Mölnlycke Code of Conduct
sets out how we expect our employees to conduct themselves to best represent the company and live our values. It reflects Mölnlycke’s commitment to ethical behaviour and how we treat each other and our stakeholders.
As a world-leading medical products and solutions company, we want to create value and contribute to the societies where we do business. Our desire to help patients and healthcare professionals to achieve the best possible outcomes is always at the core of what we do. We deliver on this commitment through uncompromising integrity.
"At Mölnlycke, we go beyond policies and written statements – we embed an integrity mindset throughout the company. To us, acting with integrity means being trustworthy, accountable and fair and doing business ethically and sustainably."
Zlatko Rihter Chief Executive Officer
Mölnlycke aims to act in a socially responsible way and promote ethical conduct. To ensure such conduct, we have set up a policy framework with our Code of Conduct as our guiding light. For more information on our policy framework, please have a look at the different areas below:
In addition to Mölnlycke’s own Code of Conduct, we have a Supplier Code of Conduct and a Distributor Code of Conduct. These third party codes of conduct reinforce Mölnlycke’s commitment to business ethics and compliance throughout our supply and distribution networks and provide specific guidance relevant to each group.
A robust framework of policies ensures ethical behaviours throughout Mölnlycke’s business, in accordance with our strategy. Mölnlycke’s policies are owned by the relevant functions and approved by the Executive Leadership Team or the Board of Directors. Below you will find some of Mölnlycke’s most important policies.
Mölnlycke’s ambition is to transform our business and become a global leader in sustainable healthcare. The sustainability policy serves as the framework for our coordinated sustainability work.
At Mölnlycke, we respect people’s privacy and it’s important for us to process personal data ethically and responsibly, both as an employer and as a trusted business partner.
The purpose of our position statements is to provide clarity to stakeholders on areas of high relevance to Mölnlycke either in light of our near- and long-term strategic ambitions or due to the nature of our business.
Our ambition is to transform our business and become a global leader in sustainable healthcare, decoupling our growth from resource constraints and reducing our dependency on virgin fossil materials and fuels.
In December 2022, we committed to becoming a Net Zero company by 2050 at the latest and in 2024 Science Based Targets initiative validated our near-term GHG emission reduction targets, confirming that we are fully aligned with the 1.5°C pathway and the ambitions of the Paris Agreement.
The commitment includes our own operations (Scope 1 and 2), as well as Scope 3 upstream and downstream. Scope 3 covers around ~70% of our total emissions (in 2023); it includes purchased goods and services, transportation, application, use and end-of-life treatment of products.
We also seeking to further the ambitions of the Paris Agreement through policy engagement, which we primarily conduct through industry bodies.
Apart from aligning with the 1.5°C pathway, we ramp up developing and delivering sustainable solutions to support the transition to a clean low-carbon economy using the UN Sustainable Development Goals on Affordable and Clean Energy (#7) and Climate Action (#13) as a lens to address challenges, build a strong growth strategy and access new markets along the way.
To make rapid progress in reducing greenhouse gas emissions and reach the Scope 1 and 2 target while maintaining long-term business growth, a clear plan has been established to transition to 100% renewable electricity by the end of 2024 and continually reduce our absolute energy consumption year-on-year, while looking into fossil-free heat sources. We actively pursue energy efficiency and conservation programmes at our locations across the globe.
The target on renewable electricity is progressing well, with a current (2023) total share of renewable electricity use of 65% globally and 9 facilities operating entirely on renewable electricity, using solar panels, renewable electricity supply from the grid and Energy Attribute Certificates (EACs), (please see Mölnlycke Annual Report 2023 for details). We have made a significant progress in our efforts to increase the share of renewable electricity from sources with higher additionality in the near future, with sites in Malaysia and UK having completed the installation of solar photovoltaic systems forecasted to account for 10% and 12.4% of the sites’ annual electricity consumption respectively. The work on the solar panel installation on our factories in Thailand is underway. We signed virtual Power Purchase Agreements (vPPA) for a wind farm in Finland also covering the factories in Belgium, Czech Republic and Denmark (35 GWh/y during 10 years). Another vPPA with a renewable energy generator in Malaysia is expected to be signed in 2024.
We partner with customers and suppliers to drive sustainable innovation to reduce GHG emissions in our value chains across our businesses. Below are just a few examples of the work we do to reduce GHG emissions in our value chains:
We have introduced GHG emissions assessment into relevant investment requests to drive further awareness of the environmental and future economic impact of major decisions, and to strengthen the sustainability of our business portfolio as a result.
An internal carbon price for investment decisions has been included, anticipating the impact of any future carbon pricing. The internal price of carbon implemented is uniform and static and set to a relatively high level, 100€/t, to internalise potential future costs of carbon in the long term. It enables the management to arbitrate between different options, to choose the most virtuous and efficient ones to achieve the goals of Net Zero by latest 2050. Mölnlycke’s suppliers and customers might be impacted by carbon pricing, which creates both risks and opportunities. For example, the company can mitigate the carbon cost impact for their suppliers and customers by offering sustainable solutions.
Our GHG value chain emissions (Scope 1, 2 and 3) are made transparent through our external sustainability reporting, which is in line with the GHG Protocol and follows GRI standards. We also report climate risks and low carbon opportunities through the CDP Climate questionnaire for the benefit of all our stakeholders. We use key indicators to track our progress and drive continuous improvement processes in every function, supported by external benchmarks.
We support the recommendations from Task Force on Climate-related Financial Disclosures (TCFD) and include those disclosures in our external sustainability reporting. We recognise that climate change will pose risks as well as opportunities for us and our customers, both directly through our operations and indirectly through our stakeholder activities. Therefore, we listen to the needs of our stakeholders when operating and providing our solutions.
Finally, we have introduced GHG emission reductions in our travel policy that applies to all employees and consultants, by reducing unnecessary travel or switching to alternative ways of travelling using more efficient and fossil-free transportation means.
At Mölnlycke, we respect people’s privacy and it is important for
us to process personal data ethically and responsibly, both as an
employer and as a trusted business partner.
Applicable data protection laws regulate the way Mölnlycke collects and processes
personal data. Our internal privacy policies and procedures also require us to meet
legal obligations around privacy in the jurisdictions where we operate. Data
protection laws apply to all processing of personal data by Mölnlycke.
Complying with these laws is essential to ensure that Mölnlycke operates in an ethical and responsible manner. We respect the privacy and rights of individuals whose personal data is processed by our company, regardless of whether they are customers, business partners, healthcare professionals, employees, or patients.
Personal data can be any type of information which is related to an identified or identifiable individual.
Examples of personal data are:
Name and surname of a person or a person’s email address such asname.surname@molnlycke.com, A person’s home address or their location data (for example collected via functions on amobile phone), An Internet Protocol (IP) address or any other type of identifier of a personal device,Images enabling identification of a person, A person’s health data.
Sometimes, personal information is changed in a way that hides who it belongs to, like using acode or a fake name. But even when it is changed like this, if it can still be used to figure out whothe person is, it is still considered personal information. However, when data is completelychanged so that it can't be linked back to any individual, like when it is grouped together or turnedinto statistics, it is not covered by these rules.
The aim of this Privacy Commitment is to establish the global and fundamental principles guiding Mölnlycke's protection of individuals' rights to their personal data and integrity. These principles shape Mölnlycke's policies and procedures, extending across the entire organization and also to its business partners.
This Privacy Commitment applies across the entire Mölnlycke organization, including its work methods, processes, materials, equipment, software, communication channels, and paper documents involved in handling personal data.
We believe that privacy is more than just following the law. As a world leading medical solutions company, we have an ethical responsibility – in addition to the legal obligations – to ensure sustainable use of, and to protect, the personal data entrusted to us. It is part of Mölnlycke being an ethical and sustainable business, revolutionising care for people and planet. All Mölnlycke personnel are expected and obliged to respect and honour this Privacy Commitment as well as Mölnlycke’s internal policies and procedures of handling personal data, to ensure that the processing of personal data is ethical, lawful, fair, and transparent, and that the rights of the data subjects are duly fulfilled and respected. To this end, Mölnlycke operates under a set of general good practices in relation to personal data processing, safeguarding that:
i. the processing of data is:
ii. we are clear, open, and honest with individuals about how their personal data will be used:
iii. to the extent possible, all individuals shall recieve information about processing of their personal data in a clear, transparent, and prompt manner:
iv. the collection, use and storage of personal data is carried out only on the minimum personal data, necessary and sufficient for the respective purpose:
v. the personal data processed is accurate:
vi. personal data is only stored for the period of time necessary to fulfil the purpose for which it was collected, to comply with a legal obligation, or for a lawful compatible secondary use, and is subsequently anonymised or deleted, in accordance with Mölnlycke's retention and deletion policy:
vii. personal data is kept centralised whenever possible to ensure quick and efficient fulfilment of data subject's rights:
viii. any personal data transferred cross-borders is adequately safeguarded and protected:
ix. a record of data processing activities is maintained to establish a transparent overview of the processing activitites conducted by or on behalf of Mölnlycke: and,
x. personal data is processed in a way that safeguards security, integrity, and confidentiality of the personal data.
Data Protection Officer (DPO).
Mölnlycke appoints a global, as well as local DPOs, where applicable and required, which are registered with the competent supervisory authority. The
DPOs are responsible for overseeing that all processing activities are conducted in compliance with applicable data protection laws, this Privacy Commitment, and other Mölnlycke policies and procedures. In addition, the DPOs are responsible for the training of personnel as well as functioning as the point of contact for inquiries from individuals whose personal data Mölnlycke
process, or from the supervisory authorities.
Cross-border transfers.
Mölnlycke is a global company and therefore processes personal data
within the different jurisdictions that Mölnlycke operates. We will not transfer personal data across borders if not necessary for the purpose of processing. When personal data is processed by Mölnlycke within the EU/EEA, we strive to limit any third country transfers. If Mölnlycke would transfer personal data outside of EU/EEA, Mölnlycke will safeguard that the transfer is made in
accordance with applicable data protection laws, by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission, or by ensuring appropriate safeguards based on the use of standard contractual clauses that the European Commission has adopted and other appropriate measures to safeguard
the rights and freedoms of individuals.
Retention policy.
Mölnlycke maintains a policy and procedures to safeguard that personal data
is either anonymised or deleted when it is no longer necessary for the purpose it is processed. Mölnlycke strives to foster a culture of “deciding what to keep” instead of “deciding what to delete”.
Records of processing activities.
Mölnlycke maintains a clear and transparent record of all processing activities. This enables Mölnlycke to have an updated overview of the business activities
which involves the processing of personal data and ensuring that such activities are conducted in a compliant manner.
Incident management.
A personal data breach is a breach of security leading to the accidental or
unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. If a personal data breach would occur, Mölnlycke is prepared to handle it through its established policies and routines on identification, remedial, assessment, reporting and documentation of
breaches.
Data protection by design and by default.
At Mölnlycke, the principles of privacy and compliance with applicable data protection laws is a natural part of the development of any project, process,
or product, involving the processing of personal data. This includes implementing necessary technical and organisational measures to safeguard that the processing activities are carried out in an ethical manner and in compliance with applicable law, this Privacy Commitment, and any other Mölnlycke policy or procedure. Mölnlycke’s operations are certified according to applicable standards and maintains all necessary routines and procedures as required according to such certifications.
Further examples of such technical and organisational measures are:
Pseudonymisation.
All personal data processed by or on behalf of Mölnlycke is pseudonymised to the extent possible. This means that information that can directly identify an individual, such as name, is removed.
Encryption.
Personal data is protected in accordance with Mölnlycke’s routines on information classification. When necessary, the personal data is encrypted in transit, rest, and use.
Firewalls.
Robust firewalls are established to function as a barrier and protect Mölnlycke’s
digital assets and environment. Automated reminders and security checks. Mölnlycke’s digital systems provide automated reminders for e.g., retention periods.
Access control.
Role-based access control safeguards that personal data is only accessible by personnel who has a legitimate need to process such personal data.
Contractual obligations.
Any and all contracts entered into by or on behalf of Mölnlycke, which involves processing of personal data, contains obligations in relation to data protection.
Training/education.
All personnel are trained in how to handle personal data in compliance with the applicable data protection laws. Personnel working specifically with processing of sensitive personal data receives additional and targeted training.
Personnel privacy champions.
As aglobal world-leading MedTech company,Mölnlycke acknowledges the need ofestablishing employee privacychampions of the business, to be able toexcel the level of privacy complianceacross the different business areas andfunctions.
Confidentiality.
All employees, suppliers, partners, and other who can access or view personal data, or that processes personal data on Mölnlycke's behalf, are contractually bound by confidentiality. The obligation of confidentiality shall remain in force, even after termination of duties, for as long as necessary to comply with the law.
If you have questions regarding the content of this Privacy Commitment or Mölnlycke’s processingof personal data, please reach out to Mölnlycke’s Chief Privacy Officer at privacy@molnlycke.com.
For the position statement in printable PDF please press here.
We value and celebrate the diversity of our employees, recognising that it fuels creativity, fosters innovation, and enhances our problem-solving capabilities. Being diverse makes us better in understanding the needs of our customers, allowing us to provide them with best-in-class solutions.
We are committed to creating an inclusive environment where every employee can be their authentic self and feel a sense of belonging regardless of their cultural background, mindset, personal styles, previous experiences, age, gender, religion, language, ethnicity, disability, sexual orientation, education, occupation, socio-economic status or any other unique trait. We empower and support employee resource groups, where employees come together to support a cause through sharing their experiences, providing mentorship, and advocating for positive change.
We believe that all employees have the right to equitable compensation, benefits, and opportunities for development and advancement. To achieve this we ensure that our internal processes are fair and equitable through continuous analysis and feedback sharing.
This position statement sets out the scope and approach of Mölnlycke’s fair competition ambition, taking into account the nature of our industry and stakeholders as well as relevant legislation.
Mölnlycke is committed to conducting business in compliance with all applicable laws and legislations and with integrity and focus on business ethics. Competition law is an inherent part of an ethical business, as competition laws monitor the distribution of economic power, to allow undistorted competition and healthy economies to grow.
Mölnlycke believes that fair competition is one of the essential principles of a well-functioning market, which benefits the development, progress and well-being of society. Mölnlycke’s Code of Conduct reinforces this principle by stipulating that “Mölnlycke promotes and protects competition” and that Mölnlycke personnel “shall comply with all competition laws and demonstrate fair and correct behaviour in competition”. To further ensure fair competition we follow our guiding principles:
The guiding principles are applicable to all entities that are part of Mölnlycke and compliance with the guiding principles is mandatory for all Mölnlycke personnel and third parties working for Mölnlycke, at all levels throughout Mölnlycke, in all activities related to their positions and functions.
For the position statement in printable PDF please press here.
Creating solutions to help achieve optimal healthcare outcomes can require complex production processes and the handling of many different substances. Mölnlycke are committed to safe use of all substances at every stage of design production. We systematically identify, classify, and risk assess all substances to ensure that any potential hazards are identified. Once identified, any hazards are carefully controlled and mitigated.
A particular focus is placed on substances that may be hazardous. We have a commitment to minimise and replace them whenever possible. This process is embedded in rigorous review and rating systems, plus portfolio-level analysis and reporting, to ensure continual removal of these substances from the organisation’s value chain. An ongoing programme of research, development and supplier interaction continues into technologies to replace hazardous substances. When replacement is not possible, hazardous substances may only be used when safe use and adequate controls can be demonstrated. This protects our teams, stakeholders and the environment.
Careful handling of hazardous substances and preventing releases to the environment are requirements of the ISO 45001 standard for occupational health and safety management and ISO 14001 standard for environmental management respectively. Mölnlycke is globally certified to the ISO 45001 and 14001 standards, and is regularly audited by an accredited body to ensure conformance.
Mölnlycke is committed to conducting its activities in a responsible manner and with respect for the human rights across its operations.
Mölnlycke has been signatory to the UN Global Compact since 2017 and is committed to avoid causing or contributing to adverse impacts on people – whether in our own company, through our business partners, or in the communities where we operate.
When referring to human rights we take into consideration, at a minimum, the International Bill of Human Rights. It includes the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights, and the ILO Declaration on Fundamental Principles and Rights at Work. We endorse the principles of the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises, and implement our commitment to respect human rights via our Code of Conduct, and through the development and implementation of other internal procedures and processes.
The responsibility to implement our human rights commitments is anchored in our Business Ethics and Compliance team, under the Legal Department. It is further supported by the relevant functions People, Supply Chain, Operations, Sustainability and it is overseen by a Human Rights Committee with representatives from the ELT.
We work actively to ensure that our commitment to operating with respect for human rights is integrated into relevant policies, processes, and ways of working, as well as in interactions with our stakeholders.
We have included human rights questions in our due diligence procedures and we continuously consolidate our efforts to identify, assess, and take action on the human rights impacts of our business activities and relationships. We demand the same high standard and responsible behaviour from our business partners, suppliers as well as distributors, and integrate this in dedicated reference documents such as Supplier Code of Conduct and Distributor Code of Conduct.
Supplier Code of Conduct I Distributor Code of conduct
Mölnlycke has an available human right grievance mechanism through the use of its Ethics Hotline, which can be used by all to report concerns on any human rights issues related to Mölnlycke and its activities. In cases where we may be directly linked to adverse impacts, we commit to work with the other party involved to provide remedy.
For the position statement in printable PDF please press here.
The benefits of a Life Cycle Assesment are twofold:
When making sustainability claims through LCA comparisons of products and services, Mölnlycke adheres to the following principles:
In making sustainability claims, transparency and accuracy are paramount for Mölnlycke. To avoid the risks of "greenwashing" and potential harm to our reputation, it's crucial that our claims are substantiated by reliable data and adhere to pertinent guidelines and standards.
Individual product Life Cycle Assessments inform our work with a holistic sustainability assessment of our portfolio that we conduct in a systematic manner aligned with standardised methodology.
In order to deliver consistent long-term performance and strengthen our safety culture, Mölnlycke invest in visible safety leadership programmes, global employee training programmes and engagement initiatives, as well as maintain an integrated Environment, Health and Safety (EHS) management system.
Our corporate EHS management system drives continual improvement in all aspects of OH&S, including setting global standards, ensuring root cause analysis of all lost time incidents, high potential incidents and near misses, training, annual site improvement plans, and performing internal and external audits. Mölnlycke also incorporates learning across the organisation through monthly dedicated global EHS team meetings and best practice sharing. Our management system covers 90% of our manufacturing locations with the remainder planned to be certified in 2024, is certified to the ISO 45001 standard, and is regularly audited by an accredited body to ensure continued conformance.
Improving safety performance is based on having robust processes in place and being consistent in applying and improving these processes at all our locations. The core elements of our OH&S excellence programme focus on people safety, process safety, health and well-being, as well as people and physical security.
Security at Mölnlycke is focused on ensuring the safety of people, information, assets and critical business processes against wilful security risks both on site, and whilst travelling. The level of standardisation of procedures, processes and training for personnel dealing with security at all our locations will continue to increase.
We encourage and empower all of our employees to actively contribute to creating a positive OH&S culture. Health and safety committees, composed of managers, safety responsibles and works council or employee representatives, are established at all our manufacturing locations and headquarters. These enable inclusive consultation and participation on the topics of OH&S systems, evaluation and improvement. The committees follow local regulations regarding agenda and frequency of meetings.
We strongly encourage our employees to raise their concerns should they experience or suspect misconducts (breach of the law, of the Code of Conduct or of Mölnlycke policies and procedures). To do so, employees can use the Ethics Hotline (online and phone) which is supported by an external vendor. We have developed policies and procedures to ensure concerns raised by employees are investigated confidentially. Furthermore, Mölnlycke does not tolerate retaliation against employees raising their concerns in good faith, supporting or participating in investigations. We proactively seek to address risks of retaliation by reaching out to employees who are identified as potentially exposed; we integrate more awareness in training and communication to make sure employees can recognise retaliation and know how to react.
Our OH&S performance is continually tracked and reported on a monthly basis, with thorough checks to ensure data quality. Our main KPI for safety is the lost time injury rate1 for employees. We report incidents to local authorities in accordance with national legislation. Mölnlycke also believes that work-related ill health2 is an important aspect of OH&S; therefore cases are tracked and analysed, and targets are set to improve performance.
Mölnlycke's ambition to decouple material use from its growth goes beyond recycling. It all starts with limiting the need to recycle. Therefore, we focus on zero waste, working in accordance with the ‘right first time’ principle and repurposing and reclaiming materials.
We’re on a journey to become a zero waste company, which involves focusing on both waste and water. We have an ambitious target of zero waste to landfill by 2030 as well as reusing water at all our most water-intensive sites by 2030 and we implement closed water loop systems in our production environments to that end.
Our waste reduction management programme to achieve the targets is based on site-specific activities designed to avoid waste being created in the first place and then minimising waste to landfill by correct segregation and disposing of remaining waste. We also identify new outlets for materials that would otherwise have been disposed of. Our actions make an important contribution to the UN Sustainable Development Goal on Sustainable Consumption and Production (SDG 12). To find out more, please see our integrated Annual and Sustainability Report 2023.
Our medical solutions often contain plastic or are delivered in diverse plastic packaging, with unique intrinsic performance properties which extend the lifespan of our solutions and protect them from external factors such as damage during transport and handling, or deterioration caused by contamination. This reduces the need for additional raw materials and resources in our products and contributes to minimising our customers’ waste.
As part of our resource efficiency journey, we have an ambition to provide >95% recyclable packaging by 2030. Governments around the world are adopting legislation targeted at tackling, for example, plastic waste. By embracing the power of upstream innovation to achieve two key circular economy innovation strategies — elimination and material circulation — we stay ahead of the curve. We continuously work together with customers, suppliers, recyclers, universities, and other partners to develop innovative and circular packaging solutions that have lower holistic environmental footprints and enable our customers to be more sustainable and deliver on their sustainability ambitions. These include a growing share of lighter, recyclable, recycled, bio-based and biodegradable packaging solutions while guaranteeing best clinical outcomes.
We consider competition with the food chain when evaluating the use of bio-based renewable raw materials and always opt for ISCC certified biobased materials, guaranteeing a transparent traceability along our supply chains and meeting the environmental and social standards.
In addition, we take a proactive approach to identify, manage and remove hazardous substances in all our products and processes to ensure safe use, ahead of legislation, future-proofing our products against changes in regulations.
We substantiate our research and efforts into alternative feedstocks and circularity of our products or packaging by continually updating our product Life-Cycle Analyses.
We further increase the existing activities aimed at preventing littering, including educational projects for our customers and local communities in the countries in which we operate.
Mölnlycke is actively engaged in promoting a circular economy, incorporating circular practices throughout its entire value chain. Mölnlycke recognises the transformative possibilities across every facet of its business with a collaborative focus on providing its customers with the most sustainable solutions that help to both utilise resources responsibly, and to decarbonise healthcare.
An important step in this journey is assessing the impact of individual solutions through Life Cycle Assessment (LCA), and the wider solution portfolio. For the portfolio level, Mölnlycke adapted the standardised categorisation methodology, Sustainable Product Portfolio Assessment, from the portfolio framework tool developed by World Business Council for Sustainable Development (WBCSD) as fit for purpose for a MedTech company.
The company’s portfolio approach promotes the use of safer and more sustainable products in all stages of the value chain. Mölnlycke’s responsibility stretches to the whole life cycle, from sourcing, transportation, manufacturing through to customer use and end of life. The company assesses the sustainability performance of all products and builds sustainability thinking into its innovation process through sustainable design insights and eco-design tools.
Mölnlycke segments its product portfolio into the following three categories to reflect the sustainability risks and opportunities.
Information from the portfolio analysis is used to support product portfolio planning through the company’s marketing and innovation processes. It also helps the company to engage with customers with a focus on sustainability.