Progress Report 2012 - Lego

With all our suppliers we strive to actively engage
and implement the fifth edition of our Code of
Conduct. However, we do expect full implementation
to be adopted in stages in some of the human rights
high risk countries we operate in. To enforce our
position we will leverage the influence we have to
seek the needed progress.
Responsible Code of Conduct for
Outbound Licensing Partners
The LEGO Group requires all of its licensing partners
to provide written assurance that their vendors
comply with the LEGO Group Code of Conduct. In
2012 we made sure that licensing partners and their
vendors audit their suppliers in risk countries on an
annual basis. This is the same requirement we have
towards our own suppliers.
Collaborating with the industry – ICTI Care Process
In 2012, the LEGO Group had 14 suppliers certified
by the ICTI Care Process in Asia. The LEGO Group
has access to the audit reports and reviews them
continuously. Should there be any major nonconformities
with the LEGO Group standards, the
LEGO Group will contact the suppliers and, if relevant,
conduct on-site inspection to check if corrective
action is implemented. Also in 2012 the ICTI Care
Process announced that from 2013 they will launch a
more ambitious seal which factories can obtain only
if they adhere to a 60 hour working week, although
allowing up to 66 hours of overtime in a twelve week
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The LEGO Group Progress Report 2012 Outside the LEGO Group
period per year. The LEGO Group was pleased to
witness this necessary progress as this is closer
to alignment with the LEGO Group requirements.
The LEGO Group has been committed to the ICTI
(International Council of Toy industries) Care Process
since 1 January 2006 (Date Certain commitment).
Whistle-blower – a way to speak up
Our whistle-blower infrastructure gives employees the
opportunity to report behaviour they consider to be in
violation of the guidelines that safeguard the integrity
and policies of the LEGO Group, as well as any law
or regulation. Employees decide whether he or she
wants to be anonymous. All reports are sent directly to
the LEGO Group’s General Counsel. Employees can
communicate in their local language and guidance
text is available in our five company languages. The
existence of the whistle blower infrastructure has been
communicated in articles on our intranet, as part of
an E-learning program mandatory for all Directors and
levels above, and a handbook on business conduct
is given to all employees as part of introduction in
Denmark. The whistle blower link can be accessed by
employees from the front page of our intranet.
Business Integrity
Doing business in most countries of the world
we need to respond to the issue of widespread
corruption. According to the United Nations Global
Compact, corruption adds 10% to the cost of doing
business. We see those resources as a missed
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