www.LEGO.com
Progress Report 09
Read about the Annual Report 
and the magazine The Brick on the back cover
The LEGO Group

The Progress Report - what to expect
The Progress Report is part of the overall reporting concept for the LEGO Group. The 
overall reporting setup consists of three independent publications that interconnect and 
together form the total 2009 reporting from the LEGO Group. Read more about the con-
cept on the back cover of this report.
The Progress Report, which you are reading now, is targeted to those who are interested 
in the detailed follow-up on progress of the LEGO Group regarding Environmental, Social 
and Governance (ESG) activities linked to the LEGO Group’s ability to deliver on the four 
promises given to all stakeholders in touch with the brand:
Play Promise – Joy of building. Pride of creation
People Promise – Succeed together
Partner Promise – Mutual value creation
Planet Promise – Positive impact
The promises are the central part of the LEGO Brand Framework and are based on the 
values and spirit of the LEGO Group. You can read more about the LEGO Brand Frame-
work on pages 12-13.
For the 2009 reporting, the LEGO Group has developed a model to select the ESG 
content to focus the report on the most relevant and current issues. The model takes 
its starting point in relevant ESG frameworks listing a wide range of generic ESG topics. 
58 ESG topics were evaluated. The first filtering was made by determining the relevance 
towards the four promises in the LEGO Brand Framework, where 36 ESG topics were 
found relevant. The 5 step evaluation of materiality, linked to AA1000 and described in the 
publication “Redefining Materiality” published by AccountAbility1), was used for a prioritiza-
tion of the ESG issues. A top 15 of ESG issues was established. The top 15 was further 
reduced to 5 topics based on what is most relevant in a 2009 context. 
On page 3 a list of the 5 selected ESG issues can be seen with page reference to where 
to read more on the issues.
This Progress Report also serves as the annual communication on progress required by 
UN Global Compact based on the fact that the LEGO Group, as the first company in the 
toy industry, signed the UN Global Compact in 2003. Furthermore, this is the statutory 
statement on Corporate Social Responsibility according to section 99 a of the Danish 
Financial Statements Act.
The Progress Report is based on the reporting framework provided by the Global Report-
ing Initiative (GRI) with a self declared C application level. The 2009 report has been sub-
ject to external verification and the auditors’ statement can be seen on page 16.
A geographical overview of the LEGO Group can be found in The Brick.
 
1 The 5 materiality evaluation steps are: 1) Direct, short-term Financial Impact 2) Policy-based Performance 3) Busi-
ness Peer-based Norms 4) Stakeholder Behaviour & concerns 5) Societal Norms (regulatory & non-regulatory)

The LEGO Group – Progress Report 2009    3
CONTENTS
4 
Key figures for 2009 
5 
Message from the CEO 
6 
Targets 2010 and follow-up on 2009 
8 
Review of the results 
12 
Governance strategy and stakeholders 
14 
System and management setup 
16 
Assurance statement from the independent auditor 
17 
Scope and calculation method 
19 
Data overview and notes 
21 
UN Global Compact overview 
22 
Global Reporting Initiative (GRI) G3 overview 
Important 2009 Environmental, Social and Governance ESG topics
5, 8-11, B 52 
Protection of consumers’ safety and health
8-11, B 32  
Occupational health and safety
5, B 24  
Climate change
8-11, B 38  
Anti-corruption
8-11, B 50  
Philanthropy
B = The LEGO Group’s magazine The Brick 
CONTENTS
Progress Report 2009
is published for the LEGO Group  
by Corporate Governance & Sustainability
and Corporate Communications.
Design and print: GRC Graphic House
LEGO, the LEGO logo, the Brick configuration and the Minifigure 
are trademarks of the LEGO Group. ©2010 The LEGO Group.
Net Promoter, NPS and Net Promoter Score are trademarks of 
Satmetrix Systems Inc, Bain & Company and Fred Reichheld.
We appreciate comments and feedback from 
all our stakeholders. Please use the e-mail 
address below: 
 
sustainability@LEGO.com
LEGO A/S 
Aastvej 1
DK-7190 Billund, Denmark
Tel: 
+45 79 50 60 70
CVR-no: 
54 56 25 19
Residence: 
Billund
Reporting Year: 1 January – 
 
31 December
Internet: 
www.LEGO.com
E-mail: 
sustainability@LEGO.com
Progress Report 09
Printed matter

4    The LEGO Group – Progress Report 2009      
KEY FIGURES FOR 2009
2009
2008
2007
2006
Financial performance
Revenue, DKK million
11,661
9,526
8,027
7,798
Profit before special items, DKK million
3,002
2,004
1,471
1,405
Tax on profit for the year, DKK million
-683
-500
-386
9
Net profit for the year, DKK million
2,204
1,352
1,028
1,290
Operating margin (ROS)
24.9%
22.0%
18.1%
17.0%
Return on equity (ROE)
82.3%
72.2%
71.6%
147.1%
Return on invested capital (ROIC)
139.5%
101.8%
69.7%
63.6%
Play Promise
Number of product recalls
1
0
0
1
Consumer Complaint Call Rate
0.093%
0.123%
0.124%
0.118%
Net Promoter Score Index
126
120
115
111
People Promise
Number of employees (headcount end of year)
8,616
7,337
4,723
4,958
Sick leave
2.9%
3.0%
3.2%
-
Injury rate per million working hours
4.8
4.4
8.0
8.6
Partner Promise
Number of quality audited suppliers
2
23
8
Number of Code of Conduct audited suppliers
48
18
22
Overall satisfaction by customers (Customer Pulse)
119
119
111
107
Planet Promise
Water consumption (1,000 m³)
116
68
92
71
Total energy consumption in production (GWh)
155
108
119
124
Waste (tons)
7,970
3,057
2,422
4,252
For Planet Promise indicators, direct comparison between 2008 and 2009 data is not always relevant. This is due to the change of the geo-
graphical presence of the LEGO Group based on a 2008 decision to insource the majority of manufacturing during 2009. For 2009, new sites in 
Nyíregyháza and Monterrey account for a water consumption of 52,000 m³, an energy consumption of 37 GWh and the generation of 3,674 tons 
of waste..
Key figures for 2009
23

The LEGO Group – Progress Report 2009    5
MESSAGE FROM THE CEO
The LEGO Group mission is to “Inspire and develop the builders of 
tomorrow”. That is our true reason for being and what our business is 
built upon. LEGO® products offer children something special on top 
of being a great toy. They offer systematic creativity. The steady evolu-
tionary process of continuously supporting and developing children’s 
creativity is at the core of our innovation process, which we endeavour 
to continuously improve.
We regard our core products as being sustainable today, based on the 
long durability and a compatibility that goes back more than 50 years. 
“Only the best is good enough” is the spirit of the LEGO Group and 
based on this we have challenged ourselves also when it comes to 
Environmental, Social and Governance (ESG) issues. This challenge has 
resulted in an updated and very clear governance strategy focusing on 
five long term targets that are seen as essential to securing that also in 
future, LEGO products and services are seen as being sustainable. 
The 5 targets are:
• Zero product recalls
• Top ten on employee safety
• Support learning to 101 million children
•  Explore the opportunity of becoming fully reliant on renewable energy
• Work towards elimination of waste
The ability to deliver on the above long term targets is highly depend-
ent on a respectful stakeholder dialogue, input and involvement – only 
through collaboration, innovation and ‘hard fun’ will we be able to sus-
tain long term success. The short version of the commitment towards 
sustainability is – POSITIVE IMPACT – which is the Planet Promise given 
to all stakeholders in touch with the LEGO brand.
With respect to stakeholder input, it is very positive to see so many of 
our customers setting sustainability high on the agenda. The journey 
towards transforming ESG issues into opportunities will be an important 
ongoing task for decades. The long term work towards elimination of 
waste will be an innovation driver for reinforced focus on material devel-
opment. It will thereby link into our core business and be part of the 
innovation needed to continue to produce products that have a safety 
second to none.
In this respect it is highly unsatisfactory that the LEGO Group had to 
make a voluntary recall in 2009 even though it was limited to a few 
thousand battery boxes. The recall was carried out as children’s safety 
must never be put at risk when playing with LEGO products. The target 
of zero recalls will continue to be a target for the LEGO Group, just as it 
has been in the past.
The ability to learn is essential for children, and LEGO play is playful 
learning. The systematic creativity inherent in LEGO play supports chil-
dren’s problem solving skills and stimulates their imagination and curi-
osity. Playing with the product stimulates learning. However, while chil-
dren who already have LEGO products are given this possibility, there 
are also children who do not have access to these learning opportuni-
ties. Our target of supporting learning for annually 101 million children in 
2015 covers both the 100 million children we reach through our normal  
business as well as the children we will reach through the philanthropy 
work of the LEGO Group.
Optimization of energy use is high on the company’s agenda, and over 
the past two years the plant in Billund, Denmark installed, and third par-
ty verified, energy saving initiatives equalling a 10 GWh annual saving or 
around 10% of the total energy consumption at the site. The optimiza-
tion will continue while the next phase of looking into the generation of 
renewable energy is initiated.
Our employees and their capability of applying imagination and creativ-
ity in finding the best solutions for the LEGO Group to the benefit of all 
stakeholders are essential for the development of the company. It must 
be safe to work with the LEGO Group and to join the ‘hard fun’ of finding 
the best solution and make it happen. This is why we aim to be a top 
10 company on employee safety globally before the end of 2015. To do 
this we need to eliminate approximately 90% of the accidents that we 
see today.
In 2009, the LEGO Group achieved its so far best financial performance 
and a good ESG performance. Based on the spirit, “Only the best is 
good enough”, we have during 2009 established clear and highly ambi-
tious long term ESG targets that support the innovation of our core 
business and further focus our ESG activities and performance. 
Jørgen Vig Knudstorp
President and CEO
Message from the CEO

6    The LEGO Group – Progress Report 2009      
Targets 2010 and follow-up on 2009
TARGETS 2010 AND FOLLOW-UP ON 2009
ISSUE
PURPOSE
TARGET 2010
Play Promise
Consumer Safety
Continue to secure high safety and quality stand- 
ards
Zero recalls in 2010
Consumer satisfaction
Secure low complaint rate
Consumer Complaint Call Rate ) 1150 parts per million 
(ppm) end 2010
Consumer satisfaction
Secure the positive experience of LEGO® products and 
services
Net Promoter Score Index * 124 end 2010
Consumer information
Secure relevant and up-to-date information for parents on 
www.LEGO.com/parents
Average monthly unique visitors on www.LEGO.com/parents 
* index 110 end 2010 compared to 2008
People Promise
Gender diversity
The LEGO Group supports internal female networks aim-
ing at more balanced promotions. Also the recruitment 
procedure is in focus
The female share of new promotions and recruitments at 
Directors+ level * 25% end 2010 
Healthy working environment
Secure low sick leave rate
Sick leave ) 3.5% end 2010
Safe work place
Secure low injury rate
Injuries with absence ) 5.0 per million working hours end 
2010
Safe work place
Secure low severity of the injuries that may happen
Absence rate due to injuries ) 0.32 per 1,000 working hours 
end 2010
Health & safety management system
Secure certification of all major LEGO sites in order to 
strengthen focus and follow-up
Percentage of employees working at OHSAS 18001 certified 
sites * 90% end 2010
Motivation and satisfaction
Secure highly motivated and satisfied employees by e.g. 
focusing on securing the LEGO image and an exciting 
daily work experience
Employee score for Motivation & Satisfaction * +10 to global 
benchmark (LEGO EEI) end 2010
Work-life balance
Secure the right balance between work and private life
Employee score for work-life balance * global benchmark 
(LEGO EEI) end 2010
Living the People Promise
Secure that the LEGO People Promise is implemented
Improvement of employee score for People Promise for 
more than 66% of departments compared to 2008
Partner Promise
Business integrity and anti-corruption
Secure embedding of the LEGO business integrity and 
fraud standard to avoid corruption, bribery, etc.
All Directors+ trained in business integrity biennially end 
2010
Product quality on all main LEGO sites
Secure that all LEGO sites live up to the set  
standards
No major quality non-conformities found at main LEGO sites 
in 2010
Environmental, Health & Safety (EHS) on 
all main LEGO sites
Secure that all LEGO sites live up to the set  
standards
No major EHS non-conformities found at main LEGO sites 
in 2010
Code of Conduct (CoC) on all main 
LEGO sites
Secure that all LEGO sites live up to the set  
standards
No major CoC non-conformities found at main LEGO sites 
in 2010
Ethical manufacturing at suppliers
Code of Conduct audits based on a country risk assess-
ment to follow-up on first peer suppliers
Target omitted from 2010
Impact of Code of Conduct audits con-
ducted at suppliers
Make findings at conducted audits lead to positive change 
at the supplier and deliver the real value of audits
All CoC non-conformities found in 2010 at supplier audits 
solved within the agreed timeframe
Impact of quality audits conducted at 
suppliers
Make findings at conducted audits lead to positive change 
at the supplier and deliver the real value of audits
All quality non-conformities found in 2010 at supplier audits 
solved within the agreed timeframe
Customer satisfaction
Secure continuous improvement of customers’ perceived 
evaluation of the LEGO Group
Overall satisfaction * index 119 end 2010 compared to 2005
Planet Promise
Energy efficiency
Focus on energy savings to optimize energy use
Energy efficiency index  * 110 end 2010 compared to 2007
Waste management
Focus on recycling of waste
Recycle 80% of total registered waste end 2010

The LEGO Group – Progress Report 2009    7
Targets 2010 and follow-up on 2009
TARGETS 2010 AND FOLLOW-UP ON 2009
TARGET 2009
ACTUAL 2009
COMMENTS TO ACTUAL 2009
Zero recalls in 2009
•
1 recall
One voluntary recall in 2009. The target of zero recalls will continue to be a 
yearly target for the LEGO Group.
Consumer Complaint Call Rate ) 0.120% end 2009
•
0.093%
A significant improvement compared to the 2008 level.
Net Promoter Score Index * 120 end 2009
•
126
An improvement of 6 index points since 2008.
Average monthly unique visitors on www.LEGO.com/parents * 
index 110 end 2009 compared to 2008
•
123
Number of visits grew with 23% compared to 2008.
The female share of new promotions and recruitments at 
Directors+ level * 25% end 2009
•
20%
The 2009 target of minimum 25% was not met. The Directors+ level cor-
responds to the upper two tiers of management. The LEGO Group will 
increase focus to meet the 2010 target. 
Sick leave ) 3.5% end 2009
•
2.9%
An improvement of 0.1 percentage points compared to 2008.
Injuries with absence ) 6.0 per million working hours end 2009 •
4.8
The LEGO Group aims to be a world-class company on employee safety 
corresponding to a frequency of 0.6 injuries per million working hours in 
2015
Absence rate due to injuries ) 0.3 per 1,000 working hours end 
2009
•
0.51
The 2009 target of maximum 0.3 hours per 1,000 working hours was not 
met. The target for 2010 has been set at a higher level, but it is the aim to 
be a world-class company on employee safety in 2015 including a con-
tinuous improvement on the severity of accidents.
Percentage of employees working at OHSAS 18001 certified 
sites * 80% end 2009
•
94%
All LEGO facilities with more than 100 employees are OHSAS 18001 certi-
fied.
Employee score for Motivation & Satisfaction * +10 to global 
benchmark (LEGO EEI) end 2009
•
+11
In order to have a comparable benchmark for the total LEGO Group 
result, a benchmark called “LEGO EEI” is calculated as a weighted aver-
age of the EEI (European Employee Index) results for the eleven largest 
LEGO employee countries.
Employee score for work-life balance * global benchmark 
(LEGO EEI) end 2009
•
+3
In order to have a comparable benchmark for the total LEGO Group 
result, a benchmark called “LEGO EEI” is calculated as a weighted aver-
age of the EEI (European Employee Index) results for the eleven largest 
LEGO employee countries.
Target established from 2010
Number of Directors+ at LEGO sites that are trained in 
business integrity * 25% end 2009
•
69%
Besides the Directors+ population, employees working directly with cus-
tomers and suppliers have been included in the training program.
No major quality non-conformities found at main LEGO sites
•
0
The main LEGO sites are audited by an accredited third party
No major EHS non-conformities found at main LEGO sites
•
0
The main LEGO sites are audited by an accredited third party
No major CoC non-conformities found at main LEGO sites
•
1
The main LEGO sites are audited by an accredited third party. The one 
major CoC non-conformity was related to working hours.
Audit of 100% of suppliers in high and intermediate risk  
countries end 2009
•
96%
Two suppliers were not audited according to plan as a planned exit of one 
supplier was postponed, and a new supplier was accepted late 2009.
50% of all major CoC findings to be solved within next  
calendar year
•
94%
16 major non-conformities were found in 2008. 15 have been solved and 
one related to no individual business registration is still open.
Target established from 2010
Target established from 2010
Energy efficiency index * 110 end 2010 compared to 2007
•
127
Energy use is high on the company’s agenda and the optimization will 
continue while the next phase of looking into generation of renewable 
energy is initiated.
Recycle 70% of total registered waste end 2009
•
88%
An improvement of 19 percentage points compared to 2008.
• Target met       • Target not met

8    The LEGO Group – Progress Report 2009      
REVIEW OF THE RESULTS
Review of the results
The 2009 progress on Environmental, Social and Governance (ESG) 
issues related to the four promises given to the stakeholders of the 
LEGO Group is described below. For more details on the four promises 
please see pages 12-13.
The overall picture of important stakeholder activities related to all four 
promises can be found in The Brick that is published as an integrated 
part of the overall reporting from the LEGO Group.
The Play Promise
Consumer Satisfaction
Consumers are becoming more and more likely to recommend to 
others the LEGO product or experience that they have just had. This 
is reflected in the Net Promoter Score Index which has increased by 
6 index points in 2009 and ended at index 126. This is 6 index points  
above the 2009 target set in 2008 as stated in the Progress Report 2008. 
The Consumer Complaint Call Rate ended at 0.093% for 2009, which is 
within the 2009 target and a significant improvement compared to the 
2008 level. 
Consumer Information
The parents’ site on LEGO.com is established to communicate relevant 
and up-to-date information to parents about LEGO products and child 
development. The site also offers parents the option to ask questions 
and discuss LEGO products or topics with other parents or the LEGO 
Group.
The parents’ site experienced a growth rate in average monthly unique 
visits of 23% compared to 2008 and ended at index 123, which is well 
above the target of index 110 for 2009.
Product Safety
The LEGO Group is proud of its quality standards and controls. How- 
ever, in 2009 a voluntary recall was made by the LEGO Group. The prod-
uct in question is a Power Function Remote Control that poses a ther-
mal burn hazard to users if the batteries inside overheat. A total of 2,250
remote controls had been sold and the product had been distributed 
only via the LEGO web shop and the Shop at Home catalogue from  
8 April 2009 to 6 May 2009. The LEGO Group has received 4 reports 
of the remote control heating up after batteries were inserted. No inju-
ries have occurred. The recall was carried out as children’s safety must 
never be put at risk when playing with LEGO products. The target of 
zero recalls will continue to be a high focus target for the LEGO Group.
The People Promise
Employee Survey
It is the ambition of the LEGO Group that all employees in the company 
feel that they hold an extraordinary job in an extraordinary company. 
Making the experience at work extraordinary is a task that requires the 
attention of the individual employee, all people leaders and the com-
pany.
The annual employee survey showed that the LEGO Group maintained 
its high scores in employee satisfaction. The picture drawn from the 
employee survey is of a global workplace in which – like last year - the 
employees at well established LEGO locations are very satisfied. This 
picture is now extended to also include the new LEGO locations. The 
three new production sites in Mexico, Hungary and the Czech Republic 
have been successfully integrated into the LEGO Group. Not only were 
the response rates in Mexico, Hungary and the Czech Republic high, 
but employees in these countries are also very positive towards their 
new workplace.
In the coming years, the LEGO Group will maintain a strong focus on 
continuous improvement, with focus on openness, trust and content of 
daily work to secure the ambition of extraordinary jobs in an extraordin- 
ary company. 
To ensure equal opportunities, the LEGO Group has set a target for the 
percentage of female promotions to the Directors+ group (corresponding 
to the upper two tiers of management). The target for 2009 was not met 
and there will be increased focus to meet the target in 2010. The LEGO 
Group was among the first companies to sign a charter to increase 
equality in management by promoting the role of women in manage-
ment; a charter initiated by the Danish Ministry of Gender Equality.
Health and Safety
The sick leave percentage for the LEGO Group ended at 2.9% for 2009 
which is within the target for 2009 and 0.1 percentage points better than 
in 2008. 
The LEGO Group experienced 61 accidents with absence in 2009 
equivalent to a frequency of 4.8 injuries per million working hours. This is 
a deterioration of the frequency by 0.4 compared to 2008. The absence 
rate due to injuries did not meet the 2009 target and ended at 0.51 
hours per 1,000 working hours (target 2009 = 0.3 hours per 1,000 working 
hours). 
The LEGO Group aims at being a world-class company on employee 
safety corresponding to a frequency of 0.6 injuries per million working 
NET PROMOTER SCORE INDEX
130
125
120
115
110
105
100
95
 
2006 
2007 
2008 
2009
Index

The LEGO Group – Progress Report 2009    9
REVIEW OF THE RESULTS
Review of the results
hours in 2015. To meet this ambitious 2015 target, an improvement of 
approximately 90% compared to the 2009 result must be achieved with-
in the next five years.
One of the initiatives to meet the 2015 target is continuous use of the 
LEGO Serious Play Health & Safety program to avoid accidents. The 
Health & Safety program is based on the LEGO Serious Play concept 
and gives a good understanding and a clearer picture of where the 
right initiatives have already been taken and where new initiatives are 
needed. Read more in The Brick.
According to the health & safety policy of the LEGO Group, all LEGO 
facilities with more than 100 employees must be OHSAS 18001 certified. 
In 2009, the last sites established in 2008 were certified according to 
the plan. Certification now covers 94% of all employees and the global 
OHSAS 18001 setup is running according to the policy.
The Partner Promise
Customer Pulse
Compared to last year, the Customer Pulse scores are at the same 
high level or above.. The Customer Pulse scores on marketing, partner-
ship and value are all above the scores from last year.
Code of Conduct
The LEGO Group has comprehensive procedures for Code of Conduct 
which apply to the LEGO Group sites and the company’s suppliers and 
licensing partners. 
The LEGO Group focuses Code of Conduct audits on Active First Peer 
Suppliers with Own Production (“AFPSOP”) (i.e. excluding trade agencies) 
located in high and intermediate risk countries. In 2009, 96% of suppli-
ers in this category have been audited. Two suppliers were not audited 
according to plan as a planned exit of one supplier was postponed, 
and a new supplier was accepted late 2009. 
In 2010, the LEGO Group will audit all AFPSOPs located in high risk 
countries. Regarding AFPSOPs located in intermediate risk countries 
from 2010, the preceding audit result will decide the frequency of the 
audit. AFPSOPs located in intermediate risk countries and with a high 
performance in the preceding audit (2009) will be audited biennially. 
AFPSOPs located in intermediate risk countries and with a low perform-
ance in the preceding audit (2009) will be audited annually. The audits 
are conducted by a third party verification company. From 2009, even 
more effort has been put into allocating enough time for each audit 
and on following up more frequently on the audit result, aiming at quick-
er and more thorough improvement. 
The LEGO Group has been committed to the ICTI (International Council 
of Toy Industries) Care Process since 1 January 2006 (Date Certain com-
mitment). The ICTI Care Process is the international toy industry’s ethi-
cal manufacturing program to promote ethical manufacturing through a 
monitoring program for the participating factories with focus on China, 
Hong Kong and Macau. The Date Certain Program is an integrated part 
of the ICTI Care Process. It is a program to obtain commitment from 
toy brands and retailers that, as of a specific, future date (Date Cer-
tain), buyers will only contract products manufactured by factories that 
are in the ICTI Care Process. As per 1 January 2010 the LEGO Group 
has 16 direct and extended line suppliers that are certified by the ICTI 
Care Process – all located in China. These suppliers are audited via the 
ICTI Care Process. The LEGO Group has access to the audit reports 
and reviews them continuously. Should any major non-conformities with 
LEGO standards be observed,  the LEGO Group will contact the sup-
pliers and, if relevant, conduct on-site inspection to check if corrective 
action is implemented.  
In late 2008, an internal instance of non-compliance with the LEGO 
Code of Conduct procedures was observed. In Japan, the LEGO Group 
has an agreement with a franchise partner who operates so called 
Click Brick stores in Japan, selling LEGO branded products. Some of 
the LEGO branded products were sourced directly from the franchise 
partner, where the sourcing was not covered by a Code of Conduct 
procedure. Based on this observation the LEGO Group in 2009 initiated 
a range of Code of Conduct audits at the suppliers to the Click Brick 
stores. At one of these suppliers located in China, it was found that one 
of the workers was only aged 15. In China, according to the labour law, 
the age limit for work is 16 years. The LEGO Group and the franchisee 
INJURY RATE PER MILLION WORKING HOURS
10
9
8
7
6
5
4
3
 
2006 
2007 
2008 
2009
CUSTOMER PULSE, OVERALL SATISFACTION
125
120
115
110
105
100
95
 
2006 
2007 
2008 
2009
Injury rate
Index

10    The LEGO Group – Progress Report 2009      
Review of the results
REVIEW OF THE RESULTS
had a dialogue with the factory, and it was agreed – upon involvement 
of her parents - to send the girl back to her hometown. The factory con-
tinued to pay her wage while she attended school. The girl was rehired 
after her 16th birthday in September 2009.
As a consequence, all sourcing of LEGO products for the Click Brick 
stores now takes place through the LEGO sourcing channels which are 
all covered by the LEGO Code of Conduct procedures.
Product Quality
Due to restructuring of the organization, only 2 quality system audits at 
suppliers have been conducted in 2009 compared to 23 audits in 2008. 
The LEGO Group is continuously supervising product quality. At Asian 
part suppliers, the LEGO Group regularly inspects parts, and at finished 
goods suppliers the company inspects products and the environment 
in which they are produced on a weekly basis. At European part sup-
pliers, outgoing and incoming inspection is made, and at the finished 
goods suppliers, the LEGO Group carries out weekly inspections.
Business Conduct
The LEGO Group enjoys 
an excellent reputation as 
a company setting high 
standards. In relation to 
Business 
Conduct 
the 
LEGO Group will continue 
setting 
high 
standards 
building on the company 
spirit and values. 
In 
2009, 
the 
LEGO 
Group updated its Busi-
ness 
Conduct 
framework 
including roll-out of a new e-learning program and a 
handbook on Business Conduct with Integrity – the LEGO Way. 69% of 
the Directors+ population completed the program in 2009 which is with-
in the 2009 target of 25%. Besides the Directors+ population, employees 
working directly with customers and suppliers have been enrolled in 
the program. Read more in The Brick.
The Business Conduct handbook will be publicly available at LEGO.com 
in 2010.
BREAKDOWN OF VALUE CREATION (DKK MILLION)
Revenue  
11,661
Financial  
income 131
Value of purchased goods 
and services 5,780
Gross value creation 6,012
Total income
For employees - 41%
Wages, salaries, pension, etc, incl taxes 
For investors - 19%
Financial expenses 
Provision for dividend
For society - 11%
Corporation tax
For the company’s future - 29%
Profit excl provision for dividend 
Amortisation and depreciation 
Impairment losses 
The Planet Promise
The change of the geographical presence of the LEGO Group due to 
the decision in 2008 to insource the majority of manufacturing, com-
bined with a considerable increase in production, are the main rea-
sons behind large changes in the figures related to the Planet Promise. 
Direct comparison between the years is therefore not always relevant. 
However, the fact that a higher portion of the production is now in-
house means that it will be easier to work on improvement of e.g. water 
and energy consumption used for manufacturing. 
According to the environmental policy of the LEGO Group, all LEGO 
production facilities must be certified according to the environmental 
standard, ISO 14001. In 2009, the last sites established or acquired in 
2008 were certified according to plan and the global ISO 14001 setup is 
now running according to the policy.
The 2009 target on energy efficiency was reached. A decline in the effi-
ciency was expected for the year due to expected insourcing of energy 
intensive production. Energy efficiency is in focus and is part of the 
initiatives that have been given even higher priority based on the CO² 
mapping made in 2008. The ambition is to gain 10% efficiency by the 
end of 2010 compared to 2007.
In 2009, the LEGO Group registered 7,970 tons of waste. The percentage 
of recycled waste improved from 69 percent in 2008 to 88 percent in 
2009. This is measured based on the total registered amount of waste. 
Non-recycled waste equals 977 tons in 2009 of which 48% is incin- 
erated, 44% is sent to landfill and 8% is electronic or hazardous waste. 
We care and share
The LEGO Group considers play a decisive element of children’s devel-
opment. Children learn through play, and play stimulates their creativity, 
motor skills and ability to solve problems. Unfortunately, more than 1 
billion children worldwide grow up in poverty and have limited possibili-
ties of play. The LEGO Care and Share program has been established 
driven by the wish to help some of these children. By means of dona-
tions of LEGO elements, it is the LEGO Group’s and the LEGO Founda-
tion’s wish to provide these children with play material which, besides 
fun play, also supports their development.
Distribution of gross value creation

The LEGO Group – Progress Report 2009    11
REVIEW OF THE RESULTS
Review of the results
The LEGO Group supports a large number of initiatives all over the 
world through product donations. Most donations consist of LEGO 
Charity boxes with mixed contents of LEGO elements.
Care for Children in Need
The LEGO Care for Children in Need program supports the LEGO 
Group mission: “To inspire and develop the builders of tomorrow”. 
In 2009, LEGO Charity donated products to approximately 400 projects 
worldwide – the largest of these in Jordan, Thailand, Burma, Poland, 
Guatemala, South Africa, Vietnam, Brazil, Russia and Korea. Several of 
these projects were carried out in collaboration with the local Danish 
Embassy or with charitable organizations, e.g. SOS Children’s Villages 
and Save the Children. 
In 2009, 8,276 LEGO Charity boxes were distributed to two age-groups 
(DUPLO Play to the pre-school children and LEGO Play to children of 
school age). Each box contains around 12 kilos of various LEGO ele-
ments. Furthermore, more than 75,000 ordinary LEGO boxes and other 
LEGO related presents were distributed.
The total value of the 2009 donations is estimated at approximately DKK 
28 million calculated in bulk prices, including donations in Denmark 
worth approximately DKK 5 million.
The LEGO Charity boxes are packed in Billund, Denmark, mostly by 
retired LEGO employees who contribute greatly with their efforts.
Care for Local LEGO® Communities 
The LEGO Group has an interest in and concern for the communities in 
which it is located and aims at acting as a good citizen. 
In this respect, participation of LEGO employees and local LEGO offices 
is ensured. For instance, the LEGO Italy employees distributed LEGO 
Charity boxes to the children affected by the earthquake in L´Aquila, 
and the children of LEGO employees in Hungary and Denmark con-
tributed to a donation of 1,000 LEGO sets to children in orphanages in 
Russia. 
In Mexico concurrently with the different LEGO projects initiated with 
the opening of the Monterrey factory in 2009, the LEGO Foundation has 
ENERGY CONSUMPTION
160
150
140
130
120
110
100
 
2006 
2007 
2008 
2009
“adopted” four schools (two primary schools, two secondary schools) in 
Monterrey which have received LEGO Education products and teacher 
support. The intention is to scale up the support in Monterrey in 2010 by 
adding two to four local schools. 
In 2009, more than 500 LEGO employees participated in projects in 
local communities or within the LEGO Charity program. 
Care for Education 
The LEGO Care for Education program includes a specially designed 
LEGO Learning System for schools. The program consists of monetary 
donation from the LEGO Foundation and LEGO Education materials. 
Focus is on already existing schools in OECD countries where the aim 
is to secure the development of learning skills at a higher level than 
that existing today. In order to be able to document that the LEGO 
Education concept makes a difference, impact studies are initiated. At 
present, this is done in Mexico, South Africa and Brazil.
In 2009 the LEGO Group and the LEGO Foundation supported the two 
following major projects:
South Africa – Developing Talents through Creative Play (2009-2013)
The project is funded by the UBS Foundation with special support from 
the LEGO Foundation. The project is run by the LEGO Education part-
ner in South Africa, Hands-On Technology.
The purpose of the project is to fully implement a LEGO Education 
solution in 25 primary schools in a township near Pretoria. This implies 
teacher training in the use of LEGO Education products and learning 
philosophy. Each year five new schools will be added to the project. By 
the end of 2013, the project will have reached 1,000 teachers and nearly 
40,000 students. Read more in The Brick.
 
Brazil – Brick by Brick, the Brazil we want (ongoing from 2008)
Launched in September 2008 in São Paulo, Brick by Brick involves edu-
cational content from Brazil. Based on a large donation of LEGO Charity 
boxes, Edacom (the LEGO Education partner in Brazil) has implemented 
a project with youth centers to give young people an opportunity to 
express what would be the Brazil of their dream. In addition, Edacom 
is providing educational content (ZOOM Magazines) and LEGO MIND-
STORMS Robotic sets. 
The project was launched in the favellas of São Paulo – but has been 
successfully extended to juvenile jails around Rio de Janeiro.
The LEGO Group operates its philanthropic program in cooperation with 
the LEGO Foundation. By the end of 2015 the program aims at reaching 
more than 1 million poor children around the world. More information 
on the LEGO Foundation can be found on www.LEGOfoundation.com.
GWh

12    The LEGO Group – Progress Report 2009      
GOVERNANCE STRATEGY AND STAKEHOLDERS
Governance strategy and stakeholders
During 2009, the Governance Strategy, which sets the direction for En- 
vironmental, Social and Governance (ESG) activities in the LEGO Group, 
was updated and approved by Corporate Management. 
The Strategy defines four areas of importance on which the LEGO 
Group will focus its ESG activities. The four areas are:
• Pioneer Safety
• Support Children’s right to grow
• Care for Nature
• Respectful stakeholder dialogue
The Strategy is based on the former strategy approved by Corporate 
Management in 2007 and focuses the scope further based on learning 
achieved and input received. The Strategy links directly to the Planet 
Promise presented in the LEGO Brand Framework (please see next 
page).
Pioneer Safety for all stakeholders in touch with the brand
Through continuous improvement and ambi-
tious target setting, the LEGO Group has 
set the quality and safety standard in the 
industry for decades. It is only natural for 
the LEGO Group to challenge itself on 
becoming even better and to continue 
setting the standards for the industry. Also 
concern for the safety of employees is an 
inherent part of how the company has 
always done business. This has resulted 
in health & safety being at a high level, 
and focus on this will continue in order 
to be able to reach the ambitious targets defined.
Support children’s right to grow
Supporting children’s right to grow is the 
essence of what the LEGO Group is about, 
whether offering learning possibilities by 
means of the product or the experience, 
or caring for nature to safeguard the 
future of the planet for the next genera-
tion. This focus area is not seen only 
as charity or philanthropy; it should be 
at the top of the list for each LEGO 
employee, whether it concerns child- 
ren in local communities, children as 
consumers or children in need of education 
in developing countries.
Care for Nature
The holistic approach to the way the LEGO Group 
designs products is important, as 21st century soci-
ety puts pressure not only on the sustainability of 
the planet, but also on the health of its inhabitants. 
The long term target towards elimination of waste 
will be an innovation driver for reinforced focus 
on material development. It will thereby link into 
our core business and be part of the innovation 
needed to continue producing products that 
have a safety second to none. Optimization 
of energy use has been high on the agenda, 
and over the last two years the plant based in Bil-
lund, Denmark installed and third party verified energy saving initiatives 
equalling a 10 GWh annual saving or approximately 10% of the current 
energy consumption at the site. The optimization will continue while the 
next focus will be to look into the generation of renewable energy.
Respectful stakeholder dialogue
It is fundamental to the LEGO Group to have a 
respectful dialogue with its stakeholders and con-
tinuously look into issues that matter to them, 
e.g. responsible marketing and anti-corruption. 
In order to ensure a systematic approach to the 
dialogue with LEGO Group stakeholders, Corpo-
rate Management has based on the business 
model defined six primary stakeholder groups. 
The six stakeholder groups are: Consumers, 
Customers, Employees, Business partners/
suppliers, Shareholders and Society.
The strategy defines five long term targets to clearly comunicate the 
way to go forward:
• Zero product recalls
• Top ten on employee safety
• Support learning to 101 million children
•  Explore the opportunity of becoming fully reliant on renewable energy
• Work towards elimination af waste

The LEGO Group – Progress Report 2009    13
GOVERNANCE STRATEGY AND STAKEHOLDERS
The LEGO® Brand Framework
The Governance Strategy delivers the content of the Planet Promise in 
the overall LEGO Brand Framework that was developed in 2008 and 
updated during 2009 to reflect the new vision – ‘Inventing the future of 
play’.
The LEGO Brand Framework is the essence of what the LEGO brand 
expresses and is presented in the following way:
To ensure clarity about what can be expected from the brand and to 
make sure that LEGO employees are clear about what is required to ful-
fil these expectations, it is essential that the brand promises are widely 
understood and strongly believed and lived.
The 4 brand promises capture the essence of the handshakes the 
LEGO Group wants to make with its consumers, employees, partners 
and the society at large; what to expect from the LEGO Group:
Play Promise: ’Joy of Building, Pride of Creation’
At the heart this promise is the joy and pride which the LEGO Group 
wants children to experience when exploring their creative potential with 
LEGO products and services; and the certainty among parents that this 
‘playful learning’ is developing the kind of skills and confidence that will 
prepare their children for the future.
The LEGO difference:
The unmistakable quality of the LEGO look, feel and design.
The interactive hands-on, minds-on LEGO play experiences.
People Promise: ’Succeed Together’
This promise defines the LEGO Group’s commitment that every em- 
ployee will experience the strong sense of purpose, spirit of collabora-
tion, creative adventure and execution excellence which characterize 
the LEGO Group at its very best.
The LEGO difference:
The positive and lasting impact on the future through playful learning
The highly stimulating and effective mix of LEGO creativity and execu-
tion excellence.
Partner Promise: ’Mutual Value Creation’
This promise defines the LEGO Group’s commitment to make working 
with the LEGO Group a mutually rewarding and value enhancing experi-
ence for every organization that the company seeks to partner with, 
whether customers, business partners or suppliers.
The LEGO difference:
The LEGO Group’s commitment to win:win partnership solutions.
Recognition that ‘Only the best is good enough’ applies to everyone the 
LEGO Group deals with.
Planet Promise: ‘Positive Impact’
This promise defines the LEGO Group’s commitment to care for the 
society that our children will inherit and to inspire and enable children 
to have a voice on the future society.
The LEGO difference:
The LEGO Group’s commitment to pioneer safety, support children’s 
right to grow, care for nature and have a respectful stakeholder dia-
logue on issues that count.
The endless possibilities of the LEGO products to be used for the ben-
efit of society – through inspiring and developing children.
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Governance strategy and stakeholders

14    The LEGO Group – Progress Report 2009      
System and management setup
SYSTEM AND MANAGEMENT SETUP
It is of high priority to Corporate Management that the LEGO business 
is operated responsibly and according to good corporate governance. 
An executive function with the responsibility of giving input on the stra-
tegic direction for Environmental, Social and Governance (ESG) activities 
was formed in late 2006. The department name is Corporate Govern-
ance & Sustainability and it reports to the Executive Vice President for 
the corporate functions.
Board of Directors
The Board of Directors consists of six members. Two of these are consid-
ered dependent on the company due to ownership. The Chairman and 
three other members of the Board are considered to be independent.
The rules of procedure of the Board of Directors are being reconsid-
ered on an annual basis. In order to ensure the continued development 
of the Board’s work, the Chairman of the Board conducts dialogues 
on the topic with the members of the Board of Directors during the 
year. A more formal Board self evaluation, based on a questionnaire, is 
conducted at regular intervals and took place in 2009. The results of the 
Board self evaluation were discussed by the Board and management, 
and a course of actions was agreed to seek continuous improvement.
Corporate Management
The Management Board consists of the President and CEO, Jørgen 
Vig Knudstorp and the CFO, Sten Daugaard. The Management Board 
together with the following four Executive Vice Presidents form Corpor- 
ate Management, the highest decision-making organ within the LEGO 
Group. The four Executive Vice Presidents are Christian Iversen, Corpor- 
ate Center, Mads Nipper, Markets & Products, Iqbal Padda, Global Sup-
ply Chain and Lisbeth Valther Pallesen, Community, Education & Direct. 
The Management Board refers to the Board of Directors.
Cross functional bodies
In order to ensure coordination and quick decision-making, the LEGO 
Group has set up four cross functional boards under Corporate Man-
agement with delegated decision power. The four boards are the Brand 
and Innovation Board, the Corporate Compliance Board, the Operations 
Board and the IT Board. Two of these boards are directly linked to the 
ESG work performed by the LEGO Group.
The Brand and Innovation Board sets the overall strategic direction 
of the LEGO brand and the development of new business ideas. The 
expectations towards the LEGO brand are handled in this board when 
it comes to strategic decisions.
The decisions on the strategic direction for Environmental, Social and 
Governance (ESG) activities are made by Corporate Management, 
whereas the Corporate Compliance Board on behalf of Corporate 
Management secures that the company is in compliance with the 
responsibility targets, company policies and standards and direction 
defined. The Corporate Compliance Board is headed by Christian 
Iversen, Executive Vice President, and members include the President 
and CEO, the CFO, the General Counsel and a high level representa-
tive from the quality department and the Corporate Governance & Sus-
tainability function.
Employees’ possibility to give input directly to executives
Employees generally consider the LEGO Group a very open and net-
work based organization where input from employees is very welcome. 
The President and CEO has an intranet blog where he shares thoughts 
and reflections in a dialogue with employees. The blog includes an 
opportunity for all employees to write an anonymous e-mail to him. Via 
the business integrity setup, a whistle blower possibility is also available 
for all employees. 
Furthermore management and employee representatives from all over 
the world meet annually in the Global Works Council to discuss the 
challenges facing the company.
Policies and standards
In 2009, a new LEGO policy framework was launched to simplify and 
clearly communicate the overall policies within which the LEGO Group 
does business. The framework consists of 11 corporate policies and a 
number of underlying corporate standards. To secure compliance with 
the corporate policies and standards, an annual review report is pre-
pared for internal use.
All relevant policies are available on www.LEGO.com/about us.
Lobbying
Lobby activities for the LEGO Group must be balanced to the benefit 
of all stakeholders based on the LEGO spirit and core values and must 
always be conducted in a transparent and professional manner.
The LEGO Group participates in toy related lobby activities in external 
associations with focus on critical standards, changes in legislation or 
other initiatives that may influence the LEGO Brand. 
The LEGO policy framework.   
Corporate Policies in the LEGO Group
Communication Policy
Environmental Policy
Finance Policy
Health & Safety Policy
IT Policy
Legal Policy
People & Culture Policy
Product Safety Policy  
Quality Policy
Responsibility Policy
Risk Management Policy

The LEGO Group – Progress Report 2009    15
SYSTEM AND MANAGEMENT SETUP
The LEGO Group has defined four main focus areas for lobby activi-
ties:
• Intellectual property rights
• Toy safety, including child health and safety
• Marketing to children
• Corporate responsibility
International and regional associations and initiatives in which the LEGO 
Group participates include the following:
• Toy Industries of Europe – TIE
• Toy Industry Association – TIA
• European Brand Organization – AIM
• World Federation of Advertisers - WFA
• European Committee for Standardization – CEN
• International Organization for Standardization – ISO
In the EU, the revised Toy Safety Directive was published in June 2009. 
The Directive has been strengthened in many ways, both in relation to 
the documentation required by manufacturers and in relation to en- 
suring the chemical safety of toys. It includes new and stricter rules on 
heavy metals and Carcinogenic, Mutagenic and Reprotoxic substances 
(CMRs). In accordance with the legislative framework for toys in the EU, 
the European Standards for Toy Safety must now be revised in order to 
adapt to the new Directive. This work is ongoing and the LEGO Group 
is actively involved as Chairman of the Technical Committee for Toy 
Safety in the European Committee for Standardization (CEN). The LEGO 
Group is also active in providing technical expertise for the revision of 
the standards. The standards for the mechanical and physical safety 
of toys must be revised within two years, and for the chemical aspects 
these standards must be revised within four years of the publication of 
the Directive. 
The LEGO Group has also been very active along with Toy Industries 
of Europe (TIE) and the European Commission in communicating the 
consequences of the new Directive to manufacturers and distributors 
both in the EU and in Asia. At present the LEGO Group holds the chair 
of the TIE.
In the US, the implementation of the Consumer Product Safety Improve-
ment Act has required that, on a continuous basis, the LEGO Group 
provides input to the Consumer Product Safety Commission through 
TIA and by itself in relation to the ongoing rulemaking process.
The LEGO Group has consistently focused on ensuring that the toy 
safety rules set as high standards as possible while ensuring that new 
rules can also be implemented. The continued focus by all stakehold-
ers on toy safety requires the LEGO Group to consistently share its view 
on this crucial topic for the toy industry.
System and management setup

16    The LEGO Group – Progress Report 2009      
ASSURANCE STATEMENT
Assurance Statement for the LEGO Group’s stakeholders from the independent auditor
We have reviewed the consolidated non-financial data of the LEGO 
Group’s Progress Report for 2009 as expressed on pages 4 and 19-20.
Criteria for preparation of the Progress Report’s non financial data
The criteria for preparation of the Progress Report’s non-financial data 
are the accounting policies described on pages 17-18. These contain 
information concerning which of the Group’s business areas and activi-
ties are included in the reporting, types of data, and Management’s 
reasons for choosing the data included. The non-financial data are fac-
tored in accordance with the accounting policies described on pages 
17-18.  
Delegation of responsibility
Company Management is responsible for preparing the Progress 
Report’s non-financial data, including for establishing registration and 
internal control systems with a view to ensuring reliable reporting, speci-
fying acceptable reporting criteria as well as choosing data to be col-
lected. Our responsibility is, on the basis of our work, to express an 
opinion on the 2009 Progress Report’s non-financial data.
Scope of our work 
We have planned and completed our work in accordance with the 
International Auditing Standard ISAE 3000 (assurance engagements 
other than audits or review of historical financial information) for the pur-
pose of obtaining limited assurance that the non-financial data for 2009 
presented on pages 4 and 19-20 have been computed in accordance 
with the stated criteria.
The obtained assurance is limited compared to that of an engagement 
with reasonable assurance. Our work has thus - based on assessment 
of materiality and risk - comprised inquiries regarding applied registra-
tion systems and procedures, review of data used in connection with 
preparation of the 2009 non-financial data, and review of underlying 
documentation, including review of whether the scope of the 2009 non-
financial data complies with described accounting policies for the 2009 
non-financial data. During the review process, we have visited entities in 
Billund (Denmark), Enfield (USA), Kladno (Czech Republic) and Nyíregy-
háza (Hungary).
Conclusion regarding the 2009 Progress Report’s non-financial data  
Based on our review, nothing has come to our attention causing us 
not to believe that the consolidated non-financial data of the Progress 
Report of the LEGO Group for 2009 have been presented in accord-
ance with the stated criteria.
Copenhagen, 24 February 2010
PricewaterhouseCoopers
Statsautoriseret Revisionsaktieselskab
Henrik Kragh 
Birgitte Mogensen
State Authorised Public Accountant 
State Authorised Public Accountant

The LEGO Group – Progress Report 2009    17
SCOPE AND CALCULATION METHOD
Scope and calculation method 
The data presented in this Progress Report comprise the LEGO Group 
based on the legal boundaries for the Group. More information on this 
can be found in the Annual Report 2009 for the LEGO Group. The report 
covers the period 1 January 2009 to 31 December 2009.
The selection of data is based on an assessment of data of special 
importance to the LEGO Group’s long term earnings. Moreover, in the 
LEGO Group’s opinion, the indicators addressed are also of interest to 
the LEGO Group stakeholders when it comes to follow-up on Environ-
mental, Social and Governance (ESG) issues related to delivering on 
the four promises given. The indicators will on an ongoing basis be 
challenged when new indicators or measurement methods become 
available.
Data have been calculated by consolidating data for the parent com-
pany (LEGO A/S) with data for all subsidiaries. The consolidation is 
based on data of a uniform nature and calculated under the same 
methods. However, data relating to health and safety only include data 
from plants with more than 100 employees. Similarly, environmental data 
only comprise production facilities. The measurement method remains 
unchanged from last year.
The manufacturing setup changed during 2008 and now includes sites 
in the Czech Republic, Hungary and Mexico which makes it difficult to 
compare 2009 data with previous years. Data measurement methods 
and the basis of calculations are addressed below; however please 
see the Annual Report 2009 for a description of measurement methods 
relating to financial results.
Play Promise
Number of product recalls
Product recalls are calculated as launched products recalled from the mar-
ket due to product safety issues and calculated per stockkeeping unit.
Average monthly unique visits on LEGO.com/parents Index
The number of unique visitors is calculated as the number of year to 
date average monthly unique visitors according to the counter on the 
page.
Consumer Complaint Call Rate
The consumer complaint call rate is calculated as the number of con-
sumer complaints received relating to products launched in the year 
of reporting as a percentage of the number of products sold in the 
launch year. Due to the substantial Christmas trade, and in order to 
give a true and fair view, complaints received in January of the fol-
lowing year are also included in the calculation, corresponding to a 
13-month period.
Net Promoter Score Index
In connection with consumer contacts and the LEGO Group’s online 
sales, randomly selected consumers are asked how likely they are, on 
a scale of 0-10 (10 = best), to recommend the purchased product or 
service to others. The development in promoters - level 9 and 10 minus 
the development in the detractors - level 6-0 is calculated and is shown 
in this Progress Report with 2005 as index basis.
People Promise
Number of employees
Comprises all employees paid by the LEGO Group, including permanently 
employed staff, contractually employed staff and trainees. The statement 
is calculated at the end of the year and measured as headcount.
Job classification
Senior Management comprises all Vice Presidents or levels above. 
Management comprises Senior Directors and Directors. The Directors+ 
group of employees consists of Senior Management and Management. 
Other employees are included in the group “Others”.
Rate of employee turnover
Employee turnover is measured as the number of permanent em- 
ployees who have voluntarily left the LEGO Group during the report-
ing period compared to the average number of permanent employees 
during the reporting period. The average is calculated on the basis of 
monthly data. The number of new employments and re-employments 
as well as dismissals is also stated.
Sick leave
Sick leave is calculated as time lost due to the employees’ own illness. 
The sick leave is calculated as the number of absence hours as a per-
centage of the total number of working hours excluding holidays and 
non-business days.
Injury rate per million working hours
The number of occupational injuries is calculated as the number of 
occupational injuries resulting in at least one day’s absence following 
the day of the injury. The rate of occupational injuries is calculated per 
million working hours.
Absence rate due to injuries
The number of absence hours as a consequence of occupational inju-
ries. The rate is calculated per 1,000 working hours, and the absence is 
calculated as from the day following the injury.
Percentage of employees working at OHSAS 18001 certified sites
The percentage is calculated as employees working in certified sites 
(certified by an external audit company) as a percentage of all employ-
ees working in the LEGO Group. 
Directors+ promotions (externally recruited or internally appointed) of 
female employees
The number of female Directors+ promotions is shown as a percentage 
of all promotions into the Directors+ group of employees. 
Employee Pulse
At the end of the reporting year, a survey, the Employee Pulse, is car-
ried through in which all employees are asked to state their opinion as 
regards the LEGO Group as a workplace. The questions cover a wide 
range of the areas included in the LEGO Group strategy and measure 
the employees’ motivation and commitment. The results are used to 
identify significant target areas at Group and departmental level.

18    The LEGO Group – Progress Report 2009      
SCOPE AND CALCULATION METHOD
Partner Promise
Percentage of Directors+ at LEGO sites trained in business integrity
The percentage is calculated as Directors+ having completed the 
e-learning program in Business Conduct as a percentage of all Direc-
tors+ in the LEGO Group.
Audits conducted at LEGO® sites
The number of audits conducted at LEGO sites is calculated as third 
party audits connected to the certification process or voluntary Code 
of Conduct audits. The number of significant discrepancies is reported 
and briefly described. These form the basis for continuous work on 
improvements.
Data relating to suppliers and business partners
The number of suppliers includes the LEGO Group’s active direct sup-
pliers calculated at the end of the reporting period. The number is 
broken down into direct suppliers and extended line suppliers. Direct 
suppliers deliver bill of material components whereas extended line 
suppliers primarily deliver merchandise. Suppliers do not include in- 
direct purchases. The number of suppliers who have been audited is 
calculated as the number of suppliers visited with a view to formalised 
monitoring and reporting of compliance with quality standards or Code 
of Conduct.
The number of significant discrepancies is reported and briefly 
described. These form the basis of the continued dialogue with the 
suppliers in order to continuously work on improvements.
Customer Pulse
To obtain an evaluation of the past year’s cooperation, retail customers 
are asked to give their perceived evaluation of the LEGO Group during 
January and February of the following year. The survey is executed via 
the web. The survey is used to track performance within the following 
five categories: 1) Products - where questions are asked regarding in- 
novation, packaging, assortment size etc. 2) Marketing – where perform-
ance is tracked on the effectiveness of customer, in-store and promo-
tion marketing etc. 3) Service – where customers rate the LEGO Group 
regarding e.g. order lead-time, quality in delivery, on-time delivery etc. 4) 
Partnership – where performance is tracked on joint planning, informa-
tion sharing etc. 5) Value – where questions related to stock turns, trad-
ing terms etc. are in focus.
The consolidated data are shown in this Progress Report with 2005 as 
index basis.
Planet Promise
Water consumption
Water consumption is calculated as the quantity of water supplied to 
the LEGO Group.
Energy consumption
Energy consumption is calculated as the total energy in the form of 
electricity and heating supplied to LEGO Group sites with production. 
The energy efficiency index is calculated as the rate between value add 
and energy consumption. Value add defined as revenue minus net val-
ue of purchased goods and services (please see figure on page 10).
Raw materials
Raw materials are calculated as plastic granulate used in manufactur-
ing.
Waste
Waste is calculated as the recorded quantities of waste disposed from 
the LEGO Group. The recycled waste percentage is calculated as the 
recycled quantities of waste disposed compared to total quantities of 
waste disposed.
Scope and calculation method

The LEGO Group – Progress Report 2009    19
DATA OVERVIEW AND NOTES
Data overview and notes
Target
Note
2009
2009
2008
Play Promise
Number of product recalls
0
•
1
0
Average monthly unique visits on LEGO.com/parents Index
>=110
•
123
100
Consumer Complaint Call Rate
<= 0.120%
•
0.093%
0.123%
Net Promoter Score Index
>= 120
•
126
120
People Promise
1
Number of employees (headcount end of year) 
8,616
7,337
1
Female
45.3%
46.7%
1
Male
54.7%
53.3%
Average age
36.7
38.2
2
Rate of employee turnover
10.4%
10.8%
Sick leave
<= 3.5%
•
2.9%
3.0%
3
Number of accidents with absence
61
35
4
Injury rate per million working hours
<= 6.0
•
4.8
4.4
Absence rate due to injuries
<= 0.3
•
0.51
0.25
Percentage of employees working at OHSAS 18001 certified sites
>=80%
•
94%
45%
Directors+ promotions (externally recruited or internally appointed)  
of female employees
>= 25%
•
20%
18%
Employees Pulse
- Work-life balance range to global scorecard (LEGO EEI)
+0
•
+3
+2
- Motivation & Satisfaction range to global scorecard (LEGO EEI)
+10
•
+11
+10
Partner Promise
Percentage of Directors+ at LEGO sites trained in business integrity
>= 25%
•
69%
0%
5
Number of audits conducted at main LEGO sites
23
9
5
Number of major quality non-conformities found at main LEGO sites
0
•
0
4
5
Number of major EHS non-conformities found at main LEGO sites
0
•
0
0
5
Number of major CoC non-conformities found at main LEGO sites
0
•
1
0
6
Total number of direct and extended line suppliers
231
196
Number of quality audited suppliers
2
23
7
Number of CoC audited suppliers
48
18
Percentage of active direct and extended line suppliers audited 
with production in high risk and intermediate risk countries
= 100%
•
96%
-
Number of major quality non-conformities found at suppliers
3
20
8
Number of major CoC non-conformities found at suppliers
36
16
Major quality non-conformities found in 2008 at direct and extended 
line suppliers solved
>=50%
•
100%
-
Major CoC non-conformities found in 2008 at direct and extended  
line suppliers solved
>=50%
•
94%
-
Customer Pulse
- Overall Satisfaction
119
119
- Products
106
106
- Marketing
107
105
- Service
117
117
- Partnership
111
110
- Value
113
112
Planet Promise
Raw material, plastic, 1,000 tons 
35
20
Water consumption, 1,000 m³  
116
68
Total energy consumption in production, GWh
155
108
Energy Efficiency Index
>=100
•
127
135
Waste, tonnes
7,970
3,057
Recyled waste (of total registered waste)
>=80%
•
88%
69%
• Target met       • Target not met

20    The LEGO Group – Progress Report 2009      
DATA OVERVIEW AND NOTES
Note 1, Total number of employees
2009
2008
Female
3,900
3,425
Male
4,716
3,912
Total
8,616
7,337
Asia
160
151
America, Australia and New Zealand
2,245
1,280
Europe
6,211
5,906
Total
8,616
7,337
Senior management
46
40
Management
302
279
Other
8,268
7,018
Total
8,616
7,337
Note 2, New hires, rehires and terminations
2009
2008
New hires and rehires
1,780
1,154
Takeover of plants
0
2,099
Terminations
515
700
The number of employees dismissed by the LEGO Group in 2009 has been cal-
culated at 180 (2008: 169). Notice concerning major structual changes will be given 
in due time as it has been demonstrated in ealier years. In late November notice 
was given to 54 hourly paid employees (the lay-offs will have influence on next 
year’s figure).
Note 3, Number of accidents
2009
2008
Americas
7
0
Europe
54
35
Total
61
35
Note 4, Injury rate per million working hours
2009
2008
Americas
2.2
0,0
Europe
5.6
5.2
Total
4.8
4.4
Note 5, Third party audits for main LEGO sites, 2009
OHSAS 
18001
ISO 
9001
ISO 
14001
Code of  
Conduct 
Audits
Billund, Denmark
2
1
1
1
Kladno (MC), Czech Republic
1
1
1
1
Kladno (Production), Czech Republic
1
1
1
1
Nyíregyháza, Hungary
1
1
1
1
Monterrey, Mexico
1
1
1
0
Hong Kong, China
1
N/A
N/A
N/A
Slough, UK
N/A
N/A
1
N/A
Enfield, USA
N/A
N/A
0
N/A
Munich, Germany
N/A
N/A
1
N/A
Total number of audits
7
5
7
4
Total number of major non-con-
formities
The one major non-conformity on Code of Conduct can be summa-
rized as:
- 1 related to working hours
Data overview and notes
Note 6, Total number of suppliers split on Code of Conduct risk,  
end of 2009
Direct
Extended
Total
China/Hong Kong
10
29
39
Mexico
4
4
Turkey
1
1
Total high risk countries
15
29
44
Czech Republic
45
45
Hungary
13
13
Italy
3
3
Japan
1
1
Korea
1
1
Poland
4
4
Romania
1
1
Slovakia
1
1
Taiwan
1
1
USA
20
20
Total intermediate risk countries
89
1
90
Austria
4
4
Belgium
1
1
Canada
1
1
Denmark
51
51
France
1
1
Germany
16
16
United Kingdom
3
3
The Netherlands
4
4
Switzerland
5
5
Spain
1
1
Sweden
10
10
Total low risk countries
97
0
97
Total
201
30
231
Only active suppliers with production in high and intermediate risk 
countries are audited, equal to 44 high risk and 22 intermediate 
risk vendors. 16 of the high risk vendors are audited in the ICTI Care 
process. A total of 48 audits conducted for the LEGO Group by third 
party auditor. Two suppliers were not audited according to plan as a 
planned exit of one supplier was postponed, and a new supplier was 
accepted late 2009.
Note 7, Total number of LEGO Group Code of Conduct audited sup-
pliers in 2009
High risk countries
26
Intermediate risk countries
22
Total number of audits
48
Note 8, Total number of major non-conformities found in LEGO 
Group Code of Conduct audits, 2009
High risk countries
26
Intermediate risk countries
10
Total number of audits
36
The audits create a dialogue with the suppliers, and the major non-
conformities set the main focus for the continuous improvement proc-
ess.
The 36 major non-conformities for the Code of Conduct area can be 
summarized as:
- 17 related to EH&S
- 10 related to working hours 
-  4 related to wages
-  2 related to management system
-  2 related to coercion and disciplinary actions
-  1 related to freedom of expression
Certifications
0
0
0
1

The LEGO Group – Progress Report 2009    21
UN GLOBAL COMPACT OVERVIEW
UN Global Compact overview
Area
Principle
Reference to
GRI indicator
Page
Human rights
1 – Businesses should support and respect the protection of internationally pro-
claimed human rights within the area in which it exerts influence
HR2: 
LA7:
LA13:
SO5:
PR1:
8-11, 19-20
8-11, 19-20
19-20
14-15
5, 8-11, 12-13
2 – Businesses should make sure they are not complicit in human rights abuses
HR2:
SO5: 
8-11, 19-20
14-15
Labour
Standards
3 – Businesses should uphold the freedom of association and the effective rec-
ognition of the right to collective bargaining
HR2: 
LA5: 
SO5:
8-11, 19-20
19-20
14-15
4 – Businesses should support the elimination of all forms of forced and 
compulsory labour
HR2:
SO5:
8-11, 19-20
14-15
5 – Businesses should support the effective abolition of child labour
HR2:
SO5:
8-11, 19-20
14-15
6 – Businesses should support the elimination of
discrimination in respect of employment and occupation
HR2:
LA2:
LA13:
SO5:
8-11, 19-20
19-20
19-20
14-15
Environment
7 – Businesses should support a precautionary approach to environmental 
challenges
EC2: 
SO5:
5, B 24
14-15
8 – Businesses should undertake initiatives to promote greater environmental
responsibility
EN1:
EN4: 
EN8:
EN22:
SO5:
19-20
5, 8-11, 19-20
19-20
8-11, 19-20
14-15
9 – Businesses should encourage the development and diffusion of 
environmentally friendly technologies
SO5:
14-15
Anti-
Corruption
10 – Businesses should work against corruption in all its forms, including extortion
and bribery
SO3: 
SO5:
B 38, 8-11, 19-20
14-15
B = The LEGO Group’s magazine The Brick
By issuing this annual Progress Report, the LEGO Group expresses its continued support to the UN Global Compact. The LEGO Group recognizes 
the importance of integrating Environmental, Social and Governance (ESG) issues into the way business is done. In this Report, the LEGO Group 
shows the company’s progress towards this integration of ESG issues into its core business.
Jørgen Vig Knudstorp
President and CEO
According to guidelines from the UN Global Compact office, the LEGO Group summarizes briefly below references in this year’s report to give a 
quick overview:

22    The LEGO Group – Progress Report 2009      
GRI G3 OVERVIEW
 
Page
Economic indicators
EC1  Economic value generated in 2009  . . . . . . . . . . . . . .  
4
EC2  Risks and opportunities due to climate change  . .  
5, B 24
EC3  Defined benefit pension plan obligations  . . . . . . . .  
A 32
Environmental indicators
EN1  Consumption of materials  . . . . . . . . . . . . . . . . . . . . . . .  
19-20
EN4  Energy consumption  . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
5, 8-11, 19-20
EN8  Water consumption  . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
19-20 
EN22  Total waste disposal  . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
8-11, 19-20
Social indicators – Labour standards
LA1  Total workforce  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
19-20
LA2  Employee turnover  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
19-20
LA5   Notice periods prior to significant structural changes 
19-20
LA7  Rates and number of occupational injuries  . . . . . .  
8-11, 19-20
LA13  Breakdown of employees by sex etc.  . . . . . . . . . . . .  
19-20
Social indicators – human rights
HR2   Human rights in relation  
to suppliers and business partners  . . . . . . . . . . . . . .  
8-11, 19-20
Social indicators – society
SO3  I nformation on anti-corruption policies  
and procedures  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   8-11, 19-20, B 38
SO5  Views of lobbying  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
14-15
Social indicators – product liability
PR1   Impacts on products  
on customer health and safety  . . . . . . . . . . . . . . . . . .  
5, 8-11, 12-13
A = The LEGO Group’s Annual Report 2009
B = The LEGO Group’s magazine The Brick
The above-mentioned indicators are fully or partly reported according 
to GRI G3.
Global Reporting Initiative (GRI) G3 overview
Application Level of the LEGO Group 2009: Self-declared Level C 
GRI  Report content/indicator  
Page
Strategy and analysis 
1.1  
 Statement from Corporate Management  
about vision and strategy . . . . . . . . . . . . . . . . . . . . . . . .  
5
1.2  
Description of key impacts, risks and opportunities. 
5, 6-7, 12-13
Organizational profile
2.1  
Name of the organization . . . . . . . . . . . . . . . . . . . . . . . .  
B 3
2.2  
Primary brands, products and services . . . . . . . . . . .  
B 3
2.3  
Organizational structure and company structure  .  
14-15
2.4  
Location of headquarters . . . . . . . . . . . . . . . . . . . . . . . .  
B 3
2.5  
 Countries in which the organization operates . . . . .  
B 3
(See world map in The Brick)
2.6  
Nature of ownership and legal form . . . . . . . . . . . . . .  
B 3
2.7  
Markets served . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
B 3
2.8  
Scale of the reporting organization  . . . . . . . . . . . . . .  
19-20
2.9  
Significant changes  . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
17-18 
Report parameters
3.1  
Reporting period  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
3, 17-18
3.2  
Date of most recent report  . . . . . . . . . . . . . . . . . . . . . .  
Cover
3.3  
Reporting cycle  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
Cover, 21
3.4  
 Contact point for questions regarding the report  
or its contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
3
3.5  
Process for defining report content  . . . . . . . . . . . . . .  
Cover
3.6  
Boundary of the report  . . . . . . . . . . . . . . . . . . . . . . . . . .  
17-18
3.7  
 Specific limitations on the scope or boundary  
of the report  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
17-18
3.8  
Basis for reporting on subsidiaries etc.  . . . . . . . . . . .  
17-18
3.9  
 Data measurement methods and the bases  
of calculations  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
17-18 
3.10  Changes in measurement methods  . . . . . . . . . . . . .  
17-18
3.11  
 Significant changes in the scope,  
boundary or measurement methods  . . . . . . . . . . . .  
17-18
3.12  GRI content index  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
22
3.13  Verification  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
Cover, 16
Governance, commitments and engagement
4.1  
Governance structure  . . . . . . . . . . . . . . . . . . . . . . . . . . .  
14-15 
4.2  
Chairman of the Board and President and CEO  . .  
14-15, A 5
4.3  
Independent members of the Board  . . . . . . . . . . . . .  
14-15
4.4  
 Mechanisms for employees to provide  
recommendations or direction to the Board . . . . . .  
14-15
4.8  
 Internally developed values,  
code of conduct or principles  . . . . . . . . . . . . . . . . . . ..  
8-11, 12-13
4.9  
Sustainability procedure and management  . . . . . .  
14-15
4.10  Evaluation of the Board’s own processes . . . . . . . . .  
14-15
4.13  Selected memberships in associations  . . . . . . . . . .  
14-15
4.14  Stakeholder groups  . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
12-13
4.15  Identification and selection of stakeholders  . . . . . .  
12-13
4.16  Approaches to stakeholder dialogue  . . . . . . . . . . . . .  
12-13
4.17  Key topics and concerns  . . . . . . . . . . . . . . . . . . . . . . . .  
 Cover, 3

The LEGO Group – Progress Report 2009    23
GRI OVERVIEW

The LEGO Group
Aastvej
7190 Billund
Tel.: +45 79 50 60 70
www.LEGO.com
G R C . D K
www.LEGO.com
Progress Report 09
Read about the Annual Report 
and the magazine The Brick on the back cover
The LEGO Group
www.LEGO.com
The Brick    
Annual Magazine 2010
THEME: 
THE DIGITAL 
LEGO BRICK 
FIGHTING CORRUPTION ...
VISITING LEGO EMPLOYEES 
 IN FIVE COUNTRIES
LEGO STAR WARS 
– THE SUCCESS CONTINUES 
BUILD YOURSELF  
A BETTER WORKPLACE 
10-ton fire engine  
reappears as 165 bricks
Read more about the Annual Report and the Progress Report on the back cover
RQWKHEDFNFRYHU
Progress Report
In the Progress Report you will ﬁnd detailed information on the 
progress of the LEGO Group’s work within environmental, social and 
governance (ESG) areas in 2009. It includes data on for example 
consumer complaint rates, Code of Conduct audits, employee 
injury rate and much more.
The Progress Report also serves as the annual communication on 
progress required by UN Global Compact.  
http://www.LEGO.com/eng/info/
Annual Report
In the Annual Report you will ﬁnd detailed information on  
the LEGO Group’s ﬁnancial results in 2009.
http://www.LEGO.com/eng/info/
The Brick
The Brick is an annual magazine designed to supplement the two
reports – Annual Report and Progress Report. It oﬀers a view into
the many ways in which the LEGO Group interacts with all its 
stakeholders, and in an easy-to-read way, it follows up on some of 
the data in the Progress Report.
http://www.LEGO.com/eng/info/
www.LEGO.com
Annual Report
The LEGO Group
Read about the Progress Report 
and the magazine The Brick on the back cover.
09