Impact, risk, and opportunity management
A dedicated Business Ethics team, which reports to our Chief Legal, Risk and Compliance Officer, oversees our observance of ethical and legal standards, and guides our interactions with colleagues, our Business Partners, and the world.
In 2025, our focus was on to establish the foundations of our ethics and compliance framework, ensuring that our program is strong, resilient, fit for purpose, and responsive to the evolving needs of our organization and our stakeholders.
At least on a quarterly basis, the Business Ethics team reports and escalates compliance issues and initiatives to the Group Ethics Committee (GEC). The GEC oversees, assesses and enhances ethics and integrity across the company, based on the Code of Business Ethics and Group policies. The GEC plays a crucial role in maintaining an ethical culture and ensuring that the organization operates with accountability.
The GEC consists of:
Chief Executive Officer
Chief Financial Officer
Chief Human Resources Officer
Chief Legal, Risk and Compliance Officer – Chair
Head of Business Ethics – Secretary
Identifying and managing bribery and corruption risks
We focus on preventing corruption and bribery by establishing effective countermeasures. Our Anti-Bribery and Corruption policy shapes our internal regulatory framework by defining the principles and areas for attention. From this, we derive a set of standards that address the main risk areas. These were further strengthened in 2025. Moreover, a multi-disciplinary third-party risk assessment was conducted to gauge the risk of bribery and corruption, among other things. As a result, we implemented further process improvements and identified areas requiring more attention. Reflecting both the enhancements in 2025 and our continued focus on preventing corruption and bribery through effective measures, during the year, we:
Continued our review of donations and sponsorships and the suitability of our philanthropic initiatives and partners
Supplemented the Conflict of Interest Standard with a section providing guidance on managing potential or actual conflicts of interest during the recruitment process
Launched a new Gifts and Entertainment Standard, replacing earlier requirements to cover the giving and receiving of gifts and participation in entertainment activities with individuals outside dsm-firmenich
Commenced work on a Group standard to harmonize our Anti-Bribery and Corruption Third-Party Risk checks. This ensures due diligence vis-à-vis our Business Partners
Gathering data through dedicated mechanisms linked to each of the aforementioned standards also helps the company to ensure their consistent application, to identify trends, analyze data relationships, and proactively address potential risks.
The aim of these standards is not only to establish a set of rules to protect the company and its workforce but also to provide clear guidance to employees on the part they play in fostering an ethical business environment. The standards are shared via dedicated communication and training programs, complementing the imperative learnings enshrined in our Group Mandatory Trainings.
Group Mandatory Trainings
Training is a key tool to mitigate the risk of breaches of ethical standards, foster ethical behavior and support effective implementation of our business conduct policies.
In 2025, the company further strengthened its mandatory compliance training framework with the objective of achieving full coverage across the workforce. Between October 2024 and August 2025, five mandatory trainings were rolled out: Code of Business Ethics (CoBE), Anti‑Bribery and Corruption (ABC), People‑Centric (including Work Respect and Harassment Prevention), Physical and Cyber Security, and Safety, Health and Environment (SHE). All employees are required to complete the five mandatory trainings. These trainings are subject to a two‑year review and refresh cycle.
By the end of 2025, completion rates for all five mandatory trainings for internal employees exceeded 96%, demonstrating a high level of awareness, engagement, and compliance across the organization.
Metrics and targets
The expected positive impact of our corporate culture is measured through the Employee Engagement Survey. See more information in Own Workforce, Inclusion and belonging.
Speak Up and incidents of corruption and bribery
In 2025, we processed 218 reports via Speak Up (2024: 163), including ANH. All were investigated.
Substantiated complaints on issues such as workplace harassment, mistreatment, conflicts of interest, labor practices, or SHE-related issues, led to terminations, written warnings, trainings, process improvements, among other things.
Five cases related to potential bribery and corruption were reported via Speak Up in 2025 (2024: three). Each case was subject to internal investigation. While allegations could not be substantiated, all reports were taken seriously and reviewed thoroughly in line with our commitment to integrity and accountability. No convictions or fines relating to anti-corruption and bribery laws have been reported. More information can be found in Speaking up in Business Ethics.