We conduct business in an honest, transparent, and ethical manner. Our team oversees a global business ethics program that goes beyond box-ticking compliance, providing active and targeted support to management and employees.
Following the 2023 merger, 2024 saw the introduction of common Group policies and standards governing our own business ethics and the standards expected of our suppliers.
Code of Business Ethics
ESRS G1-1
Our Code of Business Ethics outlines our values and commitments to each other, our communities, and our planet. It is both a reference document and a day-to-day manual, guiding our people on how we do and do not conduct business. This is elaborated upon in our business principles, which clarify key issues, help us make the right choices, and underline how we expect everyone at dsm-firmenich to act with integrity in their daily work.
Our Code is universal. It applies globally to everyone in our company whenever they are on company business, and is applicable at our offices, sites, warehouses, and any other dsm-firmenich location. In October 2024, we launched a Code of Business Ethics training to ensure that everyone understands the importance of adhering to our principles of integrity, ethics and compliance.
Our Code helps our employees understand the values and principles that apply to their work at and with dsm-firmenich. Any act or omission on the part of an employee that breaches the Code is regarded as a potential breach and may lead to disciplinary action up to and including termination of employment. According to HR data, in 2024 there were 99 cases of termination due to breaches of the Code of Business Ethics.
Group Policy framework
Group Policy framework
More detailed explanations of how our business principles are applied can be found in our Group Policy framework. This framework is also used to foster efficient and effective business processes, and to mitigate risks.
- Position statements clarify our positioning on ethical topics related to specific areas of our business for our external stakeholders. They are published on our website
- Group policies explain the rationale behind the ethical positions we adopt, our managerial intent, and the key elements of the relevant governance structure. Our Group policies also define the requirements for employees working in our Business Units and Business Partner functions
- Group standards provide further detailed guidance on how to comply with the requirements of our Group Policies in a correct and consistent manner
- Group policies and standards are usually published only internally
We’re all responsible for ensuring that every day we meet the highest ethical, fair and transparent standards. Together, with integrity, we bring progress to life.
Supplier Code and Responsible Sourcing standard
As a trusted partner to our stakeholders, we strive to operate to the highest standards. We desire only to engage with others who commit to operate to the same standards, with the objective of achieving an ethical, traceable, and sustainable value chain. These standards are articulated in the principles set forth in our Supplier Code and Responsible Sourcing standard, which is embedded in the Supplier Code.
All suppliers are expected to follow our Supplier Code, the Responsible Sourcing standard, and all relevant laws and regulations. We assess adherence via supplier self-assessment questionnaires, as well as through on-site or desktop audits. We use external (live alerting) platforms that provide relevant information (background, current events and potential threats) on our business partners. Any breach of our Supplier Code or Responsible Sourcing standard may lead to the discontinuation of the collaboration with dsm-firmenich and to possible legal sanctions.
Likewise, to ensure ethical business conduct on the part of agents and distributors who act on our behalf or deal with dsm-firmenich products further down the value chain, we expect these third parties to work according to the highest ethical principles and to comply with all relevant laws and regulations, particularly those related to combating bribery and corruption.
Identifying and managing bribery and corruption risks
ESRS G1-3
Bribery and corruption are both illegal and unethical: they have a negative impact on individuals, businesses, and society at large. We therefore do not tolerate bribery or corruption in any form. In 2024, a new anti-bribery and corruption Group policy and new Group standards were introduced to replace our legacy policies and procedures. These provide a general framework to fight against bribery and corruption and apply to everyone working for and with dsm-firmenich.
As part of the business ethics program, risks relating to ethics and compliance are periodically evaluated, with a particular focus on 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. Specific legacy trainings were in place focusing on anti-bribery and corruption awareness. These were discontinued in September 2024.
All employees in ‘at-risk’ functions were required to complete anti-bribery and corruption training. At-risk functions include all management functions, as well as employees in roles that involve interaction with external parties, control over financial transactions, legal and compliance responsibilities, and sales and marketing activities. In September 2024, the training had an aggregated completion rate of 95%1 reflecting our commitment to organization-wide compliance and engagement. This completion rate cannot be split by function as it is not integrated into our HR systems.
The newly launched Code of Business Ethics training for all employees includes a section on anti-bribery and corruption awareness. Furthermore, in December 2024, a new training course for all employees focused exclusively on combating bribery and corruption was launched and is applicable for all employees. The course covers understanding our policies and standards, recognizing corruption, reporting concerns and the consequences of non-compliance thereby helping to ensure adherence to our integrity and standards. Course completions will be monitored, and management will be informed of the completion rates. A process exists to deal with uncompleted training cases.
Speaking up
ESRS S1-3,17 S2-3 S4-3
At dsm-firmenich, we all have a responsibility to speak up in the event of any concern regarding compliance with our Code of Business Ethics. If anyone has witnessed behavior that might be in breach of our values or business principles, it is vital that this is reported. We encourage open and honest communication. Therefore, wherever practicable, we recommend that employees raise 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. We also have a whistleblowing platform in place, SpeakUp.
SpeakUp is operated by an external provider and is accessible 24/7. It offers the option of lodging reports anonymously and may also be used by third parties. All investigations into allegations reported via SpeakUp are conducted impartially, respecting the principles of confidentiality and the presumption of innocence. The investigators shall carry out their tasks in an independent and impartial manner and shall be bound by the utmost confidentiality regarding the details of the investigation. The link to the platform is included on our website, and referenced in our Code of Business Ethics, and our Supplier Code for easy access.
Speak up cases are reported to the Group Ethics Committee at least on a quarterly basis. The committee consists of:
- Chief Executive Officer
- Chief Financial Officer
- Chief Human Resources Officer
- Chief Legal, Regulatory, Risk and Compliance Officer – chair
- Head of Business Ethics – secretary
We do not tolerate any form of retaliation against individuals who, in good faith, seek guidance, raise a concern regarding potential misconduct, or cooperate in an investigation. We have zero tolerance for retaliation, irrespective of the circumstances. Disciplinary action is taken against anyone who engages in retaliatory behavior toward those who have spoken up in good faith.
SpeakUp reports
ESRS S1-17 G1-4
In 2024, we received 163 reports via SpeakUp. All were reviewed and followed up on, and investigations were initiated wherever admissible. Of the 163 reports, 8 were noncases (e.g., translation system errors and tests) and 21 cases were linked to other issues, resulting in 134 unique cases. 83 cases were closed by 31 December 2024. 34 cases were substantiated, while 49 could not be substantiated.
Actions taken included providing additional training, disciplinary measures, terminations, and reviews of our policies and processes. 51 cases were under investigation at the end of 2024. The allegations reported primarily concerned discrimination, harassment, bullying and retaliation, mistreatment/inappropriate behavior, labor practices, SHE related issues, conflicts of interest and fraud, embezzlement or misuse of company assets or resources.
Three cases concerning bribery and corruption were reported via SpeakUp, and internal investigations were conducted based on these reports. These cases could not be substantiated.
1 Including completed and on time, meaning employees who still had time to complete the training.