Business integrity

Consumers, business partners, and employees are attaching increasing importance to business ethics and integrity. Our commitment to fairness, and respect for everyone, is reflected in our purpose and values, our Business Code of Conduct, and additional Group-wide policies such as our Group Compliance Policy. We also expect any third parties with whom we work to apply equivalent measures.

Our comprehensive prioritization of business integrity forms the core of the Lindt & Sprüngli Sustainability Plan. It is implemented in our supply chain through the Supplier Code of Conduct, our working practices, as well as our endeavors to ensure the quality and safety of our products. Mandatory onboarding for our business partners, and ongoing due diligence throughout our business relations with them, serve to monitor their compliance with applicable laws, regulations and global standards. The due diligence process includes specific checks on compliance subject matters, together with the standard assessments supported by EcoVadis for our suppliers.

“Business integrity is an integral part of how we do business. Our employees are committed to fostering a working environment which promotes ethical practice. They are supported by the global Lindt & Sprüngli Compliance Organization, which continues to strengthen the Lindt & Sprüngli compliance management system in line with applicable laws, regulations, and best practice standards. Our employees play a pivotal role in supporting Lindt & Sprüngli’s compliance strategy.”

In 2022, Group Compliance performed a detailed review and update of our compliance strategy, incorporating the development of a roadmap of the compliance programs and operating model, which also extended into 2023. Group Compliance and those responsible for compliance locally in the Lindt & Sprüngli subsidiaries, as well as key stakeholders at Group level, will support the roadmap execution up to and including 2025.

Group Compliance continued to develop and roll out Group-wide compliance policies in 2023. This included review and continued development of our Compliance operating model in line with best practice standards. In 2023, we additionally focused on reviewing and further enhancing our anti-bribery and corruption compliance program, including our policies and procedures. In 2024, we will continue the focus on advancement of our global programs, including data privacy and anti-trust. Further, we will strengthen our third party risk management and trade sanction program and continue the effectiveness assessment of our Speak Up Line. In 2024, we will continue to develop our Compliance operating model through the use of technology including e-learnings.

Setting our expectations

All new employees are provided with the Lindt & Sprüngli Business Code of Conduct as part of their onboarding. They are required to acknowledge receipt and acceptance of this Code in paper form, or online via the company’s internal learning platforms. It is available to all employees on our intranet at all times. We measure the acceptance of the terms via our Global Employee Engagement Survey conducted every three years (2022: 77/100 “In my work environment, the regulations of the Business Code of Conduct are followed”). Failure to comply with the Business Code of Conduct may result in disciplinary action. 

At regular intervals we conduct mandatory awareness-raising and training courses for a defined group of employees, according to the risk area and relevance to the function or functional level. These support the implementation of our policies and connected procedures, and contribute to ensuring that everyone at Lindt & Sprüngli follows our core values and complies with our regulations and guidelines.

The Lindt & Sprüngli Supplier Code of Conduct and Compliance Declaration is distributed to our suppliers at onboarding and requires adherence to social and environmental standards by our partners throughout our supply chain. In the case of revisions, our partners are requested to re-confirm their adherence. We expect our key suppliers to encourage their employees to report concerns of unlawful activities in their own business areas and supply chains without the fear of retaliation. Further information can be found in our Responsible sourcing chapter.

Compliance Organization

Our Board of Directors oversees and promotes compliance practices throughout the company in line with the Business Code of Conduct. Our compliance strategy brings together policies, guidelines, trainings, information and awareness, collectively known as our compliance program. Lindt & Sprüngli employees are guided and led by our Compliance Organization, receiving additional support from other functions engaged in our program.

The Compliance Organization is responsible for driving the compliance programs and the Compliance operating model in accordance with best practice. Our programs include the development of compliance subject-matter policies and trainings, which are rolled out with the support of the responsible people at Group and local level. 

Our Compliance operating model integrates the three main pillars of risk management to include prevention, detection and response mechanisms. Prevention is supported by established policies, procedures and trainings. Detection is supported by our global Speak Up Line and if any suspected or known wrongdoing is identified, remedial action is taken.

As defined in our Group Compliance Policy our Compliance Organization reports periodically to the Board of Directors and Group Management.  

Legal and regulatory requirements are assessed with relevant stakeholders and implemented accordingly. Key changes in the reporting year with regard to regulatory requirements include the German Supply Chain (Due Diligence) Act. This has resulted in the assessment of, and updates relating to, additional demands placed on suppliers to obtain their confirmation of meeting the legal requirements concerning environment, social responsibilities and governance due diligence, as well as confirmation of their grievance mechanism setup.

In the reporting year we had one significant case of non-compliance with laws and regulations related to a temporary permit violation.

We monitor and implement compliance through our corporate functions. Furthermore, our Lindt & Sprüngli internal control system supports compliance. For the corporate governance of the Lindt & Sprüngli Group see our Corporate Governance Report (Annual Report 2023); for the overall Sustainability Governance see the Sustainability governance structure chapter of this report.

Respect for fair competition

Our employees and business partners are expected to commit to not participating in any corrupt or anti-competitive behavior. Lindt & Sprüngli adheres to the principle of free competition, and we comply with all applicable domestic and international legal requirements to facilitate this. The internal Lindt & Sprüngli Competition Law Policy outlines the provisions employees are expected to observe.

We have reviewed and enhanced a global Anti-Bribery & Corruption Program that includes combined classroom training and e-learning. Most of our governance body members and all of our highest governance body members, as well as relevant employees in key functions and functional levels have completed the training on anti-corruption. This promotes awareness of topics such as conflicts of interest, gifts, entertainment and hospitality. We have established an approval system for gifts, entertainment, and hospitality, managed by the Group and by the local compliance officers. The Program is aligned with applicable laws and global standards. Furthermore, the revised Competition Law Program started to be rolled out in 2023, incorporating awareness communication and training for our key internal stakeholders.

During the reporting period, there were no confirmed instances of corruption or anti-competitive behavior. At regular intervals we conduct mandatory awareness-raising and training courses to support the implementation of our policies. These courses help ensure that everyone at Lindt & Sprüngli, including all members of management, supervisors, and employees, adheres to our core values and complies with our regulations and guidelines.

Speak Up – our grievance mechanism

In October 2021, we established an independent and secure global Speak Up Line to encourage employees and third parties to raise any concerns they might have about suspected misconduct, without fear of retaliation. This is a channel for people to safely state and address their concerns about any suspected misconduct within Lindt & Sprüngli operations, and specifically any violation of the Business Code of Conduct, Supplier Code of Conduct, laws, or policies under which we operate.

Our Speak Up Line is open to individuals, community representatives, and organizations, including potentially or currently affected stakeholders. This embraces, but is not limited to, employees and workers at Lindt & Sprüngli companies, our suppliers and business partners, and community members. It is communicated to our employees through our intranet, the Business Code of Conduct, and other communication channels such as posters, e-mails, and town hall meetings, to our suppliers in our Supplier Code of Conduct, and to the public via our corporate and country level websites. Concerns can be addressed in the reporter’s native language and anonymously if country regulations permit. Dedicated, impartial case managers investigate cases reported through the Speak Up Line on the basis of the Lindt & Sprüngli investigation manual and remediation guidelines. 

We continue to improve the Speak Up Line to comply with global standards and legal requirements. Additionally, we have updated our governance documentation, including our Speak Up Policy and internal remediation plan.

Substantiated concerns help us to become aware of and address issues such as breaches of our Code of Conduct, discrimination, and harassment. Our policy is to investigate all genuine concerns, however they are raised or identified, including minor ones. Confirmed concerns are then remediated in accordance with the law.

We continuously review and assess the case categories received and what measures or actions, in addition to the remediation taken related to the specific case, are required. We also review whether reported cases are within the intended scope of the Speak Up Line to determine if further purpose and scope communications are necessary.