Transparent and responsible communication

Impact, risk, and opportunity management

We address our health and nutrition impacts, risks, and opportunities through our Responsible Marketing Policy and by taking actions to achieve the commitment in our Sustainability Plan.

Our material impacts, risks, and opportunities

According to our Double Materiality Assessment (DMA), “Consumer health and nutrition” is a material topic. We have identified material impacts and risks in our downstream value chain in relation to this topic.

Lindt & Sprüngli can impact consumer behavior by creating awareness of the nutritional content of our chocolate products and avoiding misleading marketing communication. Responsible marketing communication and transparent nutritional labeling can assist consumers in making appropriate choices about our products. We pay particular attention to restricting accessibility and content of marketing communication to children. These principles are embedded in our Responsible Marketing Policy (see Our related policies and documents within this chapter).

Non-compliance with our Responsible Marketing Policy presents a reputational and financial risk, as does non-compliance with local legislation on foods high in fat, salt, and sugar (HFSS).

Global concerns over health have initiated a rise in legislation aimed at restricting consumption of HFSS foods. These laws often concern advertising restrictions, in-store location restrictions, and product labeling. We aim to deliver on our growth ambitions, whilst ensuring compliance with such legislation.

Our related policies and documents

Our global requirements are defined in the Lindt & Sprüngli Responsible Marketing Policy. This outlines our principles and standards and was updated in 2023. Its scope covers our commitment to being transparent, non-exploitative, and not encouraging irresponsible behaviors through activity in three areas:

• Avoiding advertising to children
• Encouraging responsible consumption
• Providing transparent nutritional information

Our Global Head of Marketing is accountable for the implementation of the Responsible Marketing Policy. Employees involved in external marketing communication and product labeling receive specific training related to the Responsible Marketing Policy at least once a year, and whenever the Policy is updated.

Compliance with legislation

While we adhere to national and international legislation applying to our areas of activity, our policies often extend beyond what is legally required and hold us accountable for how we market our products. If applicable laws set stricter requirements than our Responsible Marketing Policy or signed industry pledges, they are adopted.

We have introduced a global initiative for the Group to consider our future strategy for consumer health and nutrition, while complying with increased legislation aimed at restricting consumption of HFSS foods. The strategy aims to cover various elements, such as availability in stores and marketing activities.

Our subsidiaries are responsible for ensuring compliance with local HFSS legislation and taking action accordingly.

Responsible marketing

Our responsible marketing approach applies to all marketing communication channels, including television, radio, print, cinema, online (including company-owned websites and company-owned social media profiles), direct marketing, product placement, interactive games, outdoor marketing, DVDs/movies, as well as mobile and SMS marketing.

Avoiding advertising to children

We commit to avoiding advertising our products directly to children in the absence of parental or other adult supervision. We commit not to advertise our products in media where at least 30% of the audience is made up of children under 16 and not to engage in any communication related to our products in primary or secondary schools.

Lindt & Sprüngli participates in industry activities aimed at strengthening responsible advertising to consumers. Examples are those carried out by the EU Pledge, a voluntary initiative by leading food and beverage companies at a European level and, as of 2023, activities of the BBB National Programs’ Children’s Food and Beverage Advertising Initiative (CFBAI) in the United States. Under both of these industry pledges, Lindt & Sprüngli is one of 23 companies that commits not to advertise to children under 13. We also abide by the International Chamber of Commerce (ICC) Code of Advertising and Marketing Communication Practice and the ICC Framework for Responsible Food and Beverage Marketing Communications in our marketing communication.

Encouraging responsible consumption

Our policy prohibits encouraging or showing excessive consumption in our advertising. For example, the portions shown shall not exceed recommended sizes, nor should there be any portrayal of inappropriate consumption of our products.

Providing nutritional transparency

Providing transparent product information, including nutritional information, for online and offline sales purposes is increasingly important. We monitor regulatory developments regarding the labeling of products and trends in consumer information.

We are committed to displaying clear and easily understandable nutritional information and calorie guidelines and to continuously seeking to simplify our ingredient lists. For products that have a risk of containing common allergens, we make sure that these are highlighted in the ingredients with bold type and add a clear warning about any traces of specific allergens the products may contain.

For consumers, we provide easy access to information on our products through our website, social media channels, packaging, FAQs on our website, and consumer service.

Metrics and targets

Ensuring adherence to our responsible marketing commitment

We measure both adherence to industry pledges through the EU Pledge and CFBAI pledge, as this is the most comprehensive audit data available. Through the EU Pledge initiative, our television and digital marketing programs must undergo an annual third-party compliance audit in selected European markets. This is conducted by Ebiquity and the European Advertising Standards Alliance (EASA). In 2024, the EU Pledge third-party television audit was conducted in France, Germany, Italy, the Netherlands, Romania, and Spain. The digital EU Pledge monitoring was carried out in France, Germany, Italy, the Netherlands, Hungary, and Spain. As part of the CFBAI pledge, our television communication in the US is also audited annually. The television audit is conducted by BBB National Programs using data from third-party provider Nielsen.

Additionally, we undertake a specific Lindt & Sprüngli under 16-years audit for TV advertising to measure our own Responsible Marketing pledge on advertising. These audits are also conducted by the third-party provider Ebiquity in the same EU Pledge countries and a rotating non-EU three country audit to ensure a wide coverage of our leading advertising countries. In 2024, those countries were the UK, Canada, and South Africa.

In 2024, Lindt & Sprüngli achieved 99.2% in the under-16 television audit in EU countries and 97.9% in the under-16 audit in non-EU countries.

We achieved 99.4% compliance with the EU Pledge commitments regarding television advertising overall and 100.0% compliance for daytime television advertising. Digital media audit tracking indicated that our brand-owned websites, social media profiles, and influencer profiles were 93.8% compliant, with one non-compliant influencer post being addressed. The US CFBAI TV compliance monitoring for 2024 found 99.6% overall compliance for Lindt & Sprüngli. Additionally, in 2024 no deviations or incidents were reported in any other countries regarding advertising to children, nor any non-compliance with national or international laws concerning marketing communication.

Compliance concerning nutritional transparency and regulatory compliance

In 2024, there were four incidents of non-compliance with regulations related to product information and labeling and zero incidents of non-compliance with regulations or voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship.

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