Upholding business ethics and integrity

Governance related to business ethics and integrity

Our compliance strategy brings together policies, guidelines, trainings, information, and awareness in the areas of anti-corruption and anti-bribery, antitrust, data privacy, and trade compliance – collectively known as our Compliance Programs and the Compliance Operating Model. Our Compliance Operating Model integrates the three main pillars of risk management: prevention, detection, and remediation mechanisms. Established policies, procedures and trainings, as well as detection through our global Speak Up Line, support prevention. If any suspected or known wrongdoing is identified, we take remedial action.

The Compliance Organization is responsible for driving the Compliance Programs and the Compliance Operating Model in line with best practice. Our programs are rolled out by the persons responsible for compliance at Group and local level. 

As defined in our internal Group Compliance Policy, our Compliance Organization reports periodically, but not less than twice a year, to the Board of Directors. Reporting to the Group Management members is provided three times a year. Our Board of Directors oversees and promotes compliance practices throughout the Group in line with the Business Code of Conduct. We aim to ensure that the members of Board of Directors, as well as the candidates for membership, are appropriately composed and possess the necessary qualifications and experience to discharge their duties. Based on a proposal by the Compensation & Nomination Committee, the Board of Directors has determined a set of competencies and expertise that it deems relevant for the company, its business activities, geographic presence, and future development, and which should, therefore, be adequately represented on the Board of Directors. This includes competencies and expertise on legal, regulatory, and compliance matters. An overview summarizing the respective competencies and expertise of the current members of the Board of Directors can be found in the Board of Directors section of the Corporate Governance Report (Annual Report 2024).

For the disclosures around the topic of conflicts of interest, see the Committees of the Board of Directors section of the Annual Report 2024. For the corporate governance of the Lindt & Sprüngli Group, see our Corporate Governance Report (Annual Report 2024); for the overall Sustainability Governance, see the Sustainability governance structure section in the Governance chapter of this report.

Impact, risk, and opportunity management

We address our business ethics and integrity impacts, risks, and opportunities through our policies, grievance mechanism, and measures to foster business conduct in an ethical, legal, and environmentally and socially responsible manner.

Our material impacts, risks, and opportunities

According to our Double Materiality Assessment (DMA), “Business ethics and integrity” was identified as a material topic. We have identified material impacts, risks, and opportunities in our own operations and the upstream and downstream value chain in relation to this topic.

As far as impact is concerned, consumers, business partners, and employees are attaching increasing importance to business ethics and integrity. Relevant risks are reputational and financial risks associated with non-compliance, regulator investigations and/or fines, litigation, including class actions, and business interruption. Opportunities in this area are the prevention and detection of corruption and bribery in the value chain due to effective governance and risk management, as well as employees’ and business partners’ adherence to principles of fair competition through the implementation of our Group-wide Compliance Programs.

Our related policies and documents

Business Code of Conduct

The Lindt & Sprüngli Business Code of Conduct affirms our standards for non-discrimination and ethical behavior for all employees. It also makes reference to our commitment to respect human rights and to our Speak Up Line which is an important channel for addressing any Business Code of Conduct violations or concerns.

The Lindt & Sprüngli Business Code of Conduct applies to the whole Lindt & Sprüngli Group. The CEOs of the companies of the Lindt & Sprüngli Group are responsible for ensuring that all employees are informed and educated about the Business Code of Conduct, and they are expected to enforce strict adherence to the rules and regulations of the Code. All new employees are provided with the Lindt & Sprüngli Business Code of Conduct as part of their onboarding. We require them to acknowledge receipt and acceptance of the Business Code of Conduct in paper form, or online via the Group’s internal learning platforms. The Business Code of Conduct is available to all employees on our intranet at all times. We measure the acceptance of the terms via our Global Employee Engagement Survey (last survey carried out in 2022: 77/100 respondents confirmed “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.

Supplier Code of Conduct

Our Supplier Code of Conduct requires our priority suppliers throughout the supply chain to adhere to our social, environmental, ethical, legal, and integrity standards. It sets out what we expect of suppliers with regard to compliance with laws and regulations, anti-corruption and bribery, social and working conditions, and protection of the environment. For more information on the Supplier Code of Conduct, see Our related policies and documents in the Responsible sourcing chapter.

Speak Up Policy

The Speak Up Policy establishes how an employee¹, any third party², or a relative, dependent, or spouse of an employee or third party can safely express  concerns about suspected misconduct at Lindt & Sprüngli through our Speak Up Line, specifically any violation of the Business Code of Conduct, Supplier Code of Conduct, and laws or policies under which Lindt & Sprüngli operates, without fear of retaliation. A non-exhaustive list of areas of reportable misconducts can be found in the Policy. It also explains who to contact, what to report, and how to do so, as well as the protection available to the person submitting the report. It further describes what the person submitting the report can expect from Lindt & Sprüngli if a report is submitted, and how that person’s personal data is protected.

The Speak Up Line is not an emergency service and suspected misconducts generally do not include personal work-related grievances. Concerns related to the employment should be raised with the local HR representative to allow them to be resolved most effectively. Serious work-related grievances that constitute victimization are protected disclosures. Further, this channel is not intended for consumer complaints or concerns, which are handled separately.

Dedicated impartial case managers support investigations in line with our internal investigation manual and remediation guideline. The case managers are trained regularly by Group Compliance, which is responsible for the development, implementation, and control of the Lindt & Sprüngli Compliance Programs, including the Speak Up Policy, at Group level while the programs are rolled out by the people responsible for compliance locally. The Policy 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. Our suppliers receive this information through our Supplier Code of Conduct and the public via our corporate and country-level websites. Impacts, risks, and opportunities are monitored through continuous assessments of case types, case handling, and case remediation. This supports the identification of areas for improvement and maintains awareness. Internal stakeholders were, and are, consulted as part of the formulation and revision of the Speak Up Policy.

Anti-Bribery & Corruption Policy

We do not tolerate any form of corruption or bribery as it undermines the rule of law and weakens the wellbeing of society. Our internal Anti-Bribery & Corruption Policy establishes Lindt & Sprüngli’s commitment and procedures to be followed by all employees and business partners in this context. For more information also, see Prevention and detection of corruption and bribery below.

Policy implementation and corporate culture

The Lindt & Sprüngli Group, and any legal entity belonging to the Group, commit to conducting business with fairness and integrity, respecting the laws and our values as reflected in our compliance strategy and implemented through our policies and other measures.

Compliance Programs and Operating Model

Group Compliance and those responsible for compliance locally in the Lindt & Sprüngli subsidiaries, as well as key stakeholders at Group level, support the execution of the roadmap of the Compliance Programs and Compliance Operating Model. The Compliance Operating Model was incorporated in 2022 and will be applicable up to and including 2025. Thereafter, the new Compliance Strategy post-2025 will be rolled out.

Group Compliance continued to develop and roll out Group-wide compliance policies in 2024, and also reviewed and further developed our Compliance Operating Model in line with best practice standards. In 2024, we additionally focused on continuing the global roll-out of our enhanced Anti-Bribery and Corruption Program, including continued awareness trainings globally, and monitoring of implementation of the processes defined in the program. Further, we worked on the advancement and roll-out of additional global Compliance Programs, covering antitrust, data privacy, and trade sanctions, and including the development of supplier screening technology. We also continued the effectiveness assessment of our Speak Up Line.

At regular intervals we conduct mandatory awareness-raising and training programs to support the implementation of our policies. Training programs are defined to focus on key functions to help ensure that everyone at Lindt & Sprüngli, including members of management, supervisors, and employees, adheres to our core values and complies with our global standards, policies, and applicable laws and regulations.

We monitor and implement compliance through our Compliance Organization at Group level. The Compliance Programs are executed locally through the people responsible at local level, and for anti-corruption and bribery, specifically, the designated functions-at-risk receive trainings (see Metrics table Anti-corruption and anti-bribery training). Furthermore, our Lindt & Sprüngli internal audit system supports the Compliance Organization through internal audits.

Speak Up Line – our grievance mechanism

In October 2021, we established the Speak Up Line as an independent and data-protected channel to confidentially raise any concerns about suspected misconduct within Lindt & Sprüngli operations. For more details on the scope of reportable concerns, see Our related policies and documents within this chapter.

Our Speak Up Line is open to individuals, community representatives, and organizations, including potentially or currently affected stakeholders. It allows employees and third parties to report an incident anonymously by calling a toll-free number or submitting a written report online. Concerns can be addressed in the reporting person’s native language and anonymously, if country regulations permit. Once a concern is raised, it will be assessed in an initial review and investigated by the appropriate investigators. Updates regarding the concern are communicated through a Grievance ID. A decision will be communicated within a reasonable timeframe and appropriate action and sanctions implemented.

Lindt & Sprüngli does not tolerate any form of retaliation taken against the reporting person, facilitators, witnesses, or third parties connected with the reporting person³. Retaliation is treated as a violation of the Business Code of Conduct or the Supplier Code of Conduct and consequently may lead to disciplinary measures. Retaliation can include – but is not limited to – dismissal of an employee or alteration of an employee’s position or duties to their disadvantage, negative performance feedback not reflective of actual performance, other disciplinary action, harassment, intimidation or bullying, threats to cause detriment, and contractual or other measures against the reporting person. Lindt & Sprüngli takes all allegations of retaliation very seriously. If reporting persons believe they are experiencing retaliation, they should report this.

We are continuously improving the Speak Up Line to comply with global standards and legal requirements.

Prevention and detection of corruption and bribery

Our employees and business partners are expected not to participate in any corruption or bribery. The internal Lindt & Sprüngli Anti-Bribery & Corruption Policy outlines the provisions employees are expected to observe and is available for all our employees through our intranet. In addition, we continuously monitor the implementation of our anti-bribery and corruption procedures, including our gift approval system, and review the conflict of interest registers.

We have reviewed and enhanced a global Anti-Bribery and Corruption Program, which includes combined classroom training and e-learning. All of our Group Management and Board members, as well as most of our governance body members on subsidiary level and relevant employees in key functions and at key functional levels, have completed the in-person trainings on anti-corruption and anti-bribery (see Metrics table Anti-corruption and anti-bribery training). 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 those responsible for compliance locally. The system is aligned with applicable laws and guided by the relevant standards set out in the United Nations Convention Against Corruption, the OECD Anti-Bribery Convention, and the United Nations Global Compact (UNGC).

The Lindt & Sprüngli Compliance Organization is responsible for guiding the Group’s anti-corruption and anti-bribery strategy implementation, which is executed at local level, and for supporting the business’ efforts to embed this into our business operations as well as those of our business partners. The Global Compliance Organization meets to exchange on the program roll-out and to support Group Compliance reporting to Group Management and the Board of Directors Directors on a regular basis (see Governance related to business ethics and integrity in this chapter). Group Compliance reports to the Board of Directors and Group Management members on current compliance matters on an ad hoc basis where appropriate. As defined in the Group Compliance Policy, the persons involved in any investigations relating to corruption and bribery incidents shall be determined according to the investigation circumstances. As a standard, it will include Group Compliance.

Metrics and targets

Instances of non-compliance

In the reporting year, we had three significant cases of non-compliance with laws and regulations: two cases in the US related to local health and safety requirements, and one case in Australia related to a weight discrepancy in Pick & Mix chocolates.

At Lindt & Sprüngli, significant instances of non-compliance encompass instances with and without monetary loss. Examples of incidents involving non-monetary loss which Lindt & Sprüngli considers significant are violations of penal codes and severe compliance violations, e.g., violations of antitrust and anti-corruption laws, data privacy laws, local health and safety regulations, and human rights violations.

Legal and regulatory requirements are assessed with relevant stakeholders and implemented accordingly. Key changes in the reporting year with regard to regulatory requirements included the partial transposition of the EU Corporate Sustainability Reporting Directive, the entry into force of the EU Corporate Sustainability Due Diligence Directive, the EU Empowering Consumers Directive, the EU Forced Labor Regulation, and the preparation for the EU Deforestation Regulation. 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 environmental and social responsibilities, as well as encouragement and confirmation that suppliers will report concerns of unlawful activities to Lindt & Sprüngli.

Instances of corruption, bribery, or anti-competitive behavior

During the reporting period, there were no confirmed instances of corruption or bribery or anti-competitive behavior.

Concerns raised through the Speak Up Line and incidents in 2024

Substantiated concerns help us to become aware of and address issues such as breaches of our Business Code of Conduct, discrimination, and harassment. Our policy is to investigate all genuine concerns, irrespective of how they are raised or identified, including minor ones. Confirmed concerns are then remediated through appropriate measures.

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 check whether reported cases are within the intended scope of the Speak Up Line to determine if further purpose and scope communications are necessary.

¹The term “employee” includes employees, workers hired through temporary or staffing agencies, home-workers, members of the management and supervisory body, volunteers and trainees of any legal entity belonging to the Lindt & Sprüngli Group.

²Third parties can include suppliers, contractors, or subcontractors and shareholders, as well as persons working under their supervision.

³This includes colleagues or relatives of the reporting person, and legal entities that the reporting person owns, works for, or is otherwise connected with in a work-related context.

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