental Rule, which outlines the precautionary approach to environmental management at Tieto and in the value chain. This rule is compliant with ISO 14001 requirements.
In a rapidly changing and competitive business environment, conflicts of interest is an area which needs to be carefully addressed by all companies and organizations. At Tieto, this issue is addressed in the Code of Conduct Policy as well as the Operative Decision Making and Authority Policy, which describes the overall operative decision-making rules and authorities in the company. Tieto also applies segregation of duties, where one person cannot approve activities in which this person is involved.
Implementing ethical business practices in daily business operations
Tieto’s goal is that all employees are aware of, and know Code of Conduct and are proactively implementing ethical culture in Tieto’s operations. In addition to accepting the Code of Conduct when joining the company, employees are expected to refresh their knowledge on the content of the Code of Conduct on a yearly basis by taking the Code of Conduct and Anti-corruption e-learning course. This e-learning is based on practical examples tailored for Tieto. Real-life cases help to recognize situations where employees must assess and make decisions based on the Code of Conduct.
88% of employees trained in the Code of Conduct Policy and Anti-Corruption Rule
The increased focus on Code of Conduct Policy training generated good results in 2017. By the end of 2017, 88% (86%) of employees had been trained in the Code of Conduct Policy and the Anti-Corruption Rule.
Monitoring and follow-up of unethical behaviour
Tieto’s approach to unethical behaviour is embedded in the company’s proactive awareness campaigns, continuous monitoring and follow-up processes. The company’s risk management approach comprises a risk map for higher-level management, including the Board of Directors. The risk categories are compliance, financial, operational, project and strategic. To identify and validate the risks of unethical behaviour, Tieto conducts internal as well as external audits when required.
Internal audits are conducted by the Internal Audit function according to the annual plan based on the risks found. The aim is to ensure the company complies with the laws, regulations, and customer agreements in focus, as well as the company's policies and guidelines, in all operations. The Internal Audit Policy outlines the internal audit’s objectives, intentions, directions, responsibilities and possible consequences in terms of risk control, auditing, expediency and ethics. The policy covers governance, risk management and business processes, and applies to all employees.
Some internal investigations and audits are also initiated by whistleblowing. Tieto’s whistleblowing process allows anonymous and confidential reporting on suspected violations of the Code of Conduct, related rules, or any unethical behaviour to the General Counsel of the company and to the Internal Audit function. The process is designed to ensure that persons reporting violations will not be subject to any retaliation. Failure to act in compliance with the Code of Conduct can result in the appropriate disciplinary actions.
External financial audits are conducted by an external party and vary between full scope and statutory, depending on the size of business operations and specific needs. Audits include the testing of transactions as well as assessment of possible risks of corruption. The scope of the testing may cover ad-hoc audit assignments to evaluate the efficiency of the risk controls in place.
Zero tolerance for unethical behaviour
As part of Tieto’s zero tolerance for unethical behaviour, the company has as its goal that all its employees are not only aware of and know the Code of Conduct, but also that they know how to report suspected breaches. In 2017, a total of six breaches of the Code of Conduct Policy took place.
Internal whistleblowing escalations in 2017 generated six investigations in six different countries at eight sites, altogether covering approximately 25% of employees. These investigations included the analysis of risks of corruption, harassment, discrimination, conflict of interest, and suspected false invoicing and skimming.
External audits in 2017 covered 100% of our employees in all business operations and countries. No findings of misconduct were discovered in the financial audits in 2017.
Going forward, Tieto will evaluate learnings gained from customers’ supplier codes of conduct and liability rules. Tieto also plans to further strengthen awareness about these among its customer and delivery teams. In addition, the review and updating process of Tieto´s Code of Conduct e-learning was initiated at the end of 2017. Plans also exist to review the Code of Conduct Policy as a whole in the near future.