Focus area
Mölnlycke expects all its employees to live up to its commitment to complying with applicable laws, regulations and industry codes that are relevant to conducting business ethically. We continuously improve our compliance framework supported by an embedded integrity mindset throughout the organisation.

We set high standards of ethics and responsibility in our business.
We act with integrity and care for human rights1 throughout our value chain.
Our goals
- 100% of employees to receive annual training or awareness session within Ethics and Compliance by 2023.
- 100% of employees feel safe to report concerns without fear of retaliation by 2025.
- 100% of active distributors assessed through the distributor due diligence process by 2025.
For details please see our Annual Report for 2022.
Current progress
white collar employees trained in
Mölnlcyke's Code of Conduct
Building an integrity mindset
Having an integrity mindset means going beyond compliance and considering the impact of our decisions and actions on stakeholders. It also means raising employees’ awareness level within this area, training them in ethical dilemmas and ensuring that they are comfortable and empowered to handle them.
The Code of Conduct commits us to comply with laws and regulations and to be an ethical company in the broader frame of international commitments such as the Sustainable Development Goals (SDGs). The Code of Conduct provides all employees with guidance and is regularly updated.
Our approach starts with empowering our employees to raise concerns and report misconduct. The 2022 culture survey showed that 75% of employees felt safe to raise their concerns without the fear of negative consequences. We regularly raise awareness of risks and challenges through communication and training activities, including the annual Code of Conduct training for our white-collar employees.
Ad hoc training and presentations on topics, such as general business ethics, healthcare compliance, competition law and receiving concerns, are delivered throughout the year to various employee groups based on their needs and demands. Our ambition is to expand the business ethics training program to include more topics and increase the number of in-person sessions to maximise its impact. This will include a dedicated program on the Code of Conduct for all leadership teams and for the manufacturing workforce.
Our employees can voice their ethical concerns or seek advice through the Business Ethics Compliance function or by using the company’s whistleblowing tool, the Ethics Hotline. All concerns are investigated by dedicated personnel. In 2022, the majority of the cases (55%) were related to employee relations. After thorough investigations, only 35% of cases were substantiated while another 21% led to process improvement or other change. We have revised our procedures in this area in line with the EU directive on the protection of whistle-blowers and will launch a dedicated campaign to raise awareness throughout the organisation in 2023.
RESPECTING HUMAN RIGHTS
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.
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.
FAIR COMPETITION
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:
1. We do not discuss commercially sensitive information
We do not discuss commercially sensitive information, market sharing or market allocation with our competitors. We are aware that sharing, receiving, or exchanging this type of information could be prohibited even when it is informal, such as in conversation with a former colleague or friend, or when it takes place during industry association meetings.
2. We respect fairness
Vertical agreements affect business partners that are not acting at the same level of the value chain, such as a Mölnlycke relationship with a distributor or a supplier. We respect fairness and it is important to us to not exert undue influence over our distributors. For example, in the EU, we do not prevent passive sales (i.e., sales made in response to unsolicited orders) or impose resale prices on distributors.
3. We follow best practice in tender processes
In tender processes, transparency must be maintained throughout the procurement cycle by adhering to all applicable procedures. It is therefore important that decision makers are provided with correct and transparent data. We do not exert any improper influence on the content of the tender documents, nor do we have undue contacts with decision makers in tender processes.
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.

Mölnlycke ethics hotline
The Ethics Hotline enables internal and external stakeholders to report concerns and grievances or any other suspected violations of laws, policies and procedures or inappropriate behaviour. Topics of reports can include issues such as, but not limited to, fraud, corruption, working environment issues and discrimination.

Training to support ethical growth in India
Mölnlycke carries out a screening and due diligence process before entering business relationships with distributors. We also offer training for distributors to give them an understanding of the ethical standards expected from them. As we expand our distribution network in this region of the world, we launched training for its sales teams on compliance rules, ethical decision making, engagement with healthcare professionals and interactions with distributors.
Then key Indian distributors were also invited for dedicated sessions to ensure mutual understanding of the risks linked to the medical technology sector. The sessions covered topics such as ethical decision making, corruption and bribery risks, engaging with government officials and the overall Mölnlycke due diligence process. It was an occasion to explain to distributors what they can expect from our new due diligence process and discuss any questions they may have.

Due to our global footprint, we can have a major direct and indirect impact, both positive and negative, on human rights in our own operations, as well as across our value chain – for example in the way we treat our own employees or how suppliers comply with labour rights. Therefore, we continuously identify, assess and address potential and actual adverse human rights impacts, taking into account their severity and probability.
Read moreRELEVANT SUSTAINABLE DEVELOPMENT GOALS
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