The California Transparency in Supply Chains Act Disclosure

The Lindt & Sprüngli Group strongly condemns human trafficking and slavery and remains committed to
ensuring that our supply chains are free from human trafficking and slavery.
The Lindt & Sprüngli Supplier Code of Conduct helps to implement this commitment in our supply chains.. Our
Code of Conduct requires all of our suppliers to comply with all applicable national and international laws and
regulations relating to human trafficking and slavery, including the International Labour Organization and the
United Nations’ Universal Declaration of Human Rights.

We regularly assess risks of non-compliances with our Code of Conduct, or ask a third party to assess the risks in
specific supply chains. Where necessary, we implement concrete programs to support the suppliers in reaching
and maintaining compliance with our Code of Conduct.

Under our Supplier Code of Conduct, we reserve the right to conduct (or have a third party conduct) audits of
suppliers and their facilities to verify compliance with the Code of Conduct. Suppliers we define “at risk” for
noncompliance with any aspect of our Code of Conduct, including the requirements related to human
trafficking and slavery, are assessed, audited and/or verified by independent parties on a regular basis. We
also have internal monitoring/control systems in place, covering a wider range of suppliers (up to 100% for
certain supply chains). Examples are: China Supplier Development Program; Lindt & Sprüngli Farming Program
for cocoa beans from Ghana and Ecuador; Hazelnut suppliers/farmers in Turkey; and palm oil suppliers.

The Supplier Code of Conduct requires all of our suppliers to sign a Compliance Declaration, stating that they:
(1) have received and commit to fully comply with our Code of Conduct Code and its principles and
requirements; (2) agree that we or a third party may carry out periodic, audits on their facilities; and (3)
effectively communicate the contents of our Code of Conduct to their employees, agents, subcontractors and
suppliers and ensure all measures required are implemented accordingly. Failure to comply may result in Lindt
& Sprüngli ceasing to do business with offending suppliers.

All Lindt & Sprüngli employees are required to adhere to our Business Code of Conduct, which includes
compliance with all laws and regulations. The CEOs of the Lindt & Sprüngli Group companies are responsible for
ensuring that employees are informed and educated about the Business Code of Conduct. Furthermore, the
CEOs are expected to enforce strict adherence to the rules and regulations of the policy. Our disciplinary policy
permits a range of measures, from corrective actions up to termination of relationships with employees
involved in any similar misconduct.

Relevant employees, but mainly suppliers (up to farmer level) receive regular training on our Code of Conduct,
including the relevant portions relating to human trafficking and slavery, as exemplified in our Lindt & Sprüngli
Farming Program in Ghana.


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