The investigation, carried out by an external law firm in 2014, revealed the following:
- Internal LEGO Group compliance guidelines had not been followed – in a limited number of incidents – by individual employees in the LEGO Group sales team in a certain part of Germany.
- The incidents occurred in 2012 and 2013.
- The incidents involved a limited number of retail partners and approximately 20 LEGO® products.
- Due to the limited scope of the misconduct, the internal investigation indicated that there was no impact on the general consumer price level.
In November 2014, the LEGO Group submitted these findings to the Bundeskartellamt and took the following actions:
- Sanctions were imposed on all employees who were responsible for the non-compliances. This means that some employees are no longer working for the LEGO Group.
- An extensive update to the comprehensive training program on competition compliance, which was already in place globally, was initiated and has been executed.
LEGO Group Chief Financial Officer John Goodwin comments:
“While this non-compliant behaviour only involved a small number of employees in a restricted part of Germany, we want to make it clear that it is unacceptable and not representative of what the LEGO brand stands for,” adding:
“We take the non-compliant actions from the specific LEGO employees as well as the decision of the Bundeskartellamt very seriously and we have taken steps to prevent such conduct again. There should be no doubt that the LEGO Group always adheres to the laws and regulations of all countries. This is deeply rooted in our values and cultural foundation as well as being open, honest and transparent about how we conduct our business to ensure it is done in an ethical manner”.
You can read the Bundeskartellamt’s press release on the matter here.