ESRS G1 – Business Conduct

Material Impacts, Risks, and Opportunities

As a global company with complex value chains, Beiersdorf bears a high level of corporate responsibility and is obliged to comply with various legal provisions and other regulations. Guidelines such as our Code of Conduct (CoC) reflect the principles and values of our corporate culture and help us to fulfill our obligations; we have therefore identified a positive impact in this context as part of our materiality assessment. Our Group-wide compliance management systems (CMS) in the Consumer and tesa Business Segments, which have also implemented targeted programs for the prevention and detection of corruption and bribery in particular, are likewise contributing to this positive impact. However, there are still risks associated with potentially inadequate investigations into corruption, which can have a financial and reputational impact as a consequence of instances of corruption. As a further component of our CMS, we have implemented various reporting systems and channels which, in conjunction with the protection of whistleblowers, represent an additional positive impact in the context of the materiality assessment. We explain how we deal with these material impacts and risks below.

A detailed overview of all impacts, risks, and opportunities identified and the methodology used for the double materiality assessment can be found in the chapter “ESRS 2 – General Disclosures.”

Corporate Culture and Guidelines for Business Conduct

The core values of the Consumer Business Segment are Care, Trust, Simplicity, and Courage. They are intended to serve as a daily benchmark for ensuring that we always communicate and act consistently across our business areas. tesa’s core principles include Respect, Honesty, Trust, Tolerance and Integrity.

These corporate values are reflected in our CoCs as well as in key guidelines that provide further detail on the requirements of the CoCs. The Consumer and tesa CoCs have been drawn up in cooperation and consultation with all the main functions and are binding Group-wide for all companies in the Consumer and tesa Business Segments.

Other guidelines as part of our CMS

In addition to the CoCs, as part of our compliance programs, we have implemented, among other things, company-wide, uniform guidelines on antitrust law, on data protection with regard to the principles of the European General Data Protection Regulation (GDPR), and on the prevention of corruption.

The Consumer and tesa antitrust guidelines contain clear instructions on behavior in accordance with antitrust law, guidelines for contacting and exchanging information with competing companies, information on communication with customers, for example in connection with sales prices, and basic dos and don’ts.

The Consumer and tesa data protection guidelines describe in particular how the principles of the European General Data Protection Regulation (GDPR) are implemented for the lawful processing of data in our EU companies. They also provide employees with assistance and instructions on how to handle data.

The Consumer and tesa anti-corruption guidelines provide guidance for our employees on how to deal with gifts, product samples, and invitations from and to representatives and employees of other companies and public officials. They also contain information on how to deal with conflicts of interest.

As with the CoCs, it is the responsibility of managers to implement the guidelines in the company and monitor compliance. They receive significant support in this regard from the Compliance Officers in the regions and subsidiaries.

We also underscore our aspirations and minimum standards through our membership of recognized initiatives and associations. Beiersdorf AG and tesa SE are both members of the United Nations Global Compact, for example, and both are committed to the core labor standards of the International Labor Organization (ILO).

Group-wide CMS

Consumer and tesa each have their own, closely coordinated CMS. The CMS of each Business Segment is based on established international standards such as IDW PS 980, the CMS auditing standard. The aim of our CMS is to comply with essential legal provisions and internal guidelines in all countries in which Beiersdorf operates. The tasks of our CMS include the structured implementation of key compliance programs throughout the entire organization and, in particular, the prompt identification and management of relevant compliance risks.

We are guided by the following principles:

• Prevent: We incorporate pre-emptive measures in our management system to prevent wrongful conduct. This includes, for example, our CoC, other guidelines, as well as communication and training measures.
• Detect: We carry out annual risk analyses both centrally and locally in our affiliates in order to identify significant compliance risks across the Group at an early stage.
• React and improve: We present the results from the risk analyses to the Executive Board and use them to continuously adapt and improve our global and local compliance programs. We penalize any violations of legal or internal requirements as appropriate in each individual case. In addition, we continuously develop improvement measures for the entire CMS.

Locally responsible compliance officers in the regions and affiliates communicate the components of the compliance programs to our employees and play a fundamental role in their local implementation. The aim of this is to ensure that all elements of our CMS are firmly established at our sites around the world and are continuously monitored and improved.

Group-wide whistleblower and reporting systems

As part of their CMS, Consumer and tesa have set up and communicated various reporting systems and channels. These can be used to record any breaches of conduct that are unlawful or in conflict with internal company guidelines – anonymously if preferred. Guidelines and procedural guides, for example on whistleblowing, case management, and ad hoc reports, have been implemented.

The Consumer Business Segment has the “Speak up. We care.” platform, while tesa uses a whistleblower platform called “Your voice – Our bond.” Both platforms are provided by the same system provider and can be used anywhere in the world at any time. They are available in various languages and can be used by our own employees as well as customers, consumers, suppliers, and other stakeholders. Possible misconduct that can be reported includes incidents relating to company policy, human rights violations, and cases of corruption or bribery. Information on how to submit complaints and how they are processed is publicly available on the respective company website, on the company intranet and on the homepage of the whistleblower platforms. There are also other internal reporting options for our employees, such as central compliance hotlines and email addresses. We regularly inform our employees about the various reporting systems and channels as part of compliance training.

Taking into account the Directive (EU) 2019/1937 on protection for whistleblowers, we have established processes for responding promptly to any reports received. Access to and processing of reports is systemically restricted to a small number of employees in the Corporate Compliance departments, Corporate Audit and corresponding experts (referred to as “case managers”) from the relevant internal departments. The latter only have access to reports that fall within their respective areas of responsibility. Processing is based on internal procedures, standards, and the German Whistleblower Protection Act (HinSchG). This obliges “case managers” and other persons entrusted with investigating the report to handle information and investigative measures confidentially and independently. Any conflicts of interest in dealing with the whistleblower, the complaint, or the investigative measures must be promptly identified and managed. We treat the identity of whistleblowers as strictly confidential throughout the entire procedure, not least in order to protect them from possible retaliation. Their identity may only be disclosed to the extent that it is absolutely necessary for a possible investigation and criminal prosecution or as required by applicable law. The same applies to the identification and treatment of any accused person and any other individuals involved.

The Consumer Business Segment continually monitors the effectiveness of its whistleblower system. To do this, comparisons of the reports received are made with the results of other companies of similar size to ensure that the system is used appropriately. As part of a survey on compliance culture in 2024, we also surveyed the extent to which employees are aware of whistleblowing channels. The predominantly positive feedback shows that the channels are known to employees and are perceived as trustworthy. As part of external communications, we have taken measures to ensure that whistleblowing channels are easily accessible worldwide. The overhaul of the country websites ensures that all relevant stakeholders have easy access to the channels. These measures ensure that not only employees, but also external stakeholders such as workers in the value chain, consumers, and affected communities have access to and can trust the whistleblower system.

Compliance training

A key component of our CMS is a risk-oriented training concept for specific target groups with e-learning and face-to-face training on individual compliance topics. As part of this, we have defined a uniform, global training procedure that has been agreed with the responsible Executive Board member and implemented in all of our affiliates.

Training on the CoCs for the Consumer and tesa Business Segments takes place every two years (tesa) and every four years (Consumer), and is mandatory for all employees worldwide. The topics covered include business conduct, personal integrity, the handling of company resources, information and data, and how to proceed in the event of any breaches.

Training courses on the prevention of corruption, antitrust law and data privacy are also held every two years for both Business Segments.

In the Consumer Business Segment, the courses are aimed at all employees worldwide or, in the case of data privacy, EU-wide (with the exception of production employees). Employees also receive additional, in-depth training if they are exposed to increased risk in their roles or activities in the respective areas. When it comes to preventing corruption, this applies in particular to employees in the sales, marketing, purchasing, and management functions.

At tesa, training is provided for all employees with increased risk. This means that, similarly to Consumer, corruption prevention training is mainly targeted at employees in the sales, purchasing, and management functions. Further training is provided as required.

Consumer and tesa have defined an annual participation rate of at least 95% worldwide for all of the above-mentioned compliance training courses, measured in terms of the annual target group for the various key compliance training areas. The achievement of this target is part of the annual reporting to the Executive and Supervisory Boards. In 2024, the actual participation rate was 92% for the Consumer business segment and 99% for tesa. The participation rate includes the subsidiaries of La Prairie and Chantecaille.

In addition to the training courses, we regularly inform our employees about relevant compliance topics and new developments through a variety of communication channels such as the intranet and emails. We are also in regular contact with our local affiliates, for example to discuss relevant updates, any issues that arise, and best practice approaches.

Prevention and Detection of Corruption and Bribery

Consumer and tesa aim to prevent corruption and bribery and address incidents in this regard using the CMS described above and the associated guidelines, procedures (e.g. relating to reporting channels), and actions.

As already mentioned, our mandatory training courses are subject to clear, globally applicable requirements on anti-corruption, which are monitored locally by the established compliance networks and centrally by the Corporate Compliance departments. These departments are also tasked with ensuring that the defined training metrics are achieved, and will apply the necessary escalation measures if not enough training courses are completed. The Executive and Supervisory Boards are also informed about corruption and bribery as required.

Any incidents of corruption or bribery reported via the systems described above that are substantial and require sanctions are referred to the relevant management team and, if applicable, to a member of the Executive Board.

Local Compliance Officers and the Corporate Compliance departments are the points of contact for employees with any questions on corruption and bribery.

Incidents of Corruption or Bribery

Reports and incidents of corruption or bribery in the reporting period are recorded and evaluated via the existing reporting systems, as described above (see “Corporate culture and guidelines for business conduct” and “Prevention and detection of corruption and bribery”).

This includes all reported and confirmed incidents of corruption or bribery in direct connection with Beiersdorf AG (including affiliates with a majority shareholding) and/or its employees that have led to a legally binding judgment. If this results in fines, these are shown as the total of all legally binding fines that a Beiersdorf AG company had to pay due to violations of anti-corruption laws and/or anti-bribery laws. Our reporting systems as described above form the basis for determining whether any incidents of corruption or bribery occurred during the reporting period, and if so, what fines were imposed.

There were no convictions or fines in connection with corruption and bribery offences at Beiersdorf in the reporting period.

We always investigate all reports of corruption and bribery received via our reporting systems, clarify the relevant facts, and, after careful consideration, take appropriate action. Depending on the circumstances, this may include disciplinary or communicative measures as well as adjustments to internal processes.