Business Ethics

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Reporting period

The Sustainability section includes information from the combined entity for 12 months (DSM and Firmenich are reported as of 1 January 2023). The sustainability data in this Report cover all entities that belong to the scope of the Consolidated financial statements. If this is not the case this is mentioned specifically. As this is the first year of reporting for dsm-firmenich, no comparative data is available for 2022. For more information, see Sustainability statements.

We do business honestly, transparently, and ethically. To live up to this promise and to drive compliance with all applicable laws and regulations wherever we operate in the world, we have installed a Business Ethics team. This team is responsible for the design and implementation of a global Business Ethics Program that goes beyond a check-the-box compliance and provides support to management and employees.

At the start of our new company, the dsm-firmenich Code of Business Ethics and the dsm-firmenich Supplier Code were launched. During 2023, the existing legacy policies and procedures in the area of Business Ethics that are in line with the new foundational Codes remained in force. Common Group policies and standards will be introduced in 2024.

Code of Business Ethics

Our Code of Business Ethics comprises our values and our commitments to each other, our communities, and our planet. It is a reference document as well as a day-to-day manual to guide our people on how we do business (and how we do not). This is elaborated in our business principles, which clarify key issues, help us do the right thing, and underline how we expect everyone at dsm-firmenich to act with integrity in their daily work. Our Code is universal. It applies to everyone in our company and everywhere: at our offices, sites, warehouses, and when engaged in any company business. In 2023, we launched a campaign to request and require all dsm-firmenich employees to read and acknowledge our Code of Business Ethics.

Jane Sinclair, Chief Legal, Risk & Compliance Officer

We’re all responsible for setting the highest standards of honesty, fairness, and integrity. Together, we can make integrity key to how we bring progress to life.

Jane Sinclair Chief Legal, Risk & Compliance Officer

Group Policy Framework

For the implementation of our business principles more detailed explanations are provided by the documents of our Group Policy Framework. The Group Policy Framework is also used to foster efficient and effective business processes, and to mitigate risks.

Position Statements clarify the company’s positioning on ethical topics related to specific areas of our business for our external stakeholders and can be found on our website.

Group Policies explain the why, the high-level management intent, the key elements of the governance structure, and define the requirements for employees of our Business Units and Business Partner functions.

Group Standards provide further detailed instructions on how to comply with the requirements of the Group Policies in a harmonized way. Group Policies and Standards are usually only published internally.

Group Policy Framework (graphic)

Supplier Code

As a trusted partner to our business stakeholders, we strive always to operate to the highest standards. We only want to engage with others who commit to operate according to the same standards, with the objective of achieving an ethical, traceable, and sustainable value chain. These standards are captured in the principles set forth in our Supplier Code. All suppliers are expected to follow the dsm-firmenich Supplier Code and all relevant laws and regulations. We confirm the adherence to the principles of our Supplier Code via Supplier Self-Assessment Questionnaires and on-site or desktop audits. A breach of this Code could lead to the discontinuation of the collaboration with dsm-firmenich and to possible legal sanctions and proceedings.

Likewise, to ensure ethical business conduct of agents and distributors when acting on our behalf or dealing with dsm-firmenich products further down the value chain, dsm-firmenich expects them to work according to the highest ethical principles and comply with all relevant laws and regulations, in particular those related to fighting bribery and corruption.

Identifying and managing bribery & corruption risks

Bribery and corruption are both illegal and unethical: they have a negative impact on individuals, businesses, and wider society. Therefore, we do not tolerate bribery or any form of corruption.

Our Code of Business Ethics and Supplier Code help employees and supply chain partners to understand the values and principles that are relevant to their work at and with dsm-firmenich. Any act or omission on the part of an employee or supply chain partner that is in contradiction with the Codes shall be regarded as a potential breach and may lead to disciplinary action up to and including termination of employment, or termination of the business relationship, respectively.

The dsm-firmenich Code of Business Ethics and Supplier Code are complemented by the legacy policies and procedures to fight corruption, which explain the behaviors that are prohibited, the situations that should alert employees and supply chain partners, what the good practices are, as well as additional compliance requirements depending on the type of third party. In 2024, a new anti-bribery and corruption Group policy and new Group standards will be launched to replace legacy policies and procedures.

As part of the Business Ethics Program, ethics and compliance-related risks are periodically evaluated, particularly with a view to anti-corruption and bribery. Moreover, dsm-firmenich has a strong culture of risk management, internal control, and audit.

Awareness of bribery and corruption is also ensured by mandatory trainings. Course completions are monitored and management is informed as to completion rates. A process is in place to deal with uncompleted training cases. A unified common training related to combat bribery and corruption is to be developed.

Finally, there are grievance mechanisms to report any misconduct related to a potential or actual violation of dsm-firmenich’s Code of Business Ethics, Supplier Code and applicable policies and standards.

Speaking up

At dsm-firmenich, we all have a responsibility to speak up if we have a concern regarding compliance with our Code of Business Ethics. In the event people are not sure about a particular matter or have witnessed behavior that could be seen to be at odds with our values or business principles, it is vital to report it.

We encourage open and honest communication, and therefore, where possible, we recommend that employees address their concerns directly with the person involved or with their local contact from HR, their line manager, their Legal partner, or the Business Ethics team. If this is not feasible, our whistleblowing channel can be used.

In 2023, we still used our legacy notification systems for whistleblowing, Firmenich Speak-Up and DSM Alert. Since January 2024, our dsm-firmenich SpeakUp platform is available. The platform is operated by an external provider and can be accessed 24/7. It offers the possibility to report anonymously and is also available for third parties. All investigations will be conducted impartially, respecting the principles of confidentiality and the presumption of innocence.

We do not tolerate any form of retaliation against individuals who, in good faith, seek guidance, raise a concern regarding misconduct, or cooperate in an investigation. We have zero tolerance for retaliation, no matter the circumstance. Disciplinary action will be taken against anyone who engages in retaliatory behavior toward those who have spoken up in good faith.

Whistleblower notifications

In 2023, we received 100 notifications via our legacy notification systems for whistleblowing (Speak-Up, Alert). All notifications were reviewed and followed up, and investigations were started if admissible. Of the 75 notifications that have been closed, 24 notifications were substantiated and 51 notifications could not be substantiated. Actions taken included providing training, disciplinary actions, terminations, and policy/process review. Another 25 notifications are still under investigation.

Reported allegations were primarily related to ‘Discrimination, Harassment, Bullying and Retaliation’ and ‘Misconduct or Inappropriate Behavior’. There was one report related to bribery and corruption, investigation of which did not lead to the further substantiation of the reported concerns.

Whistleblower platform






Not substantiated


Under investigation




























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