Introduction

The purpose of this policy is to identify and define risks of irregularities such as fraud, bribery, and other forms of corruption that the Lindex Group may be exposed to in its operations. It also clarifies responsibilities and provides further guidance and instructions on standards of conduct relating to corruption and conflicts of interest, by outlining unacceptable behaviour in order to prevent and detect corruption.

Lindex Group applies a zero-tolerance approach to all forms of bribery and corruption. A core principle of the company is to conduct its operations in a transparent and responsible manner, as stated in Lindex Group’s Code of Conduct.

Our Commitment

Lindex Group is committed to creating a workplace environment where ethical conduct, integrity, and compliance with laws and regulations are upheld at all times.

This Anti-Corruption Policy is based on the tenth principle of the business initiative known as the UN Global Compact, which states that ‘Businesses should work against corruption in all its forms, including extortion and bribery’.

All employees and members of management are expected to perform their duties honestly, with integrity, and in the best interest of the company. They must avoid any conflicts of interest and comply with local laws. The same standards are expected from all parties with whom the Group has business relationships, including customers, suppliers, public authorities and partners. This policy encourages everyone working for or with Lindex Group to speak up and report any concerns about potential violations of law, regulations, organisational policies, or ethical standards without fear of retaliation.

All potential violations of this policy will be thoroughly investigated, and appropriate action will be taken. Breaches of this policy may result in legal proceedings or disciplinary measures, including termination of employment or contracts, depending on the circumstances.

Scope

This policy applies to everyone associated with Lindex Group, including, but not limited to, all employees, interns, contractors, vendors, stakeholders, customers and others within Lindex Group’s value chain, as well as any third parties acting on behalf of Lindex Group. The policy applies in all countries where Lindex Group operates. All potential violations of this policy will be thoroughly investigated, and appropriate action will be taken.

For the purposes of this policy, corruption means any act involving the misuse of entrusted responsibility and/or authority for personal and/or corporate gain. Corruption includes, but is not limited to, bribery, conflicts of interest and misuse of company assets.

Bribery means promising, offering, giving, receiving or soliciting an undue advantage to or from a person or entity, either directly or through an intermediary, with the intent to influence a person’s actions or decisions in order to gain or obtain a business advantage. Undue advantage includes anything of value, such as money, objects of value, entertainment, travel, privileges or an advantage, preferential treatment, or even the promise of such benefits, aimed at influencing a person in an official or public capacity.

Bribery also includes facilitation payments made to government officials to facilitate or expedite processes, and kickbacks, i.e. the return of a sum already paid or due as a reward for awarding or furthering business.

1. Areas with Exposure to Corruption

Corruption can arise in various areas of business operations and activities, typically in connection with procurement, contracting, construction, and purchasing processes. It may also occur in the form of gifts, entertainment and hospitality, facilitation payments, political or charitable contributions, and fraudulent activities.

1.1 Purchasing, Procurement and Contracting Processes

Lindex Group conducts all business in a highly ethical, transparent and responsible manner. This includes fair and impartial contract-awarding processes, free from any form of corruption, whether in procurement, purchasing, or other organisational functions.

1.2 Gifts, Entertainment and Hospitality  

Lindex Group’s employees and management must not offer or accept any form of gifts, entertainment or hospitality that could be perceived as affecting the outcome of a business transaction or otherwise potentially influencing the integrity of the recipient. The term gifts includes items, payments, invitations, personal favours, compensation, or any other form of persuasive means.

Ordinary courtesy corporate gifts and hospitality that are part of normal business operations are permitted only if they are transparent, reasonable and appropriate with regard to the recipient’s position and circumstances. They must be given in good faith, in compliance with applicable local legislation, and within the Lindex Group’s internal guidelines. Cash or other monetary gifts are never acceptable.

1.3 Facilitation Payments

Facilitation payments are strictly prohibited, whether made directly or indirectly. These are small unofficial sums paid to government officials to facilitate or expedite routine services to which the payer is already legally or otherwise entitled to receive with or without the payment. They may also be intended to avoid regulatory penalties, for example to make officials turn a blind eye to non-compliance or negative inspection results.

The use of third parties to conduct business transactions should be avoided where possible. If third parties are engaged, their services must be transparent, reasonably priced, and free from kickbacks or improper payments intended to facilitate other services or work beyond their contractual scope.

This includes, but is not limited to, any type of government services and attempts to speed up processes or similar transactions.

If an employee encounters a situation involving physical coercion they must prioritise their own safety. Any payments made in such situations must be reported to the immediate superior and to the Chief Legal Officer as soon as possible.

1.4 Donations to Charity

Lindex Group may make donations to non-profit public benefit organisations that promote education, culture, research or other social initiatives aligned with the company’s values and objectives. All charitable donations must be properly documented, with transparency regarding the intended use of funds. Charitable donations must be evaluated separately from the company’s commercial activities and must not be linked to any past, present or future business transactions. Donations may only be made to duly registered non-profit public benefit organisations with clearly defined purposes and principles.

Lindex Group’s business divisions may also support non-profit public benefit projects as part of commercial campaigns or activities. Decisions on such commercially related support or sponsorships of non-profit projects are made by the leadership teams of the relevant business divisions.

Lindex Group does not make political contributions or donations to any politician, political party or related organisation, either directly or indirectly.

2. Conflicts of Interest

Transparency in our business is crucial in order to avoid conflicts of interest. A conflict of interest arises when personal relationships, participation in external activities or financial interests influence – or could reasonably be perceived to influence – business decisions. It may also occur when an employee holds a second job that conflicts with Lindex Group’s interests. All dealings with business partners shall always be impartial and professional. Lindex Group values full transparency in relation to any potential conflicts of interest. Employees are required to withdraw from any decision-making process that creates or could be perceived to create a conflict of interest.

3. Fair Competition

Lindex Group is committed to promoting fair competition and open markets. Fair competition is a basis for business development and innovation. Lindex Group believes that free and fair competition is always positive and enables the company to conduct good and sound business. Any agreements, including but not limited to, price fixing, market sharing, bid rigging, or output restrictions, are regarded as corruption.

4. Commitment of Business Partners

All employees and management involved in engaging business partners are responsible for ensuring that appropriate due diligence is carried out for each new business partner, to ensure compliance with this policy and to prevent corruption.

All contracts with business partners shall be made in writing and shall be filed and recorded in accordance with applicable company procedures. Verbal agreements are not permitted. Fees paid out shall be appropriate and reasonable in relation to the standard remuneration for such services legitimately provided. Payments may only be made against a valid invoice detailing the services provided and expenses incurred and must be processed through an official bank transfer by a reputable financial institution. No part of any payment made may be passed on by a business partner in violation of this policy.

5. Accurate Financial Record-Keeping

Maintaining accurate and up-to-date financial records is essential to Lindex Group’s commitment to transparency and integrity. All financial transactions must be recorded accurately and promptly, in accordance with applicable laws and regulations. This ensures compliance with anti-corruption laws and helps us detect and prevent any fraudulent activities. Lindex Group adheres to all relevant financial reporting standards and conducts regular internal and external audits to verify the accuracy of its financial records.

6. Support and Investigation

6.1 Support

Questions regarding anti-corruption issues or the interpretation of this policy may be directed to your immediate superior, the Leadership Team, the Head of Security, or the Chief Legal Officer.

6.2 Reporting

If you observe or experience misconduct involving Lindex Group or its value chain, you are encouraged to speak up.

All individuals covered by this policy are required to report any suspected violations of this Anti-Corruption Policy. The whistleblowing channel is available to everyone, and Lindex Group employees may also report concerns directly to their manager, the Security Manager, or the company management.

All reports of suspected violations will be investigated thoroughly, objectively, promptly and independently, without regard to the individual’s position, length of service, or relationship with Lindex Group. Appropriate measures will be taken based on the findings of the investigation, and any substantiated criminal activity, including corruption, will be reported to the relevant authorities.

All information received in connection with an investigation of a suspected violation will be treated confidentiality and shared only on a strict need-to-know basis. This is to protect both the reputation of individuals during an on-going investigation and the safety of employees who raise concerns, ensuring they are not subject to any form of retaliation or harassment. Employees must not attempt to conduct any personal investigations into suspected violations of this policy.

Implementation

The implementation of this policy is an ongoing process that requires commitment at all levels of the organisation. Self-leadership and clear communication are key to its success. The Group Management is responsible for ensuring that this policy is communicated, implemented, and followed throughout the organisation, and that the necessary prerequisites for continuous implementation are in place across all divisions.

The focus areas outlined in this policy are diverse and therefore require different approaches to implementation. These include systematic controls, regular communication and continuous training on anti-corruption topics.

To support implementation of and adherence to this policy, each business division maintains supporting documents such as guidelines and action plans. The leadership teams of each business division are responsible for developing these documents and for providing relevant training as needed.

Governance

Lindex Group’s Board of Directors is accountable for the management of actual and potential corruption risks, impacts and opportunities.

Lindex Group’s Board of Directors approves the Anti-Corruption Policy and reviews it annually. When necessary, the CEO or CEO’s delegate may make technical amendments to the policy approved by the Board of Directors.

The Chief Legal Officer is responsible for maintaining and interpreting this policy, as well as for updating it when required.

The leadership teams of the business divisions are responsible for ensuring that all employees, business partners, and third parties engaged by them are familiar with this policy and any supplementary guidelines. They must also ensure that employees receive relevant training on anti-corruption matters.

Our focus  

All Lindex Group employees, management, and partners or suppliers are strictly prohibited from directly or indirectly promising, offering, giving, receiving, or soliciting anything of value – either directly or through intermediaries –  in connection with any business matter, for the purpose of obtaining or providing an improper advantage.

Lindex Group employees must always:

• Act honestly and serve as role models of ethical integrity.
• Know and comply with this policy.
• Observe all applicable laws, agreements, internal policies and regulations.
• Neither request nor accept gifts of non-trivial value and follow normal industry practice.
• Neither offer nor pay bribes, gifts or other favours to public authorities, suppliers, or other partners.
• Clearly distinguish between company and private interests and avoid potential conflicts of interest. Refuse gifts that may create a conflict between private interests and the company’s interests.
• Notify their immediate superior of any gifts received from suppliers or partners.
• Report any incidents, risks or concerns that may constitute a breach of this policy

Lindex Group does not tolerate any form or degree of corrupt activity. Such conduct is never in the company’s interest. If an employee is uncertain about their obligations under this policy, they should seek guidance from their superior or management. Everyone covered by this policy is responsible for keeping themselves informed and for ensuring their conduct complies with the requirements of this policy, relevant local rules and legislation in the countries in which business is conducted, and any other business practices that may be applicable, such as trade association codes of ethics or international conventions.

All business transactions carried out on behalf of Lindex Group must be recorded accurately and truthfully in the company’s accounts, in accordance with the Lindex Group reporting policies. Any suspected violations of this Anti-Corruption Policy must be reported. All reported or suspected breaches will be investigated thoroughly, independently, objectively and promptly.

Speak Up

Lindex Group encourages all its employees, suppliers, partners, public authorities, customers, and other stakeholders to report any suspected misconduct or raise concerns related to this policy through the whistleblowing channel: report.whistleb.com/en/stockmann

All reports will be thoroughly and independently investigated and addressed by the company. Further details regarding the reporting process can be found in the Lindex Group Speak Up Policy.

This policy was approved by the Lindex Group plc’s Board of Directors in December 2024.