Progress Report 2011
The LEGO Group

Progress Report 2011
The LEGO Group

4 
Welcome to  
Progress Report 2011
This Progress Report 2011 and the Annual Report 2011 constitute the 
reporting commitments of the LEGO Group in 2011.
The purpose of the Progress Report 2011 is to provide our stakeholders 
with a fair and balanced picture of our sustainability efforts in 2011. The 
report provides an overview of our activities, practices, goals and results.
The Progress Report 2011 also serves as our annual communication 
on progress in sustainability, as required by the United Nations Global 
Compact. The report is the statutory statement on Corporate Social 
Responsibility according to section 99a of the Danish Financial State-
ments Act.
The report is developed in accordance with the main reporting prin-
ciples of the Sustainability Reporting Guidelines from the Global Re-
porting Initiative (GRI). And we are inspired by the voluntary standard 
AA1000 Accountability Principles drawn up by the Institute of Social and 
Ethical Accountability (AccountAbility).
The basis of the report, the scope, and the materiality determination are 
all based on a dialogue with main stakeholders about issues that are 
material to them.
For the 2011 report, we have applied the same model as we have used 
during the last three years for selecting sustainability content. 
Read more about this at 
http://aboutus.lego.com/sustainability

5
Table of 
contents
Setting the scene
Our Material Progress 2011
10	
Our sustainability issues
12	
Sustainable play
18	
Environment
22	 Climate
26	 Employees
32	 Stakeholder dialogue
36	 Human Rights
39	 Governance
41	
The LEGO Foundation
Our 2011 numbers and 
supporting information
45	
2011 numbers and comments
49	
Assurance statement and GRI
04	 Welcome to Progress Report 2011
05	 Table of contents
06	 2011 highlights
08	 Sustainability – the LEGO way
09	 Message from the CEO
Progress Report 2011 is published for the LEGO 
Group by Corporate Affairs and Operate A/S
Editor in chief: Charlotte Simonsen,  
Senior Director, Corporate Communication, 
media@lego.com
 
Contributor: Operate A/S
 
LEGO A/S
Aastvej 1
DK-7190 Billund, Denmark
Telephone: +45 79 50 60 70
CVR-no: 54 56 25 19
Residence: Billund
Reporting year: 1 January – 31 December 2011
 
Design: Operate A/S
Print: KLS Grafisk Hus A/S
Paper: Scandia 2000 and Gallerie Art Silk. 
Copies: 5,000
 
The collective CO² emission of 5,000 copies is 
0.7 tonnes, which will be compensated according 
to the UN Convention. Currently, the compensa-
tion goes to a wind farm in India.
Read more about our sustainability work here: 
http://aboutus.lego.com/sustainability
LEGO, the LEGO logo, the Brick configuration 
and the Minifigure are trademarks of the LEGO 
Group. © 2012 The LEGO Group.
Net Promoter, NPS and Net Promoter Score 
are trademarks of Satmetrix Systems Inc, 
Bain & Company and Fred Reichheld.
No. 001
KLIMA-NEUTRAL
TRYKSAG

Product 
recalls
In 2011, the LEGO Group once again 
reached its target of 0 product recalls. 
We calculate product recalls as launched 
products recalled from the market due to 
product safety issues. Product recalls are 
calculated per stock keeping unit. 
0
Injury rate
2.0 2.1
1.8
Target 2011
Result 2011
Target 2012
We calculate the injury rate as the 
number of occupational injuries per 
million hours that result in at least one 
day’s absence following the day of the 
injury. 
2011 highlights
Building on the success of previous years, we set our-
selves a series of ambitious targets for 2011. We have 
made progress, but there are also targets we did not 
meet.
Because the safety of children is our primary concern, 
we have a goal of zero product recalls. All parts of the 
LEGO Group are focused on this goal, and we are 
proud to have reached it again in 2011. 
We have an ambitious vision of reducing the amount 
of waste we produce and increasing the amount of 
waste we recycle. In 2011, we recycled 88% of the total 
waste, compared to our target of 85%. 
A high degree of energy efficiency is important for us 
as it makes good sense for the climate, the environ-
ment and the bottom line. We have made great strides 
in previous years and despite improving energy effi-
ciency by a further 2.4%, we did not meet our ambitious 
target of 5% in 2011. Maintaining improvements at the 
same rate has been difficult and is expected to remain 
so. As a consequence, we have reduced our target for 
2012 to 2.5%.
Recycled 
waste
as percentage of total  
registered waste
Target 
2011
Result 
2011
Target 
2012
88
85
0
Our recycled waste 
percentage shows the 
recycled quantities of 
waste compared to total 
quantities of waste. 
6

Read more at 
http://aboutus.LEGO.com/sustainability
We have been working for years towards our 2015 tar-
get to be among the top ten companies for employee 
health and safety. In 2011 we achieved an all-time low 
injury rate of 2.1, but just missed our ambitious target 
of 2.0. 
Moreover, we have seen a considerable fall in the 
number of hours that employees are absent because 
of illness, well within our target. 
Motivation and commitment among LEGO employees 
was again at a very high level in 2011, which is a key 
factor in reaching our goals. We are working to ensure 
diversity in many dimensions, but failed to meet our 
target for the percentage of females promoted to di-
rector levels and above. 
Female 
directors+ 
promotions
Target 
2011
Result 
2011
Target 
2012
30
23
0
We did not reach our 
target of ensuring 
that at least 30% of 
promotions to top 
management levels 
went to females.
Consumer complaint call rate
The consumer complaint 
call rate is the number 
of consumer complaints 
received relating to 
products launched 
in 2011 as a parts per 
million (ppm) of the 
number of products sold 
in the launch year. 
Target
2011
Result
2011
Target 
2012
0
100
200
300
400
500
600
700
800
Sick leave
Sick leave is the number 
of hours lost due to 
the employees’ own 
illness calculated as a 
percentage of the total 
hours worked.
Target
2011
Result
2011
Target 
2012
0.0
0.5
1.0
1.5
2.0
2.5
3.0
Energy efficiency improvement
We set a high target 
for 2011. We calculate 
the energy efficiency 
improvement as the 
rate between energy 
consumption and raw 
materials used.
Target
2011
Result
2011
Target 
2012
0
1
2
3
4
5
  7

8 
Mission
Vision
Promises
Spirit
Values
Inspire and develop the builders of tomorrow
Inventing the future of play
Play Promise
Joy of building. Pride of creation
Partner Promise
Mutual value creation
Planet Promise
Positive impact
People Promise
Succeed together
Only the best is good enough
Imagination    -    Creativity    -    Fun
Learning    -    Caring    -    Quality
It is deeply embedded in the values of the LEGO 
Group to leave a positive impact on our surroundings. 
We are in the business of play and our vision is to 
invent the future of play. Children are our role mod-
els. They reinvent the world and themselves in it over 
and over again, surprising themselves and others by 
what they can create and do. We want to leave them a  
future that will enable them to achieve their full hu-
man potential.
Since our foundation, we have been working con-
sciously and deliberately with sustainability, signing 
the UN Global Compact in 2003 and striving to ad-
dress its ten principles. In 2006 we issued our first 
sustainability report and have since tracked our pro-
gress every year.
Our efforts in the area of sustainability follow on from 
the way we run our business – ‘The LEGO way’, where 
only the best is good enough. In 2009 we made four 
main promises to our stakeholders. These set the di-
rection for everything we do, also when it comes to our 
sustainability efforts. 
By delivering on our promises we are well on our way 
to achieving our vision of ‘Inventing the future of play’.
When we defined the sustainability agenda in late 
2009, we found it important to also define a few, fo-
cussed overall targets primarily with the purpose of 
setting the direction for the organisation. 
Sustainability - the LEGO way
Our overall targets
0 product recalls
0 waste
Support learning for 101 million children
Minimum 100% renewable energy
Top 10 on employee health and safety
The four promises are defined as part of our LEGO® Brand Framework:
You can read more about our targets at 
http://aboutus.LEGO.com/sustainability

9
The LEGO Group achieved a 
record-breaking profit for 2011. It 
is essential for us to create good 
financial results in order to secure 
the health of the company. We can 
only do so by continuously working to develop our 
sustainability efforts, while striving towards our Planet 
Promise of leaving a positive impact. 
Since we were established, it has been of the utmost 
importance for our owners to create value for all 
stakeholders: first and foremost for our core target 
group, consumers who experience the unique, fun 
and developing play experience when engaging with 
our products; employees who can put their skills and 
creativity into play in the workplace; customers and 
other partners with whom we jointly create mutual 
value; and the environment surrounding us whether it 
is by reducing greenhouse gas emissions or working 
to find better solutions to how we design, produce 
and distribute our products.
We believe that the most important positive impact 
we as a company have is through our products. 
LEGO® products offer children something special 
on top of being a great play material. They offer 
systematic creativity. The steady evolutionary 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 sustainable, based on 
their long durability, and a compatibility that goes 
back more than 50 years.
The sustainability ambitions we have set out to reach 
therefore also centre on our core products and their 
impact from purchase of raw materials, to design and 
production, to distribution and to the play experience 
they bring to children of all ages.
For most sustainability areas we have made good 
progress during the past year, for example in waste 
and employee satisfaction. However, we have set high 
ambitions, and not all targets have been reached. 
This is the case within gender diversity and injury 
rates. Thus, there is no time for complacency. 
As with everything we do, our sustainability ambitions 
are based on our company spirit: ‘Only the best is 
good enough’. Therefore, we will continue to set high 
ambitions in order to increase our positive impact. 
In 2011 we started a journey of creating an even more 
adaptable LEGO Group, which will also makes us a 
more sustainable business. This change continues 
into 2012 and will have great implications for most of 
our employees as well as many stakeholders. We did 
this in order to work more effectively when address-
ing the five adaptive challenges facing us. These are: 
globalisation with a particular focus on Asia, digitali-
sation, marketing integration and core innovation. Our 
Planet Promise will remain in focus as we tackle these 
challenges.
With this Progress Report, we hold ourselves account-
able to our stakeholders and report on how we have 
delivered on the promises we have made. Business 
acumen and prudence are prerequisites for long-
term respect, recognition, and success in society. We 
have a well-designed and well-executed corporate 
governance in place which should help to ensure 
that, in addition to advancing on our own sustainabil-
ity targets, we also live up to our commitment to the 10 
principles of the UN Global Compact. We signed the 
Compact in 2003 as the first company in the industry 
and continue to support this initiative.
In 2012, we celebrate the 80th anniversary of the LEGO 
Group. In the years to come, we will keep pursuing our 
vision of inventing the future of play and do so in a 
balanced way that supports long-term sustainability. 
Succeeding in that will be the foundation for our suc-
cess in the coming 80 years.
Message from the CEO
Jørgen Vig Knudstorp
President and CEO

10 
In 2011 we have changed our reporting structure from reporting 
through our value chain in 2010, to this year reporting on eight 
sustainability issues relevant to our business. We believe this 
structure improves the transparency of our sustainability efforts. 
The way we go about our daily business and our strategic 
decisions impact all these issues. The eight sustainability issues 
will help you navigate through this report. 
Sustainable 
play
Stakeholder
dialogue
Human rights
Environment
Environment, pages 
18-21. In the LEGO 
Group we want to leave 
a positive impact on 
the environment. Focus 
is on resources, as this 
has vital importance for 
future environmental 
demands. 
Stakeholder dialogue, pages 
32-35. We engage with our 
stakeholders with respect, lis-
tening and engaging in an open 
and honest dialogue on issues 
that matter to our stakehold-
ers in order to meet or exceed 
their expectations. We have a 
responsibility that goes beyond 
the value chain of our products. 
Sustainable play, pages 12-17. We have 
strong opinions about Play. We believe that 
the LEGO Group should produce and market 
high quality products that last for generations 
and are safe online and offline. It is about 
continuing to develop a systematic approach 
to creativity and play to enhance learning 
and to help pass on the joy of play from 
generation to generation. 
Human rights, pages 36-38. We actively take 
part in the promotion of internationally agreed 
human rights. We fully acknowledge that we 
have a responsibility to ensure respect for 
human rights in our operations. Human rights 
align well with many of our core values and we 
made a formal commitment to human rights by 
signing the UN Global Compact in 2003. 
Our sustainability issues

11
Climate
Governance
The LEGO 
Foundation
Employees
Governance, pages 39-40. 
We maintain professional 
management of our company, 
including a strong and com-
petent board of directors in 
line with leading management 
practices, also with regard to 
good corporate governance. 
Employees, pages 26-31. We strive to 
improve the well-being, job satisfaction 
and development of our employees, 
while recruiting, welcoming and 
integrating new employees to our 
organisation. We recognise the rapid 
growth of our business has only been 
made possible by the skill, dedication 
and commitment of our people.
Climate, pages 22-25. Our most important 
stakeholders are children. They have a 
right to a healthy and rich environment 
both now and in the future. We acknow-
ledge our contribution to man-made 
climate change, and are concerned about 
the consequences. We are therefore 
focused on saving energy at production 
sites and offices, and are working towards 
securing using renewable energy sources 
to, as a minimum, balance our electricity 
consumption at the latest in 2020 to leave 
a positive impact. 
The LEGO Foundation, pages 41-44. In the 
LEGO Foundation we work to inspire and 
develop the builders of tomorrow. We do 
so by working with three different funding 
programs: Care for Children in Need, Care 
for Education, and Care for LEGO Local 
Communities. The LEGO Foundation holds 
25% of the LEGO Group shares.

12 
Sustainable play
Throughout 2011 we worked on developing new corporate standards 
such as the new position on marketing to children. This chapter is 
about how we maintain consumer confidence in our products and 
how we work with systematic creativity and learning for children.
We have strong opinions about play. Our origin and 
authenticity is expressed in the name: LEGO (a short-
ened form of the Danish words Leg and godt, or play 
well). We believe the LEGO Group should produce 
and market high-quality products that last for genera-
tions and are safe both online and offline. We con-
tinue to develop a systematic approach to creativity 
and play to enhance learning and to help pass on the 
joy of play from generation to generation. We call this 
Sustainable Play.
All LEGO® bricks are compatible across time and 
product line, giving each brick a very long lifetime. 
LEGO bricks never become redundant, as each one 
can be reused to build new ideas and to unfold chil-
dren’s creativity. Bricks that are not passed on to fam-
ily or friends are often sold second-hand. We call this 
Sustainable Play. The resilience and long-life of LEGO 
products supports our Play Promise by extending play 
value over time. It also opposes a culture of ‘play and 
throw away’, helping to support our Planet Promise.
Learning through systematic creativity
Our mission is to ‘Inspire and develop the Builders 
of Tomorrow’ by stimulating children’s systematic 
Target 2011
Target 2012
Result 
2011
Consumer complaint call rate
Other selected relevant data
Product recalls
Selected sustainable play data
Net Promoter Score Index®
0
0
0
The consumer complaint 
call rate is the number 
of consumer complaints 
received relating to 
products launched 
in 2011 as a parts per 
million (ppm) of the 
number of products sold 
in the launch year. 
The index shows how likely consumers are to recommend 
a LEGO product or service to others.
For full data on sustainable play read data overview, page 45.
Target
2011
Result
2011
Target 
2012
0
100
200
300
400
500
600
700
800
We calculate product recalls as 
launched products recalled from 
the market due to product safety 
issues. Calculated per stock 
keeping unit.
The LEGO Group has in 2011 
stayed within our target of 0 
product recalls.
The LEGO Group continues 
to have a focus on 0 product 
recalls in 2012.
120 index

13
creativity. The LEGO Learning Institute is part of the 
LEGO Group and supports this mission by conduc- 
ting research on how children can express creativity 
through systems of play and learning. The ambition 
is to bring knowledge and insight to new audiences, 
while at the same time generating helpful feedback 
to the people who design and build our play experi-
ences. Over the years a profound understanding of 
how children learn and play has been accumulated. 
In 2011 the LEGO Learning Institute researched the 
Future of Learning with leading experts in play, learn-
ing and children’s cognitive development. This foun-
dational study emphasises the importance of creative 
leadership in learning. In the course of the year, the In-
stitute held several working seminars with both LEGO 
employees and external academic partners on the Fu-
ture of Learning and its previous report, The Future of 
Play. The results of the Future of Learning project will 
be publicly available in 2012, and the LEGO Group is 
seeking to stimulate many initiatives around creative 
learning in 2012.
Since its beginning more than 30 years ago, LEGO 
Education has been responding to demands from 
pre-schools, schools and after-school facilities to ad-
dress important areas of the curriculum. In 2011 LEGO  
Education continued to extend its global reach with 
several major projects, including introducing LEGO 
Education WeDoTM to science and technology teach-
ing in 20,000 primary schools across Peru. 
Children’s private speech and play
In 2011, the Billund-based LEGO Learning Institute intensified its 
academic collaboration with the University of Cambridge and Dr 
David Whitebread. In a project on Private Speech and Play, support-
ed by the LEGO Foundation, a new study has initiated a series of 
experiments to evaluate how open-ended play stimulates children’s 
‘private speech’. 
This research describes the relationship between what children 
are doing with their hands through play, and what they are think-
ing about when playing. This indication of ‘children speaking out 
loud’ when playing by themselves, signifies a the start of a process 
of self-regulation, which is important for cognitive development, 
school readiness and the general ability of children to manage 
their emotions and social behaviour, explains Bo Stjerne Thomsen, 
Senior Research Manager LEGO Learning Institute.
Bo Stjerne Thomsen, Senior Research Manager, LEGO Learning Institute
case
At this workshop, participants studied the 
relationship between play and brain activity.

14 
Build The Change: 
Building our Green City 
of the Future 
More than 800 school children came together in Mel-
bourne in Australia in November 2011 to build the 
green city of tomorrow out of LEGO® bricks. The 
children focused on green parks, alternative power 
stations, pleasant places to sit and enjoy life, and 
finally green and sustainable houses.
The children were building their ideas at the Build The 
Change event, ‘Green City of the Future’. The event co-
incided with the official Danish Business delegation’s 
visit to Australia named ‘State of 
Green, Join the Future. Think Den-
mark’ headed by Their Royal High-
nesses, the Danish Crown Prince 
Frederik and Crown Princess Mary. 
The Royal couple came to see the 
work that the children had done 
and showed great interest in the 
ideas behind the creations. 
LEGO Education, the Danish 
Art Agency and ARTPLAY had ar-
ranged the Build The Change 
event in Melbourne in partnership. 
The event was designed to give 
the general public a chance to 
build their ideas and dreams for a 
greener city in the future. As many 
as 2,400 people participated.
– These children are the next 
generation to take over and it is important to stimu-
late their ability to think out of the box in order to find 
innovative and creative solutions to the challenges 
they will meet in the future. From listening to the pre-
sent voice of children we can improve the future. Now 
we just need to ensure that their voices are heard, 
says Camilla Torpe, event manager and creator of the 
event. 
The Build The Change programme was launched 
in 2009 and introduced building with bricks as a tool 
to communicate and express ideas. Participants – 
mainly children – build the changes they want to see 
in their own communities. 
Build The Change events are organised between 
the LEGO Group and selected partners and focus on 
many different topics. Through the programme the 
LEGO Group hopes to foster systematic creativity and 
imagination among children. Besides creating aware-
ness about LEGO Education and its learning products, 
the event in Melbourne also provided the children 
with the opportunity to reflect on how to build a green 
future. 
In 2012 the plan is to establish a joint venture with 
the city of Manchester in the United Kingdom to ini-
tiate a Build The Change event that will serve as a 
source of inspiration for an urban renewal plan in 
Manchester. Children and their families will be invited 
to build their ideas for a better city.
Focus
HRH Princess Mary took an interest in LEGO® MINDSTORMS®. 
Photo: Robert Cianflone/AP/Polfoto.

15
Quality systems in place
The LEGO Group imposes high standards on design, 
development and production of LEGO products. All 
LEGO play materials comply with the European and 
the US toy regulations. All play materials must as a 
minimum comply with all toy standards, national as 
well as international. Our ISO 9001 certified quality 
management system forms the basis for quality con-
trol and continuous monitoring. The system ensures 
quality through random sampling, including counting 
elements, building models and assessing moulding 
quality. We want to ensure that external partners com-
ply with our guidelines not only with regard to quality 
and safety but also with regard to our strong opinions 
about children and play.  
Meeting our consumers’ needs and 
exceeding their expectations
Our ambition is to create life-long play experiences. 
This is why it is crucial that our products are durable, 
while providing interesting and fun play. We have a 
strong focus on the needs of our consumers in de-
veloping our products and it is important for us to 
exceed our consumers’ expectations of our products 
and the LEGO brand. We maintain an open dialogue 
with our consumers in order to get a sense of their 
needs and expectations. 
We want to constantly improve our products and 
we have a history of collaborating with consumers to 
create new products. In 2011 we launched our ‘Closing 
the Loop’ programme as a way to get more feedback 
from consumers. Adults buying our products in stores 
can volunteer to be contacted shortly after their pur-
chase by a LEGO employee, who will ask them about 
their experience. Our main objective is to gather infor-
mation that can help us shape our products to meet 
the consumers’ expectations. 
Consumer complaints
We also measure consumer satisfaction through 
the Consumer Complaints Call Rate. Since 2005 we 
have collected, analysed and systematically catego-
rised consumer complaints to detect a pattern and  
designate main areas for development. Thanks to a 
substantial amount of data, we are now better able 
to track which product lines score high and low in the 
Net Promoter Score (read more page 43), and make 
targeted adjustments and improvements. The Con-
sumer Complaint Call Rate has been reduced over 
the past three years. The target for the Consumer 
Complaint Call Rate in 2011 was below or equal to 800 
ppm and the result was 623 ppm. Our target for 2012 
is to be below or equal to 550.
We continue to react on consumer feedback to im-
prove the play experience.
Product safety
Product safety is a top priority and is relevant both 
for our physical products and our online and digital 
products. It is crucial that our consumers trust in the 
quality of all LEGO products and that they are safe 
for children. Product safety is an important element 
of product development, quality management and 
partnerships. However, we aim to do much more than 
just meet regulations – we want to meet and exceed 
all consumer expectations of the quality and safety 
of our products, with regard to design, play patterns 
and usability. As a global company we need to com-
ply with a variety of local and regional product safety 
legislation. Some of this is achieved by following inter-
nationally acknowledged safety standards and sup-
porting the further development of such standards. 
The LEGO Group is a member of the Toy Industries 
of Europe (TIE) and the US Toy Industry Association 
(TIA), and chairs the European committee for stand-
ardization of toy safety. As a member of CEN and ISO, 
we are engaged in promoting safety in the toy sector 
by helping to define safety standards for toys.  
In 2013, an updated version of the European Toy 
Safety Directive will come into effect. The new regula-
More than 800 school children took part 
in LEGO Build The Change in Melbourne.

16 
tions have more stringent demands for materials. We 
have spent 2011 screening our material portfolio and 
verifying compliance of each raw material to meet 
these demands by 2013.
Product recalls are a strong indicator of quality and 
safety and we have only had two product recalls over the 
past eight years. In 2011 we met our target of zero prod-
uct recalls, and this will be our target for 2012 as well. 
In 2011, we formalised the LEGO Partnership Traffic 
Light into a corporate standard in order to signal 
internally that the LEGO Partnership Traffic Light is 
global and must be adhered to by all LEGO employees. 
For many years, the LEGO Partnership Traffic Light has 
been used to ensure that the LEGO Group manages 
its business outside its core categories in a controlled 
and structured way.
The categories within the LEGO Partnership 
Traffic Light cover many different business areas. 
Internal stakeholders from Global Quality, Corporate 
Affairs, Corporate Communications, Legal, and Brand 
Development highlight concerns within their area of 
responsibility continuously in order to ensure that we 
get a 360 degree perspective on external partner 
opportunities.
Marketing to children
Marketing and advertising allow us to show children 
the play experiences they can expect from a LEGO 
product. However, when communicating with children, 
we are sensitive to the fact that children perceive 
marketing messages differently from adults. We want 
Build The Change was launched in 2009 and introduced building with bricks as a tool to allow children 
to communicate and express ideas about the changes they want to see in their own communities.
to make sure that when an advertised product is 
purchased, it will meet or exceed the expectations 
generated by advertising. By doing so we also believe 
that we can prevent disappointments and uphold the 
loyalty of LEGO builders.
The LEGO Group is a member of the Responsible 
Advertising and Children Programme, and we are 
committed to acting in accordance with legislation 
as well as self-regulation, such as the International 
Chamber of Commerce’s (ICC) code of advertising 
and marketing communication practice. Self-regula-
tion within advertising is a key component of ensur-
ing that marketing communications are carried out 
responsibly. Self-regulation exists in the US with the 
Children’s Advertising Review Unit (CARU), in most 
European countries and many jurisdictions around 
the world, and sets up regulation that goes over and 
above legal requirements. Since 2002 we have sup-
ported the organisation Media Smart, which develops 
We ensure that our products meet or exceed 
the expectations generated by advertising.

17
and donates teaching resources about the interpreta-
tion of commercial messages. Media Smart in the UK 
has also developed material about online marketing 
and the need to protect your data. In 2011, a lesson on 
body image was developed by Media Smart to teach 
young people about the influence of media and ad-
vertising on body image.
In 2011 we introduced a corporate standard 
and principles for marketing to children in order to 
strengthen the internal awareness of our values and 
principles when it comes to marketing to children. 
We have always worked actively on ensuring that 
our marketing practices are responsible and live up 
to our stakeholder’s expectations. However, with an 
increasingly digital and global world we found that 
it was worthwhile to ensure that our principles are 
clearly stated. And our new standard is a reminder to 
all of our employees of the rules we all need to follow 
in everyday marketing practices.
The guidelines are related to three main issues: in-
experience and credulity; avoidance of harm; and so-
cial values. Across all channels, our marketing efforts 
must not exploit the natural credulity and inexperi-
ence of children by e.g. failing to disclose information 
about the need for additional purchases. Additionally, 
children and youngsters must not be portrayed in un-
safe situations or encouraged to engage in hazard-
ous activities. Finally, our marketing efforts must not 
suggest that our products will give children a physi-
cal, psychological or social advantage over other chil-
dren.
Online safety
We have a focus on online protection when we deve- 
lop our digital platforms. We support and comply with 
the Federal Trade Commission’s Child Online Privacy 
Protection Act (COPPA) as well as articles of the 1989 
United Nation’s Children’s Rights Convention, stating 
that children have the right to participate in play and 
the right to protection. 
Before 2010, our main focus was on securing child- 
ren’s safety in the digital world by constructing and 
keeping a safe environment on the digital platforms. 
But children interact more and more in the digital 
world, which represents an important part of their 
public sphere. This is why we expanded the focus on 
digital safety in 2011. Children spend more and more 
time playing online. They see it as a natural exten-
sion of the physical world and boundaries between 
the two are blurring. As a commercial company we 
need to make our products available for children in 
their digital playroom and be present in the social 
media, but it is a challenge to combine this with our 
high standards on child safety. Because we adhere to 
COPPA rules, we do not engage directly with children 
under the age of 13 on third-party social media plat-
forms because we have been unable to fully moder-
ate and protect children in this sphere.
Weapons and violence
Boys’ interest in weapons 
between the ages of four 
and nine is considered by aca-
demics to be a phase in their de-
velopment. Learning about how 
to handle conflicts, aggression and weapons 
is often part of a LEGO play experience, but 
only as a means to achieve the goal, whether 
it is rescuing citizens, finding treasure or sa- 
ving the universe. 
We have strict rules for the use of weapons 
and violence in our products. The LEGO 
play experience must never be related to 
real world modern warfare, killing, torture or 
cruelty to animals. In 2011 we expanded the 
LEGO brand guidelines with regard to use, 
expression and form of violence and wea- 
pons. The standard consists of guidelines 
already known to our employees, but now 
these guidelines serve as an explicit basis for 
product development and communication.
Read more about sustainable play at 
http://aboutus.LEGO.com/sustainability

18 
In the LEGO Group we want to leave a positive im-
pact on the environment. Our focus is on resources 
as this has vital importance for future environmental 
demands. We work to ensure that our business is pre-
pared to deliver on these requirements. Our ultimate 
long-term goal is zero waste.
For decades we have been focused on the durability,  
long life and compatibility of our products, which gives 
them a unique starting point. However, we still seek to 
create more environmentally-friendly products and to 
reduce the waste we generate.
We do have an inevitable impact on the environ-
ment: from purchase of raw materials, to design of 
products, to the production process, packaging and 
distribution and finally to end of life. With our Planet 
Promise in mind, we work at reducing these impacts 
while focusing our environmental initiatives in order to 
ensure that we leave a positive impact overall. 
Our production
All our production facilities are certified according to 
the environmental standard, ISO 14001. Each produc-
tion plant in the LEGO Group adheres to our environ-
mental policies in order to reduce our impact on the 
environment. In 2012 we are gearing up to ensure that 
our offices outside production facilities also adhere 
Environment
In 2011 our environmental work included increasing our efforts 
in recycling waste at our factories, reducing the size of our 
packaging and preparing wood-based packaging and print  
to use solely FSC materials. 
Target 2011
Target 2012
Result 
2011
Raw materials
Other selected relevant data
Recycled waste
Selected environmental data
Water consumption
85%
88%
88%
We calculate raw 
materials as plastic 
granulate used in 
manufacturing at LEGO 
sites. Our use of raw 
materials has increased 
from 42* in 2010.
* 1,000 tonnes
* 1,000 m3
We calculate our water consumption as the quantity of 
water supplied to the LEGO Group. 
For full data on the environment read data overview, page 45.
Our recycled waste percentage shows  
the recycled quantities of waste disposed 
compared to total quantities of waste 
disposed.
We managed to recycle more 
waste i 2011 than targeted for.
We have set our target for  
2012 according to our result  
in 2011.
49
*
225
*

19
to all environmental policies. To make sure that we 
reach our ambitious targets by 2015, we are planning 
to initiate two global projects on waste and employee 
health and safety in 2012. The projects will build up our 
capacity and capability with regard to waste sorting 
as well as on continuously safe-
guarding the health and safety of 
our employees. 
However, we still need to im-
prove to reach our ambition of 
zero waste. One of the initiatives 
to meet this target in production 
is the formation of Green Teams 
at several local LEGO sites in 2011. 
The Green Team members 
are responsible for encouraging 
and implementing new ideas on 
how to reduce waste and energy 
consumption. The idea is that 
the teams send clear messages 
about the environment and en-
courage small changes in be-
haviour that will, in turn, evolve 
into fundamental changes in the 
mindset of our people. In 2011 
the work of the Green Teams has 
been a great success, especially at the plants in Hun-
gary and Mexico. In both locations Green Teams have 
involved many employees.
Our global material approval process
Having a comprehensive raw materials list for our 
products is extremely helpful when we take our prod-
ucts through our global material approval process. 
We have used this process to test materials for many 
years, but from 2012 we will also be looking at the en-
vironmental toxicology impact as part of this process. 
We review all materials and assess them in order to 
make sure that they fulfil the high demands of being 
included in LEGO® products. In 2011 we began work-
ing on further central procedures to strive for higher 
standards by measures such as internal off-gas test-
ing used in the Health and Safety assessment, and 
initiating the use of Life Cycle Assessment as part of 
the evaluation. This has contributed to an improve-
ment of the global material approval process. 
Zero waste
Zero waste means that it should be possible for 100% 
of waste from the LEGO Group to be recycled and 
used in other products. We see this as a long-term 
ambition that may not be achievable in practice, but 
remains our ultimate goal. We have 
improved the percentage of recy-
cled waste in 2011 to 88% from 87% in 
2010 at our productions sites. In 2011 
the total amount of waste was 11,055 
tonnes, compared with 9,644 tonnes 
of waste in 2010. The increase in total 
waste is not just a result of the growth 
in production, but also an increase in 
waste from building activities at all 
sites.
As the design of a LEGO prod-
uct and its packaging has high 
impact on the waste generated 
downstream in the supply chain, 
we also strive to work towards 
our goal of zero waste during the de-
sign phase. We have started our jour-
ney in two main areas: by optimizing 
our elements and packaging. 
Design for Disassembly of LEGO elements
Design for Disassembly is about designing a product 
so it can be separated into base elements of materi-
als at its end-of-life. Each element can then be reused 
as raw material for new products. When it comes to 
sub-assemblies and the electronic elements of our 
products, we also see an opportunity to encourage in-
novation by our suppliers to support cost reductions 
and environmental optimisation at the same time. In 
2011 we began working with Life Cycle Assessments 
(LCA) to evaluate the effects of an element’s design 
on the environment over its life. LCA can help us make 
decisions on a more informed basis when we design 
our products. 
Sustainable packaging
We have made great advances to increase the use of 
recycled materials and our primary packaging (LEGO 
boxes) already contains on average around 75% recy-
cled materials.
Waste
We calculate waste as the 
recorded quantities of 
waste disposed 
from the LEGO 
Group. This 
only includes 
data from LEGO 
Group sites with 
production. 
11,055
tonnes

20 
Smaller boxes meet consumer 
needs and save CO² and waste
The Green Box project started as a project to reduce 
the size of LEGO® boxes to meet demands from 
retailers and consumers who wanted less pack-
aging material. With it comes the potential to save 
over 1,000 tonnes of carbon emissions from pack- 
aging and over 2,500 tonnes of cardboard waste 
once it has been fully implemented in 2013. 
Throughout 2011, the LEGO Group has been working 
to develop and test the Green Box project in order 
to be able to fully imple-
ment it globally in 2013. 
The project focuses on 
reducing the size of box-
es, but as the project de-
veloped it became clear 
that there were obvious 
environmental 
benefits 
too.
Preliminary trials in-
dicate that this project 
could help save around 
1,000 tonnes on carbon 
emissions from packag-
ing material and over 
2,500 tonnes post-con-
sumer waste.
– We can see that by 
taking box sizes down, we save significantly on vol-
ume. This has a positive impact on how much paper 
we have to buy for packing material, on how many 
boxes we can stack on pallets and finally, on how 
many products we can pack in trucks when we dis-
tribute, says Carsten Rasmussen, Senior Vice Presi-
dent and General Manager, EU Production.
Calculations of the total carbon emissions regard-
ing the total lifecycle of the packaging materials indi-
cate that the carbon footprint of the packaging mate-
rials will be reduced. 
As the boxes are smaller, more can be filled into 
trucks distributing LEGO® products, which in turn 
means fewer trucks on the roads. 
– We have 40,000 product movements every day 
globally, and with the smaller boxes we can move 
more with fewer trucks, says Carsten Rasmussen.
In order to improve packaging even more, Carsten 
Rasmussen and his team are currently testing the 
plastic bags containing bricks inside the box, known 
as pre-packs. The tests are looking for ways to reduce 
the amount of air in the pre-
pack bags, while keeping 
up the high requirements 
for product safety. 
Less packaging 
material = less waste
By reducing the amount 
of packaging material, the 
amount of post-consumer 
waste will also be reduced.
– We are extremely hap-
py with these positive ef-
fects on our environmental 
impact. Combined with the 
fact that we will now also 
start using FSC-certified 
material for all wood-based 
packaging and print, we see this project as a great 
leap towards creating a positive impact for the future, 
says Jes Faltum, Director, Sustainability Development, 
Corporate Affairs.
Focus
LEGO employees Carina Lysgaard and Franz Kock from the 
Green Box project show the difference between old and new 
LEGO boxes.
Read more about the environment at 
http://aboutus.LEGO.com/sustainability

In 2011 we joined FSC Denmark, the Danish office of 
the Forest Stewardship Council, as part of our plan 
towards achieving 100% FSC-certified sources for 
main wood-based packaging and print materials. We 
chose to join FSC because of the high level of trust it 
has internationally. 
In 2011 the LEGO Group was criticized by Green-
peace for using mixed tropical hardwood from a sup-
plier in Indonesia. According to Greenpeace, mixed 
tropical hardwoods were found in one LEGO product, 
a book produced under licence by one of our licen- 
sing partners.
We entered into a dialogue with Greenpeace and 
further developed our three-step plan: first to reduce 
the impact of our packaging on the world’s forests 
already put forward in our Progress Report 2010; sec-
ond, to maximize the use of recycled packaging ma-
terial; and third, to also ensure that all fibre, including 
any virgin fibre used, comes from FSC sources.
  21
Greenpeace
One of the world’s most bio-diverse habitats, the Indonesian tropical rain forest, is being pulped and turned 
into paper packaging. Driving this destruction is Asian Pulp and Paper (APP). Greenpeace’s investigation 
found tropical APP fibre in packaging from the LEGO Group.
The LEGO Group reacted quickly. It had some clear advantages compared to the other companies. Firstly, 
it was already thinking in terms of reducing its paper use, to increase share of recycled and to only use 
certified virgin fibre. 
Secondly, because it makes most of its products in its own factories, it could 
quickly confirm that the use of rainforest fibre had been confined to license prod-
ucts. This direct ownership allowed the company to enact its new paper policy, 
while other toy companies took months investigating the required change. 
point of view
Dan Belusa, Greenpeace
Read more about the environment at 
http://aboutus.LEGO.com/sustainability
Changing employee behaviour is an 
important part of reducing waste.

22
Climate
Our climate work in 2011 has concentrated on reducing our 
total energy consumption, with focus on energy savings 
through new initiatives, such as engaging employees and 
dedicated work towards securing renewable energy sources.
Our most important stakeholders are children. They 
have a right to a healthy and rich environment both 
now and in the future. We acknowledge our contri-
bution to man-made climate change, and are con-
cerned about the consequences. We are therefore 
focused on saving energy at production sites and 
offices and are working towards securing renewable 
energy sources to, as a minimum, balance our elec-
tricity consumption at the latest in 2020 to leave a 
positive impact. We have a target of using 100% re-
newable energy in 2020. 
In a step towards that and creating transparency 
for our own and other corporations’ activities on the 
climate agenda we joined WindMade™ as a foun- 
ding partner in 2011 with the ambition of establishing 
a standard for how companies can demonstrate their 
renewable energy commitment and performance. 
We succeeded in this ambition during 2011 and the 
first WindMade standard is now a reality. The process 
has brought important progress for the LEGO Group 
through informative dialogue and knowledge sharing 
with NGOs and professionals globally. This will help 
Target 2011
Target 2012
Result 
2011
Total energy consumption at production sites
Other selected relevant data
Energy efficiency improvement
Selected climate data
GHG emission
+5%
2.5%
+2.4%
* 1,000 tonnes CO²-equivalents.
For full data on the climate, read data overview, page 45.
We set a high target for 2011. We calculate 
the energy efficiency improvement as the 
rate between energy consumption and raw 
materials used. 
We did not meet our 
target in 2011. 
We have adjusted our 
target in 2012.
This is our total energy consumption in the form of 
electricity and heating supplied to the LEGO Group.
198 GWh
96
*
tonnes

23
us greatly in our work towards our target to use 100% 
renewable energy. In 2012 the LEGO Group will play 
a less active role in WindMade as it has now com-
mercialised and delivered on our ambition. We will still 
support the initiative as a founding partner.
Energy efficiency and consumption
Between 2007 and 2010 we have made great strides, 
improving energy efficiency significantly. Maintaining 
improvements at the same high yearly rate has been 
difficult and is expected to remain so. Our target for 
energy efficiency, set in 2007, has been to improve 
by 5% yearly towards 2015. Despite improving by a 
further 2.4% in 2011, we have not met our ambitious 
target of 5%.
The main reason behind this is that we increased 
our total use of energy by 10% in 2011, keeping pace 
Our energy usage 
by main areas
72%
12%
5%
11%
Moulding
Packaging
Storage
Administration
Better cooling for our employees has adversely 
impacted our energy efficiency in 2011.
This figure shows in which parts of our business we used 
the most energy in 2011.

24
tocol. The accuracy of the calculations enables the 
LEGO Group to identify where in our value chain we 
need to focus in order to reduce our greenhouse gas 
emissions.
The GHG account indicates that a large contribu-
tion stems from upstream activities related to the raw 
materials we use, amounting to approximately 60% 
of the GHG account. Emissions from processing of 
the raw material, bulk transport, distribution and other 
core activities amount to approximately 30% of the 
GHG account. Based on these findings we have iden-
with the growth of our business. The expansion of our 
Mexico plant in particular has significantly contributed 
to this increase through the implementation of com-
fort cooling as part of our People Promise. Moreover, 
approximately half of our planned energy efficiency 
projects were stopped, or delayed unexpectedly.
We will make continuous investments in improv-
ing energy efficiency, but the gains will be harder to 
achieve. For 2012 we have adjusted our target to 2.5%, 
focusing on improvement projects within energy ef-
ficiency. The search for new and big innovations to 
once again significantly increase our energy efficien-
cy will continue in parallel.
Greenhouse Gas Account 
In 2011 we calculated the Greenhouse Gas (GHG) 
Account for the LEGO Group for the year 2010. The 
goal of the study was to estimate the GHG account 
throughout the value chain. It covers the relevant di-
rect and indirect GHG emissions from activities within 
the organizational boundaries, from the reporting 
company, and upstream and downstream. 
The calculations are based on the guidelines out-
lined in the GHG Protocol Corporate Accounting and 
Reporting standard published by WBCSD/WRI. To the 
extent possible, it includes Scope 1, 2 and 3 emis-
sions and it comprises the accounting and reporting 
of the greenhouse gases covered by the Kyoto Pro-
The LEGO Group joined WindMade™ as a 
founding partner in 2011. Photo: DONG Energy
2007
2008
2009
2010
2011
0
20
40
60
80
100
GHG emission
(1000 tonnes CO²-equivalents)
Our CO²-emissions 
have grown due to 
general growth of 
our business. We 
have seen a growth 
in emissions in 2011 
because of increased 
volumes produced at 
our Mexican plant.

25
tified the following focus areas in the attempt to re-
duce the GHG burden account for the LEGO Group.
Improving transport 
In 2010 we set up a benchmark model to compare 
our logistics contractors directly. This system creates 
a competitive environment where smart-thinking for 
better transport solutions is easier to evaluate and 
implement. During 2010 we worked closely with one 
of our transport providers in Europe to test a new sys-
tem which reduces the distance travelled by unload-
Mexico’s Green Team reduces energy 
At the LEGO factory in Mexico, a new Green Team manned by en-
gaged employees saw the light of day in 2011. The Mexican Green 
Team’s mission is to find ways to reduce energy consumption. 
During 2011 the team began by installing internal electricity meters. 
The meters provide the team with a detailed overview of where 
the factory needs to focus to reduce energy consumption. The 
collection of data from 2011 will be used for a new plan for energy 
reduction in 2012.
Mexican employees, unused to the idea of reducing energy, 
weren’t sure at first why they needed to focus on energy con-
sumption and many of them were not completely sure what to do. 
To engage his colleagues better the leader of the Green Team, 
Jesus Ramirez, arranged weekly meetings, each with a new topic, 
as well as training sessions.
– The weekly meetings, information, and training have truly made 
a positive impact on my colleagues, because they now know ex-
actly what targets we are reaching for and most importantly why! 
Now we are all committed to reducing energy and we get positive 
feedback from everyone, explains Jesus Ramirez.
Jesus Ramirez, Leader of the Green-Team, Mexico
case
ed trucks when products are brought to and from our 
European Distribution Centre in the Czech Republic.
We have also worked to secure transportation ca-
pacity and improve the options for environmentally-
sound rail transportation. This is why we have used 
the system of intermodal transport.
Read more about climate at 
http://aboutus.LEGO.com/sustainability

26
Employees
In 2011 we continued our work towards our 2015 target to be 
among the top ten companies in the world for employee safety. 
We also worked to improve the well-being, job satisfaction and 
development of existing employees, focussing on empowerment 
and collaboration and we worked to integrate new employees.
The employees in the LEGO Group are the building 
blocks of our success. We recognise the rapid growth 
of our business has only been made possible by the 
skill, dedication and commitment of our people. In the 
next few years we expect to welcome around 5,000 
new colleagues and it is very important that each and 
every one of our new colleagues understands and 
lives our unique LEGO culture. Two main issues are in 
focus regarding our employees: We want to improve 
the motivation and skills of our employees. And we 
continously improve safety. This is all part of realising 
our People Promise to succeed together.
Safety at the LEGO Group
At the LEGO Group safety comes first; not only with 
regard to the products, but also with regard to our 
employees. We have set a target to be among the 
top 10 companies in 2015 for employee safety. We 
are OHSAS 18001 (Occupational Health and Safety 
Management System) certified at all LEGO sites with 
more than 100 employees. This certification ensures 
our commitment to continuous implementation and 
improvement of the way we manage our health and 
safety systems. We measure our employees’ safety 
Target 2011
Target 2012
Result 
2011
Other selected relevant data
Injury rate
Selected employee data
2.0
1.8
2.1
Motivation and satisfaction
At the end of the report-
ing year we survey our 
employees regarding 
among other things their 
motivation and satisfac-
tion. The number shows 
how many index points 
we are above our inter-
national benchmark.
For full data on employees read data overview, page 45.
Sick leave
Sick leave is the number 
of hours lost due to 
the employees’ own 
illness calculated as a 
percentage of total hours 
worked.
Target
2011
Result
2011
Target 
2012
0.0
0.5
1.0
1.5
2.0
2.5
3.0
We calculate the injury 
rate as the number of 
occupational injuries 
resulting in at least one 
day’s absence following 
the day of the injury. 
We are at an all-time low for 
injury rate, but did not reach 
our target for 2011.
We have set an ambitious 2012 
target.
+14

27
by looking at several indicators, including the number 
of injuries with absence and the absence rate due to 
injuries. While the number of injuries with absence in 
2011 fell to 36 from 44, the absence rate due to inju-
ries rose to 0.35 per 1,000 working hours in 2011 from 
0.29 in 2010. This failed to meet our target of 0.26 for 
the year. The increase is a reflection of an increase in 
the severity of the injuries, requiring our employees to 
take more time off work.
In 2011 the injury rate fell to 2.1 injuries per million 
working hours, from 3.0 injuries per million working 
hours in 2010. However, this was slightly above our 
2011 target of 2.0. 
We saw a greater number of injuries among our 
office workers, mainly in Denmark, but also at our 
brand retail stores. In the first half of 2011 alone there 
were no fewer than six reports of office accidents in 
Billund resulting in periods of absence, greater than 
the whole of 2010. To remedy this, in 2012 we have 
planned further campaigns to highlight safety aware-
ness in offices, but also in LEGO® Brand Retail stores. 
Our offices in the UK, the US and Germany have not 
had one single accident in 2011 resulting in absence.
However, in production we have seen some tre-
mendous improvements as a result of an ongoing 
campaign to encourage our production workers to 
take ownership of safety improvements, to regard re-
sponsibility as a collective matter and to pay attention 
to safety in everyday work life. This proactive safety 
approach has been introduced as the way to change 
culture, attitude and behaviour. 
We have embedded a focus on proactive safety 
as part of our Performance Management Programme. 
Production employees are now obliged to report safe-
ty observations each month. And employees in se-
lected areas have to undergo our training programme 
‘Safety Plus’. The programme combines theory-based 
knowledge about safety and practical exercises in 
groups. Focus is on raising awareness about preven-
tion of accidents. We have rolled out the tool called 
‘15 seconds’ in selected areas of the organization in 
order to train employees to reflect upon safety and 
inappropriate habits for 15 seconds every day. 
We believe that our collective actions will lead to a 
change in behaviour, resulting in reductions in injuries 
and absence due to injuries in 2012. The target for 
2012 is to reach less than 1.8 injuries per million work-
ing hours, which is even lower than the 2011 target, 
and to reach an absence rate due to injury of less 
than or equal to 0.2 per 1,000 working hours. This tar-
get is stricter for us than the target we set for 2011. 
Though we did not make the target this year, our con-
tinuing focus on problem areas makes us believe it is 
possible to do so in 2012.
EHS non-conformities at main LEGO sites
In 2011, we received 10 major Environment, Health and 
Safety non-conformities from our external certifica-
tion company. Six of these were related to environ-
ment, and four were related to health and safety. Nine 
of these were in Billund and one in Kladno. In 2012 
we will have a special focus on Billund for improving 
LEGO employees in the world
219
3,286
7,285
Asia
The Americas and 
Oceania
Europe
Safety training in production has helped 
reduce the number of accidents.

28 
Increased focus  
on diversity in 2012
A diverse body of employees is a key factor to the 
success of a global company such as the LEGO 
Group. From 2012 the focus on diversity at all levels 
in the company – and with special attention on di-
rector level and above – will be enforced.
It is about people from Asia, Europe and the US. It is 
about women and men. It is about professional back-
grounds and different personalities. 
Such diversity is important for the 
LEGO Group to match the world 
in which business is made and to 
support better decision making. 
Jørgen Vig Knudstorp, the CEO 
of the LEGO Group explains:
– In the future we need to ad-
dress these diversity challenges 
when hiring and promoting 
leaders. From now on all lead-
ers have to explain why they 
cannot find at least one can-
didate amongst the last three 
with a ‘diversity profile’. By empha-
sising the importance of following 
the policy and by speaking out loud 
about cultural biases we believe that we will be able 
to recruit an even more diverse body of leaders, says 
Jørgen Vig Knudstorp. 
Re-organising for the future
In 2011 the LEGO Group began a large re-organisa-
tion. The re-organisation has focused on becoming 
more adaptable and more effective. One of the ma-
jor effects of the re-organisation process has been 
the expansion of Group management from six to 22 
members.
One of the unforeseen consequences of this move 
has been the fact that the LEGO Group now has a 
Group management with no women. 
 – We are highly concerned about diversity in two 
main areas. We keep a high focus on both cultural 
and gender diversity, says Jørgen Vig Knudstorp and 
continues:
– I believe that we are on the right track towards 
improvement. The fact that no women were appointed 
to the new management reflects that in the past we 
have not had a strong enough focus on developing 
our female employees’ talents. We 
have this now. We believe that in 
three years’ time we will be able to 
harvest the benefits of our new in-
ternal recruitment focus on women 
for director level and above.
Attracting diversity can be a 
challenge
One side of the coin is to de-
velop female talent. Another side 
consists of attracting women as 
part of a diverse body of talents 
in general. Troels Wendel-
bo, Director, HR Insights 
& Planning, Executive HR 
explains:
– We need to challenge 
ourselves when recruiting 
new directors. We need to attract more diverse can-
didates externally. We know that diversity is a param-
eter at all management levels in order to build the 
necessary pipeline of talents for the organisation. 
The average staff turnover in the LEGO Group is 
low, which means that it takes time to change the di-
versity ratio. Also the hidden cultural barriers, such 
as the human propensity to select people reflecting 
themselves, need to be uncovered in order to insti-
gate change.
Focus
Female 
directors+ 
promotions
Target 
2011
Result 
2011
Target 
2012
30
23
0

29
these matters. The environmental non-conformities 
showed that additional resources should be dedi-
cated to address the findings, and an environmental 
manager was hired to secure future compliance.
Occupational health of the LEGO employees
In 2011 we also looked more in detail at the occupa-
tional health of our employees. Occupational health 
involves both the health and safety of our employ-
ees. We take some of the responsibility for the health 
of our employees upon us at Group level, in order to 
reduce sick leave and improve the well-being of our 
employees. We regard this responsibility as a chance 
to remind our employees about the necessity of a 
healthy lifestyle and we provide them with concrete 
opportunities to act. Our employees are encouraged 
to suggest improvements or express ideas on how to 
improve our working environment. 
In 2011, we encouraged our employees to engage 
in various locally arranged activities such as becom-
ing a member of the local LEGO cycle team,  running 
during the lunch hour or joining the local LEGO gym 
to work out. Other local initiatives were healthy food 
alternatives in the canteens, no sweets in the work-
place, quit-smoking courses and weight-loss pro-
grammes. Our employees are encouraged to suggest 
improvements or express ideas on how to improve 
our working environment. 
Motivation and satisfaction
Highly motivated and satisfied employees are the 
building blocks of our succes today. In our annual 
Employee Pulse survey a high level of motivation and 
satisfaction among our employees is evident. We 
measure our performance against the general labour 
markets in a point system, and we have a long-term 
target of being 10 points ahead of our benchmarks. 
We can see from the Pulse that it is the same things 
that motivate people all over the organisation from 
Mexico to New Zealand and from production worker 
to top-level management.
A total of 93% of employees took part in Employee 
Pulse in 2011, which shows high engagement. As was 
the case last year, the overall level of motivation and 
satisfaction rose to +14 in 2011 from +12 last year. 
An increase in motivation, satisfaction and engage-
ment is related to our values, culture and reputation, 
according to our employees. Across the world, our 
employees said that having an extraordinary job with 
exciting tasks and great colleagues, while working for 
a company with a strong culture and values is highly 
motivating and satisfying. 
During the last three years, we have had a stra-
tegic focus within our people and culture agenda to 
embed and embrace our culture as formulated in our 
People Promise. We use our employees' own subjec-
tive assessment of our company culture from  the 
Pulse results to measure our People Promise. In the 
third year of this initiative, we have seen this score 
improve from 51% to 66%, meaning that two thirds of 
all departments experience our culture even stronger 
today than in former years. This is below the rather 
ambitious target set of 80%, but more than satisfac-
tory. Most importantly, we do not find huge motivation-
al discrepancies between either different job levels, 
business units, nationalities or length of service across 
the company.
Work-life balance
Our employees also report on how they experience 
the balance between their life at work and outside 
work. Our target for 2011 was to achieve an employee 
score on work-life balance of 0-5 points above the 
global benchmark. The results show that we have 
achieved six points above. 
Despite this high score, we are well aware of the 
challenges in keeping a healthy balance. It is impos-
Motivation and job satisfaction are 
high among LEGO employees.

30
sible to define a standard work-life balance as each 
individual has different circumstances at work and at 
home. One of the potential pitfalls of being a highly-
motivated organisation is the risk of employees push-
ing themselves and each other too hard, driven both 
by personal enthusiasm and by strong commitment 
to the many, often exciting and rewarding, tasks at 
hand. Some employees might be so engulfed in their 
job at periods that they are at risk of being stressed 
or burned out. To combat this we focus on a frequent 
dialogue between employees and managers. We 
have also focused on expanding virtual workplaces 
and are constantly exploring alternatives to long dis-
tance commutes and business trips abroad by work-
ing together in smart and virtual ways.
Cultural and gender diversity
The LEGO Group is an international company and we 
want our employees to reflect the variety of society 
in general with regards to culture, backgrounds and 
way of thinking. 
We have a strong focus on diversity in respect 
of culture and gender in order to strengthen the or-
ganisation and our relationships to our stakeholders. 
In recent years we have focused on how to secure 
and improve our recruitment of women to positions at 
leadership level or above. We have measured our pro-
gress in two dimensions; namely the overall number of 
female directors in the LEGO Group and the number 
of female new-hires and promotions at director level 
and above. We have seen general progress with re-
gard to female recruitment in new director positions. 
In 2010 we achieved 32% female recruitment for 
director level and above, which indicates that re-
cruitment in the LEGO Group is moving in the right 
direction to meet our high ambitions with regard to 
gender diversity at this level. This result formed the 
basis for setting the target for 2011 as high as at least 
30%. While we succeeded in recruiting a good num-
ber of highly competent female directors in 2011, we 
achieved only 23%. The primary challenge for the 
LEGO Group is to recruit women to these positions 
externally. Only 14% of those recruited externally for 
new positions were female while the percentage was 
29% for internally recruited staff. Even though the re-
sults show that reaching our target is a challenge, we 
are not lowering our ambition. The target for 2012 is 
to attain 30% or more women for positions at director 
level and above. 
Though we do not set targets for our cultural diver-
sity, in 2011, we hired a larger amount of employees 
with a cultural diverse background at manager levels 
and above than ever before.
Attracting and integrating new talent globally
The number of employees in the LEGO Group in-
creased by 947 in 2011. The increase is attributable 
to the large increase in activities in connection with 
The mould workshop in Billund has been the 
focus in a proactive safety campaign in 2011.

31
Proactive safety as the means to an improved safety culture  
Throughout 2011 the LEGO Group has kept a strong focus on 
safety in the mould workshop in Billund. The aim has been to 
reduce the injury rate by improving the safety culture. Employees 
took part in a safety workshop identifying problems and solutions.
– Since the launch, all 91 employees have had to report one safety 
observation a month. The we select and award the best observa-
tion. I am sure that this initiative and our explicit focus on safety 
has improved our safety culture. Now it’s on everyone’s mind and 
it’s OK to care and interfere. I think this has contributed to the 
fact that our injury rate has been significantly reduced, says Arne 
Jensen, Manager of Mould and Maintenance.
the considerable sales growth. Our challenge is to 
attract qualified applicants for vacancies, select the 
right people for the jobs, and integrate them into the 
LEGO culture. 
Attracting new employees includes marketing the 
LEGO Group as an attractive workplace – and one 
of the tools is to provide new, personalised content 
in the jobs section of www.LEGO.com. On average, 
60-70 vacancies are available at any given time. We 
also now appear on job-related social media such as 
LinkedIn. Our aim is to position the LEGO Group as 
one of the world’s most progressive employers. The 
new job site is an important step on the way. It was 
launched on December 1 2010 and has reached ap-
proximately 50,000 unique visits a month – especial-
ly from the US, Germany and Denmark. One of the 
benefits is that applications for jobs in Denmark from 
other countries are on the increase.  
When we hire a new employee, we immediately 
provide them access to a special website where they 
can learn more about the LEGO culture and history. 
And as a new initiative in 2011, the new employees 
will from the first working day be teamed up with a 
‘Brick-Mate’ - a colleague who can help them with the 
big and small issues in figuring out the organisation 
as a newcomer.
 These are some of the initiatives of the “on-
boarding” strategy designed to help new recruits get 
aboard and into their new jobs. Further initiatives in-
clude the launch of two other internal websites: one 
for leaders whose job includes taking on new employ-
ees, the other is a site new employees can visit after 
they start working for the company. The new strategy 
focuses on three phases in our recruitment of a new 
employee: attracting candidates, selecting the right 
people, and finally settling the successful candidates 
in their new jobs. It is built on the framework of our 
best practices of how we onboard new employees.
case
Arne Jensen, Manager of Mould and Maintenance 
Read more about employees at 
http://jobs.LEGO.com

32
Stakeholder 
dialogue
Throughout 2011 we have been working to further improve 
the regulations on toy safety. We have engaged in continuous 
dialogue with all of our stakeholders and through a number of 
surveys, conversations and discussions learned more about 
them and their expectations of us. 
Being in a respectful dialogue with stakeholders and 
our surrounding community is of foremost importance 
for the LEGO Group. We are committed to being open 
and honest, and to reaching high transparency when 
we communicate with our stakeholders, e.g. NGOs, 
consumers and fans, suppliers, and public authorities.
The LEGO Group gets great inspiration and input 
from every stakeholder, whether through online com-
munities, employees, partnerships or other forums. 
Our products’ journey from distribution centres to the 
hands of a LEGO builder has to pass through several  
of our stakeholders such as distributors, retailers and 
buyers. The success of this journey is defined by the 
way we co-operate closely with our partners and com-
municate and advertise effectively and responsibly. 
Lobbying activities
We work to ensure that our lobbying activities always 
seek to benefit all stakeholders and are conducted 
in a transparent and professional manner. We partici-
pate in toy-related lobbying activities in external as-
sociations with focus on critical standards, changes in 
legislation, or other initiatives that may influence
the LEGO® brand.
Our primary focus is on regulatory developments 
within intellectual property rights, toy safety and mar-
keting to children. We are interested in ensuring that 
the framework conditions for the toy industry are sen-
sible and workable. As an example we support strict 
rules on toy safety to ensure the highest possible 
level of safety for children, but new rules must also 
still be possible to implement. We believe that with 
our long history of producing safe toys we have key 
knowledge and competencies to contribute to the 
process of developing new rules.
We participate in international and regional asso-
ciations such as the Toy Industries of Europe, TIE, the 
Toy Industry Association, TIA, the European brand or-
ganisation, AIM, and the World Federation of Advertis-
ers, WFA. We also take active part in the development 
of new toy safety standards in the European Com-
mittee
for Standardisation, CEN and the International Or-
ganisation for Standardisation, ISO, and the American 
Standard for Testing and Materials, ASTM.
The focus in 2011 has mainly been on explaining 
what the LEGO Group is doing in relation to chemi-
cals and product safety and we have primarily com-
municated with the European Commission, NGOs, 
and the American authorities. The reason for this is 
the continued focus on chemicals and product safety, 
and input from toy companies on the best approach 
on managing chemicals is requested by a number of 
stakeholders. We have had a good dialogue with the 
authorities about the level of documentation that can 
be considered satisfactory in regards to the product 
LEGO stakeholders
Business 
partners/
suppliers
Customers
Shareholders
Employees
Society
Community,  
Media, NGO’s, 
Authorities
Consumers

33
safety area. We find these discussions very fruitful as 
they inform us about the expectations from our stake-
holders and give us an opportunity to explain our ap-
proach and to make informed decisions on how we 
can improve.
Dialogue with NGOs
We have had a constant dialogue with national and 
international NGOs throughout the year. We value this 
dialogue as it helps us to improve employees’ rights, 
working conditions as well as our environmental per-
formance. And it helps increase the understanding of 
these potentially complicated issues. 
Tax and other economic impacts
Tax is a major aspect of business in the community. On 
the wider agenda, the economic impact of our busi-
ness on society is based on the direct and indirect 
employment and associated money flows, including 
tax paid. It is fundamental to us that our relationships 
with the local communities in which we operate are 
based on trust, mutual respect, and a cooperative 
spirit. We respect the laws and pay the taxes required 
from us. The corporation tax bill for the LEGO Group 
in 2011 was DKK 1,381 million. 
Engaging with consumers 
In 2011 the LEGO Group focused on aligning our di-
rect contact with consumers through the LEGO Club, 
brand retail stores, our VIP loyalty scheme and LEGO 
Community Engagement and Events. 
We also began a process of getting even closer 
to our consumers by studying how they perceive and 
use our products where they meet them – whether 
online, in stores or through consumer service.
There are millions of articles, videos and photos 
about LEGO elements and models on the web and on 
social media networks, but the LEGO Group has only 
had a sporadic presence featuring individual prod-
uct lines or initiatives. In 2011 we introduced a corpo-
rate approach, employing a social media strategist, 
implementing guidelines for engaging on social me-
dia networks and a social media ‘drivers licence’ for 
employees. Being present in social media is part of 
our overall strategy to increase engagement with our 
consumers and improve the overall consumer experi-
ence. It is also a great possibility for us to gain valu-
We meet our customers in many 
situations, here at the Nuremburg Toy Fair.
Walmart
The LEGO Group is the best in the industry 
at really helping us to manage our business 
through all metrics including modular productiv-
ity goals, sales goals, etc. The main challenge 
is to work further out with us; often The LEGO 
Group is too far along in the production process 
to make changes to products, including exclu-
sives and new item shipments.
point of view
Andy Prince, Sr. Category Director 
for Boys, Games and Summer Seasonal, Walmart
able insight into our consumers’ interests. Without our 
employees’ active engagement on our different social 
media platforms we will not succeed. To enable the 
social media strategy internally we have trained 125 
employees as certified social media users. 
The LEGO Group launched several different social 
media sites in 2011. One of these is LEGO CUUSOO, 
which is a website which allows the LEGO Group to 
source ideas from all around the world by asking peo-
ple what they think we should be producing. Another 
site is ReBrick, a social bookmarking service, which 
was launched as a further step along the road of col-
laboration with LEGO fans and consumers. The focus

34
is on sharing and celebrating what consumers cre-
ate with LEGO bricks. ReBrick will make it easier to 
navigate, enjoy and be inspired by the content cre-
ated by LEGO fans and also help create connections  
between people in the LEGO community.
Consumer satisfaction
We measure consumer satisfaction through the 
Net Promoter Program® which is a  system of con-
tinuously listening to consumer feedback, acknow- 
ledging that we heard them, learning from it, taking 
action, and letting consumers and others within the 
company know what we did to improve their future 
experiences. About 500,000 consumers in 2011 told 
us how likely they were to recommend our products 
or services to others and why or why not.  
We failed to meet the target of index 124 or above 
in 2011, with the final index ending at 120, at the same 
level as 2010.
The Net Promoter (NP) Program has proven to be 
very effective in collecting feedback from consum-
ers, using these insights to drive business decisions 
and actions, and letting our consumers know that 
we heard them and took action. Net Promoter Score 
(NPS) is the key metric used to track consumer sat-
isfaction and loyalty with our products and services. 
NPS serves as an early warning indicator for the 
health of a business as it is closely linked to future 
sales. It is logical: if someone is satisfied with us, they 
will return, buy again, and tell their friends.
It is even more important that we hear from un-
happy consumers and react quickly so we can take 
action, apologize and make it right. This is how we 
will earn their loyalty and repeat business. The Net 
Promoter Program raises employees’ awareness and 
motivates them to consider the impact on consumer 
satisfaction and long term loyalty when making busi-
ness decisions.
LEGO® bricks make a difference in townships in South Africa
For many years the LEGO Group has had great co-operation in 
South Africa with Hands on Technologies, both as a business 
partner and with regard to charity work through The LEGO Foun-
dation. Hands on Technologies is a distributor for LEGO Education 
products. The problem was that many less privileged children 
from townships had never seen LEGO® bricks before and did not 
know how to use them.
– We have been able to constantly improve the learning with 
LEGO Charity boxes, e.g. by developing instruction material for 
teachers. The children are now able to build their future. We gave 
them 101 activities they can do with the LEGO bricks and general 
training, says Brent Hutchenson, MD Hands on Technologies and 
adds:
– We see that when the children are playing with LEGO bricks 
they change their attitude and they have a desire to learn new 
things.
Brent Hutchenson, MD Hands on Technologies, South Africa
case

35
Read more about stakeholder dialogue at 
http://aboutus.LEGO.com/sustainability
The LEGO Group will continue to raise the bar to 
create the best possible products and experiences 
for our consumers.
Knowing our customers better
To make sure we listen and act on retail customer 
feedback, we have institutionalized an annual health 
check of our relationship with our main customers; 
the Customer Pulse Survey. The Pulse provides us 
with information on expectations for our future busi-
ness, the effectiveness of our marketing efforts and 
the quality of our partnerships. It gives us valuable in-
put on how we are performing on our Partner Promise. 
In 2011, the Customer Pulse survey showed an in-
crease in overall satisfaction, rising to 126 index points 
from 123 in 2010, with a base in 2005 figures. This 
beat the 2011 target of 124 index points. A target for 
2012 had not been set as the Progress Report was 
published. The Customer Pulse figures for Products, 
Marketing, Service, Partnership and Value were all at 
the same level as 2010 or higher (see page 45 for de-
tails). In 2011 we also conducted a stakeholder survey 
in three markets: Denmark, the US and Germany, to 
gain more knowledge about their perceptions and 
expectations of our sustainability work. We did this in 
order to ensure that we improve our communication 
about sustainability to our stakeholders, as more and 
more of our stakeholders demand specific informa-
tion from us in this area. The survey taught us, among 
other things, that we can improve and intensify the 
level of communication about sustainability issues to 
our customers. We will be working on developing this 
area in 2012.
Co-operation in 2011 
During 2011, the LEGO Group has collaborated and 
started partnerships with some of the world’s largest 
companies and organisations working towards com-
mon goals of promoting education, science, technol-
ogy and creativity to children. 
The LEGO Group’s three-year partnership with 
NASA reached a milestone last year when the first 
LEGO models were delivered to the International 
Space Center orbiting the earth. 
The models will be used in eight educational activi-
ties conducted by ISS crew members and available 
to teachers around the world. The first activities were 
posted to LEGOSpace.com in 2011, the others will fol-
low during 2012. 
A second project in the joint outreach and edu-
cational programme was the launch of three LEGO 
Minifigures as passengers on the deep-space probe, 
Juno. The specially-constructed aluminium Minifig-
ures of the Roman god Jupiter, his wife Juno and ‘fa-
ther of science’ Galileo Galilei will help raise aware-
ness about Juno’s mission to improve understanding 
of our solar system’s beginnings by revealing the ori-
gin and evolution of Jupiter. Juno and the Minifgures’ 
journey will also be featured on LEGOSpace.com.
The LEGO Group also supported the first Google 
Online Science Fair to inspire scientific exploration 
among the next generation of scientists and engi-
neers. The science fair celebrates scientific talent, 
creates scientific role models and unites students 
around the world in the quest for learning. The event 
was the largest online science fair in the world, at-
tracting with more than 7,500 entries from more than 
90 countries.
The LEGO Group is also sponsoring this year’s fair, 
which is even more global in scope. Submissions will 
be accepted in 13 languages and there will be 90 re-
gional finalists – 30 each from the Americas, EMEA 
and APAC. 
In 2011 we worked with NASA on several 
programmes to promote science and engineering.

36 
Human rights
In 2011 we began developing a strategy for human rights. The 
strategy has included the development of a draft policy on 
human rights, the start-up of a value chain impact assessment 
process and a review of our Code of Conduct.
Human rights play an increasingly important role in 
the global sustainability agenda. In recent years we 
have experienced a growing expectation from society 
in general and NGOs that we actively take part in the 
promotion of internationally agreed human rights. 
We fully acknowledge that we have a responsibility 
to ensure respect for human rights in our operations. 
Human rights align well with many of our core values 
and we made a formal commitment to human rights 
by signing the UN Global Compact in 2003, commit-
ting us to ten universally accepted principles in the 
areas of human rights, labour rights, environment and 
anti-corruption. 
Human rights strategy 
The LEGO Group began the process of developing a 
human rights strategy in 2011. The overall objective of 
the strategy is to ensure that we have the right mea- 
sures in place when it comes to ensuring respect for 
human rights in our operations. The completed stra- 
tegy will outline the approach that the LEGO Group 
intends to take on human rights, and draw up those 
activities that we believe are essential for us in order 
to meet our commitments. We expect the strategy to 
be finalised and adopted in 2012.
While all human rights are equally important, we re-
alise that some stakeholder groups are more affected 
than others by our activities and at risk of having their 
rights infringed upon. Similarly, we have a greater op-
portunity to support the promotion of some human 
rights than others. 
Our strategy will for that reason focus on our em-
ployees, our consumers (the children), our suppliers 
and people in local communities affected by our op-
erations.
Human rights impact assessment process
A key component of the strategy is a human rights 
impact assessment of our value chain, a process 
which we began in 2011. The impact assessments will 
first identify actual and potential areas where we risk 
negatively affecting human rights. Second, the as-
sessment will identify leadership opportunities where 
we can have a positive impact by promoting certain 
human rights. 
During 2011 we have developed a tool box for con-
ducting human rights impact assessment, including a 
preliminary human rights risk assessment of our value 
chain. The next step will be to assess to what extent 
our policies, guidelines and processes appropriately 
address the human rights risks we face. We expect to 
finalize the process in 2012. 
The impact assessment process will lead to a list 
of potential risks and leadership opportunities, which 
will inform the finalization of the human rights stra- 
tegy. An example of a potential risk could be when we 
expand our business and production sites and buy 
new land. An example of a leadership opportunity 
could be supporting the promotion of children’s right 
to education.
Our Code of Conduct covers: 

y Child labour 

y Compensation and working hours 

y Discrimination 

y Coercion and harassment 

y Forced and compulsory labour, including 
human trafficking 

y Health and safety 

y Freedom of association 

y The environment

y Anti-corruption

37
Children’s rights
Focus on children’s rights and businesses’ impact on 
children’s rights has gained momentum in 2011. This is 
reflected in the Business and Children’s Rights Princi-
ples, an initiative started by the UN Global Compact 
in Co-operation with UNICEF and Save the Children. 
The Principles will be launched in March 2012 and 
encompass those areas where a business potentially 
impacts children’s rights, negatively as well as posi-
tively. In 2011 we participated in the consultation pro-
cess of the Business and Children’s Rights Principles 
and we are following the initiative closely.
In 2011 we developed a corporate standard on mar-
keting to children, which clarifies our position on this 
issue and ensures that when we market our products 
to children, we do it in a respectful and sensible way.
We expect that we in 2012 will continue and even 
reinforce our focus on supporting children’s rights. 
We hope to do that in dialogue with our stakeholders, 
such as UNICEF and Save the Children.
Our Code of Conduct
We encourage our suppliers and business partners 
to respect their employees' human rights, and this 
includes providing them with decent working condi-
tions.
Since 1997 we have required that our suppliers 
and business partners sign our Code of Conduct. We 
monitor compliance with the Code of Conduct via 
independent on-site audits and engage in proactive 
co-operation and capacity building of our suppliers to 
promote sustainable supply chains. In 2011 we started 
to conduct 5-10 un-announced audits on a trial basis. 
This audit form has shown to be very successful and 
will be continued in 2012. 
If there are conditions which do not meet our re-
quirements, the supplier must draw up an action 
plan in dialogue and with the assistance of the LEGO 
Percentage of 
Major CoC non-conformities 
found at supplier audits 
solved in accordance with corrective action plans
100%
98%
Target 2011
The number from 2011 shows the percentage of major 
Code of Conduct non-conformities found at audited 
suppliers which have a deadline for the corrective action 
in 2011 and which have been solved before the agreed 
deadline. We did not reach the 2011 target.
Result 2011
All our suppliers and business partners 
sign our Code of Conduct.

38 
Group, including a timetable for corrections. This will 
be combined with a follow-up visit to check whether 
conditions have improved. Through a combination of 
action plans and follow-up visits, the LEGO Group is 
helping to secure a programme of steady improve-
ment in the working conditions of its suppliers and 
business partners.
Our 2011 target for the resolution rate of the ma-
jor non-conformities found at our suppliers was 100%. 
However, since we failed to close one major non-
conformity we finalized the year with a resolution rate 
of 98%. The reason for this was that we expected to 
phase out a supplier where a non-conformity had 
been identified, but by the end of the year we realized 
that it was necessary to postpone the phasing-out 
until mid-February. The non-conformity will be closed 
in February 2012. Due to increase in production, the 
LEGO Group has increased the supplier portfolio 
in 2011. Many of these suppliers are located in hu-
man rights high-risk countries which has resulted in 
an increase of Code of Conduct audits. However, in 
general we find fewer and fewer non-conformities at 
our regular supplier base. We believe that the main 
reason is the long-term relationship with our strate-
gic suppliers base, which has been made possible 
through a joint effort to raise their performance. The 
stakeholder analysis that we conducted in 2011 shows 
among other things that ethical responsibility is im-
portant for our consumers. These findings led us to 
start work on refining our Code of Conduct manage-
ment system in 2011. In addition to refining the Code 
of Conduct our focus has been on describing in more 
detail the various processes that we and our suppli-
ers need to follow. We believe that further detail in our 
Code of Conduct will benefit the employees of our 
suppliers. 
A major focus for us in 2011 has been to comply 
with the international standards on working hours in 
China, which prescribe a 60 hours working week, in-
cluding overtime. We have seen difficulties with some 
of our suppliers in keeping within this standard. Due 
to the financial crisis, orders come in very late and it 
is difficult for suppliers to hire workers at short notice. 
Furthermore, people are no longer willing to travel far 
for jobs. These facts increase pressure on the workers 
already there. 
This challenge has been discussed with all strate-
gic suppliers. We are in a close dialogue to help them 
improve this issue for their workers, which includes 
looking at their working processes. 
In 2012 the LEGO Group will continue to engage 
in capacity building and training of suppliers to ad-
dress the challenges they may face in adhering to the 
standards of our Code of Conduct. Our aim is to en-
sure supplier ownership of good working conditions 
in their workplaces. We will also train workers in order 
to empower them to take a stronger role in asserting 
and protecting their own rights.
Stop Toying Around!
After more than a year of involvement with 
the LEGO Group, the “Stop Toying Around!” 
Campaign remains convinced of the on-
going dialogue. Dialogue builds trust. But 
dialogue is not a means in itself. Dialogue 
needs to continue while serious, sustainable 
improvements are achieved. Transparency 
and dialogue about positive changes are 
essential for supporters of the campaign, to 
decide whether the LEGO Group deserves their 
trust as a toy company with real 
commitment to high ethical 
standards that include 
factory workers in China.
point of view
Read more about human rights at 
http://aboutus.LEGO.com/sustainability
Claudia Bonk, International Coordinator

39
As a family-owned business it is important that we 
maintain professional management of our company, 
including a strong and competent board of directors 
in line with leading management practices, also with 
regard to good corporate governance. 
Good governance in a family-owned company
Since the establishment of the LEGO Group in 1932, 
the company has been privately owned by the Kirk 
Kristiansen family. Our approach to good corporate 
governance is focused on combining the strengths 
and benefits of being privately owned with good cor-
porate governance for listed companies. The LEGO 
Group and its owners are interested in managing the 
company in line with globally leading management 
practices, also with regard to corporate governance.
The benefits associated with being privately owned 
with few owners include having owners close to the 
business with strong industry knowledge and strong 
values, which can be inspiring and supporting for the 
development of the company and the employees. 
Other benefits are the ability for long-term focus, to 
move fast and be agile with regards to changes in the 
business environment.
Board of Directors
The LEGO Group Board of Directors consists of seven 
members. Three of these are considered dependent 
on the company; two due to ownership, and one due 
to being in the management of the parent company. 
The Chairman and three other members are consi- 
dered to be independent.
As a family-owned business it is important to main-
tain a professional management of the company, in-
cluding a strong and competent board of directors. 
One of the ways to support this is the practice the 
board has had for many years of electing the Chair-
man from among the independent board members. In 
general the company works to ensure a professional 
board management, including definition of required 
board competencies to ensure a diverse and com-
plementary composition of the board, regular board 
self-assessments, competitive compensation to the 
board of directors and clear and specific rules on 
mandate for each of the management bodies in the 
LEGO Group.
Furthermore, as a family-owned company, the 
LEGO Group is more exposed to the risks involved 
in the handover from one generation to the next. To 
mitigate this risk, a plan is prepared and implemented 
that results in high involvement of the next generation 
of the family owners in company matters related to 
the ownership.
Governance
In 2011 we continued to focus on good governance in a family-
owned business, working with a professional management and 
cross-functional bodies to ensure transparency and follow up 
on our policies, standards and directions. 
Business integrity 
training
Since 2009 we have had a target to secure the dedication to 
our business integrity among our leaders. We want to make 
sure that all employees at director level and above receive 
training in business integrity every two years.
In 2011 our business integrity programme was updated and 
a major group of employees at director level and above 
was due to complete a retraining in the last quarter. Due to 
the focus on changing the organisation in the last quarter 
(read more on page 40) several of these directors failed to 
complete the planned re-training bringing the 
number of trained directors in the organisa-
tion down to 79%. It is however, planned to 
reschedule the training and the target for 2012 
will therefore remain at 100%.
Besides the employees at director level 
and above, several employees working 
directly with customers and suppliers have 
completed the training programme.
98% 100% 79%
Result 2010
Target 2011
Result 2011

40 
Corporate Management
The LEGO Group Management Board and Corporate 
Management were changed during 2011. The latest 
major organisational change was in 2005, and since 
then the LEGO Group has experienced significant 
growth both in number of employees and in revenue.
The biggest change in the new organisation is a 
new Corporate Management team, consisting of 22 
members instead of previously six. Furthermore, the 
number of organisational layers has been reduced 
to ensure a flatter organisation, which ensures both 
a broader and a deeper perspective on the realities 
of business, while making it simpler and 
faster to make decisions.
The structure of the LEGO 
Group has also changed. 
Previously it had five busi-
ness areas; Global Supply 
Chain (GSC), Markets & 
Products (M&P), Com-
munity, Education & Di-
rect (CED), Corporate 
Center (CC) and Corpo-
rate Finance (CF). In the 
future, the LEGO Group 
will be organised in three 
areas: 

y Operations

y Marketing 

y Business Enabling
 
The new LEGO Group Management Board con-
sists of the President and CEO, Jørgen Vig Knudstorp, 
the CFO (the CEO is also temporarily acting CFO), 
the COO, Bali Padda and the CMO, Mads Nipper. The 
Group Management Board together with 18 Senior 
Vice Presidents forms the new Corporate Manage-
ment, which is the daily management body within the 
LEGO Group. The Management Board refers to the 
Board of Directors.
The cross-functional nature of the new corporate 
management facilitates collaboration, quick deci-
sion-making and clear authority delegation.
The LEGO Group has a corporate compliance 
board which has members from Corporate Manage-
ment, including the CFO and the head of Corporate 
Legal Affairs. It has an explicit obligation to report to 
the Board of Directors on compliance matters.
Creating value with four promises
There is strong focus on ensuring the balance be-
tween the value created for the owners, compared to 
value creation for the remaining stakeholders of the 
company such as consumers, employees, custom-
ers and other partners. There is a sincere belief in the 
owner family that creating value for the company’s 
stakeholders will also result in long-term value crea-
tion for the owners. The LEGO Brand Framework, in-
cluding its four promises to various stake-
holder groups, supports this thinking, 
and therefore is an important part 
of how we do business.
Policies
The LEGO Group has a 
framework of 12 corpo-
rate policies, which all 
provide 
position 
and 
guidance 
on 
various 
sustainability issues. For 
example our Responsi-
bility Policy ensures that 
our spirit and company 
values are never compro-
mised. Our Health and Safety 
Policy helps to ensure that all our 
activities are planned and executed 
in accordance with a healthy and safe 
working environment.
Whistle Blower
About five years ago, the LEGO Group introduced 
its whistle-blower function. This gives employees the 
opportunity to speak out about behaviour that they 
consider to be in violation of the guidelines that safe-
guard the integrity and policies of the LEGO Group, 
as well as any law or regulation. It is up to the employ-
ee to decide whether he or she wants to be anony-
mous. All reports are sent directly to the head of the 
LEGO Group’s Corporate Legal Affairs.
Co
rp
or
at
e 
Ma
n
ag
e
m
en
t (
C
M)
M
a
n
a
g
e
m
e
n
t
 
B
o
a
r
d
 
(
M
B
)
O
p
e
r
a
t
i
o
n
s
 
 
 
 
 
 
 
 
 
 
 
 
M
a
r
k
e
t
i
n
g
B
u
s
i
n
e
s
s
E
n
a
b
li
n
g
CEO
Product
Group 1
Product
Group 2
Europe
Americas
& Paciﬁc
Asia & Emerging 
Markets
Innovation
& Consumer 
Marketing
Corporate
Aﬀairs
Corporate
Finance
Corporate
IT
Executive HR
Europe Moulding
& Europe DUPLO
Value Chain
innovation
Engineering
& Quality
Procurement
Americas
Manufacturing
EU Packing
Shopper
Marketing &
Channel Dev.
Supply Chain
Planning &
Distribution
Read more about governance at 
http://aboutus.LEGO.com/sustainability

41
 The LEGO 
Foundation
In 2011, The LEGO Foundation reached out to 600,000 children – 
exceeding this year’s target of 470,000 children. The total value of 
donations from The LEGO Foundation in 2011 was DKK 46 million 
in product donations and DKK 29 million in financial support.
The LEGO Foundation is a non-profit organisation 
that  through its investment company owns 25% of the 
LEGO Group. The LEGO Foundation also manages 
three different donation programmes. In The LEGO 
Foundation, we believe that all children have the right 
to play and learn. Under the headline “We Care and 
Share” we make LEGO® products accessible and ap-
plicable for less privileged children around the world 
through our donation programmes such as Care for 
Children in Need, Care for Education and Care for 
LEGO Local Communities. 
The work of The LEGO Foundation is based on the 
LEGO Brand Framework and like the LEGO Group, 
our mission is to “Inspire and develop the builders of 
tomorrow”. This way, we provide the children of the 
world with the tools to help them take responsibility 
for their own lives – empowering them to be the archi-
tects and constructors of the future society. 
The LEGO Foundation donates LEGO products all 
over the world, helping thousands of children, and or-
ganising activities that offer children and adults good 
experiences and insight into the many creative learn-
ing opportunities inherent in LEGO products. We en-
hance the education of the less privileged children 
via research programmes, systematic learning mate-
rials and supplementary education of teachers. It is 
The LEGO Foundation target to reach out to one mil-
lion children in 2015. 
Children in a slum area in Hyderabad, India, playing with LEGO® DUPLO® bricks received 
from private donors and the LEGO Foundation.

42 
Care for Children in Need
Running charity programmes often calls for in-depth 
knowledge of local practices. Therefore, the Care for 
Children in Need programme continues our co-oper-
ation with external organisations to help prioritize and 
successfully distribute LEGO Charity boxes. 
During 2011, The LEGO Foundation reached out to 
about 78 countries in five continents. 
We signed a three-year collaboration agreement 
with UNHCR. The LEGO Foundation and UNHCR have 
been working together to bring LEGO Play boxes and 
DUPLO toys to child refugees and asylum seekers as 
well as stateless children and returning and internally 
displaced children being assisted and protected by 
UNHCR. As an example, in co-operation with Save the 
Children we sent 1,800 boxes of LEGO Play boxes and 
LEGO DUPLO Play boxes to Dadaab in Kenya. Togeth-
er with UNCHR we sent 1,200 boxes to Kakuma, also 
in Kenya. The LEGO Foundation has also contributed 
DKK 1 million to UNHCR emergency relief in the Horn 
of Africa, thought to be one of the worst humanitarian 
crises in the world today.
Care for Education 
The Care for Education programme supports the 
development and improvement of underprivileged 
school systems by introducing and implementing the 
LEGO Learning System. By doing so, the communities 
In 2011 The LEGO Foundation also administered a 
number of related foundations. 
Ole Kirk’s Foundation supports non-profit and 
charitable, social, cultural, church-related, hu-
manitarian and educational purposes, mainly in 
Denmark.  One of the original purposes of the 
Foundation was to develop the local community 
around the LEGO Group into an attractive living 
environment for its employees. Ole Kirk’s Founda-
tion accepts applications from the general public, 
and caring for the weak and vulnerable in society 
is an important aspect in its work. The total value 
of Ole Kirk’s Foundation donations in 2011 was DKK 
33.6 million.
Edith & Godtfred Kirk Christiansens Foundation 
was formed in 1978 with the purpose of supporting 
non-profit and charitable projects. The Foundation 
supports a large number of cultural and church-
related projects in Denmark and internationally. 
As regards cultural projects, the Foundation gives 
priority to new ideas and initiatives that enhance 
the quality of life and human values, especially as 
regards children, young people and families. Exam-
ples of the projects supported by the Foundation 
are the Center for ADHD and funding the establish-
ment of an SOS Children’s Village in Jimma, Ethio-
pia. In 2011, the total value of donations by the Edith 
& Godtfred Kirk Christiansen’s Foundation was DKK 
15.9 million.
Each year, LEGO employees in Denmark can  
nominate projects for the LEGO Employees’  
Anniversary Grant. The grant’s funds come from 
a collection among LEGO employees in Denmark 
in connection with the LEGO Group’s 50th anniver-
sary. The purpose is to give employees an opportu-
nity to get involved in and submit projects that they 
consider important and interesting. The projects 
are typically small-scale projects where focus is 
on nearness and involving people they know, who 
have committed themselves to trying to make a 
difference for others. 
In 2011, a total of DKK 250,000 was donated to 16 
very wide-ranging projects – all nominated by 
LEGO employees. Recipients were causes such 
as a water pump run by solar cells for a school in 
Gambia and mattresses and beds for an orphan-
age in India, a centre for AIDS victims in Thailand, 
and a waste disposal system to improve health in a 
village in Guatemala.
Related Foundations

43
and school systems can provide an education that 
will motivate children to become self-directed, moti-
vated learners, with the interest and capacity to be-
come active citizens in their society.  
The programme enters into long-term partnerships 
with ministries of education, NGOs, foundations or 
private companies with the same philanthropic goals 
as the LEGO Foundation. Through collaboration with 
local governments, we train and support teachers in 
practicing a child-centered educational approach. 
Our Care for Education programme combines pro- 
duct donations in combination teacher training, sup-
port, for infrastructure and research. The Care for 
Education programme covers age groups from early 
childhood to high school. 
We support projects in various countries from 
Mexico to Ukraine and South Africa. One of several 
projects in China is a collaboration with the Ministry of 
Education that focuses on creativity and technology 
in schools. Another China project has in 2011 reached 
out to 50-60,000 children in migrant and village kin-
dergartens in some of the poorest and most remote 
provinces of China. In Southern India, Tamil Nadu, we 
support 100 primary schools and high schools for 
casteless children and we have trained all teachers in 
ten selected play schools.
Care for LEGO Local Communities
Ever since Ole Kirk Kristiansen founded the LEGO 
Group in 1932, the family has been very much aware 
of their responsibility towards the local communities 
in which their employees live. The purpose of ‘Care 
for LEGO Local Communities’ is to take concrete lo-
cal action, showing compassion and human interest, 
especially in the children in local communities.
The activities in Care for LEGO Local Communi-
ties have received a warm welcome from employees, 
because they are proud to be able to help make a 
difference in their own communities and experience 
the impact of their efforts at close hand. Decisions on 
which projects should receive help from LEGO em-
ployees each year are made by the employees them-
selves through the works councils. 
Capital of Children
Through three generations, the Kirk Kristiansen family 
has believed in the importance of a strong engage-
UNHCR
– Engagement, efficiency and expertise are the 
values that guide the co-operation between the 
United Nations refugee agency (UNHCR) and 
The LEGO Foundation and make our multi- 
faceted partnership unique. The partnership is 
guided by our common vision that all children, 
everywhere, receive the quality education, deve- 
lopment and well-being that is their right. Adding 
another layer to the partnership, the financial 
support of The LEGO Foundation to UNHCR’s 
life-saving emergency relief in the Horn of Africa 
was a very timely response to the massive and 
urgent needs there. We are 
very proud of working with 
The LEGO Foundation and 
appreciate the enormous 
work of former LEGO 
employees and staff of 
the foundation.
point of view
Pia Prytz Phiri, UNHCR’s regional representative 
for the Baltic and Nordic countries
Care for Education combines product donation 
with education. Our project in China is now up and 
running in 25 Chinese provinces.

44  The LEGO Group – Progress Report 2011
44 
ment in the Billund community. The vision of making 
Billund an international as well as national gathering 
point for children, creativity, play and learning began 
to take shape in 2011. Billund Municipality (Denmark) 
and The LEGO Foundation will each invest DKK 6 mil-
lion in the new private-public partnership over the 
coming three years. 
In 2012, the present Billund town hall building will 
be refashioned into an open knowledge centre, the 
Institute of Play & Innovation Science. The Institute of 
Play & Innovation Science will aim to attract research-
ers and businesses and create a space for experi-
mentation making it possible for children of all ages 
to experience the learning of the future. 
All of Billund Municipality can and will benefit from 
the Capital of Children. To give one good example, 
The LEGO Foundation has decided to donate a LEGO 
Lab to all schools in Billund Municipality in connec-
tion with the project. A LEGO Lab is a completely new 
specialist classroom which will give the students an 
opportunity to work far more creatively with problem 
solving, thereby bringing other competences into 
play in the learning process. 
The best reward is a child’s smile
Each year The LEGO Foundation has supported more and more 
projects in the local community around the LEGO factory in Klad-
no, Czech Republic. The goal is to make the LEGO presence felt 
in the region and the projects focus on supporting and improving 
children’s lives, creativity and development as well as improving 
their leisure time and making hospital stays more bearable and 
enjoyable.
Amongst this year’s projects are providing LEGO® bricks for hos-
pitalized children; building better access to the grammar school in 
Kladno to allow disabled children in wheelchairs to attend classes; 
and furnishing the foster home in Ledce – including help to build 
a new PC room for the children with active participation of local 
LEGO employees.
– Helping people, especially children, is the most beautiful of all 
work. There is no better reward than a child’s smile. It is easy to 
just donate money, but there’s no motivation. Therefore, we not 
only support children’s homes financially, but we are also actively 
involved with the children in improving their environment. We are 
involved in painting their rooms and assembling their furniture, 
explains Jana Vlasáková, Works Council Chairman in Kladno. 
case
Jana Vlasáková, Works Council Chairman, Kladno
Read more about The LEGO Foundation at 
http://LEGOFonden.dk

45
  45
Performance data
Stake-
holder
Notea)
Measures
Results
2009
Results
2010
Targets
2011
Results
2011
Targets
2012
Consumer measures
Number of product recalls
1
0
0
l
0
0
Consumer complaint call rate, ppm
930
779
<= 800
l
623
<= 550
Net Promoter Score Index®b)
126
120
>= 124
l
120
c)
Employee profile measures
1
Number of employees 
8,616
9,843
10,790
1
Female
45.3%
48.6%
47.4%
1
Male
54.7%
51.3%
52.6%
Average age
36.7
36.5
36.4
2
Rate of employee turnover
10.4%
9.3%
8.1%
Director level and above promotions (externally recruited or  
internally appointed) of female employees
20%
32%
>= 30%
l
23%
>= 30%
Health & safety measures
Sick leave
2.9%
2.2%
<= 2.6%
l
2.1%
<= 2.3%
3
Number of injuries with absence
61
44
36
4
Injury rate
4.8
3.0
<= 2.0
l
2.1
<= 1.8
Absence rate due to injuries
0.51
0.29
<= 0.26
l
0.35
<= 0.20
Employee commitment measures
Employees Pulse
-	 Work life range to global scorecard (LEGO EEI)
+3
+4
+0
l
+6
+0
-	 Motivation & Satisfaction range to global scorecard  
	 (LEGO EEI)
+11
+12
+10
l
+14
+10
-	 People Promise 
	 (departmental improvement rate)
51%
>= 80%
l
66%
d)
-	 Employee Net Promoter Score (LEGO EEI)
+0
Business integrity measure
Percentage of Director level and above at LEGO sites trained in 
business integrity biennially
69%
98%
100%
l
79%
100%
Key ESG measures at LEGO sites
5
Number of audits conducted at main LEGO sites
23
20
20
5
Number of major quality non-conformities found at main LEGO sites
0
5
0
l
1
e)
5
Number of major EHS non-conformities found at main LEGO sites
0
8
0
l
10
e)
5
Number of major CoC non-conformities found at main LEGO sites
1
1
0
l
0
e)
Percentage of major quality, EHS and CoC non-conformities found 
at audits at main LEGO sites solved in accordance with corrective 
action plans
100%
Key ESG measures in supply chain
6
Total number of core and extended line suppliers
231
117
154
7
Number of quality audited suppliers
2
33
47
7
Number of CoC audited suppliers
48
33
61
Number of major quality non conformities found at suppliers
3
26
33
8
Number of major CoC non conformities found at suppliers
36
66
64
Percentage of major quality non-conformities found at supplier 
audits solved in accordance with corrective action plans
100%
100%
l
100%
100%
Percentage of major CoC non-conformities found at supplier audits 
solved in accordance with corrective action plans
100%
100%
l
98%
100%
Customer satisfaction measures
Customer Pulse
-	 Overall satisfaction
123
123
>= 124
l
 126
127
-	 Products
106
105
 105 
-	 Marketing
107
107
107 
-	 Service
117
121
127
-	 Partnership
111
109
 109
-	 Value
113
110
112 
Resource measures
Raw material, plastic, 1,000 tonnesf)
36
42
49
Water consumption, 1,000 m3  
116
220
225
Total energy consumption at production sites, GWhg)
155
174
198
Energy efficiency improvement
-
-
+5% 
l
+2.4%
+2.5% 
Waste, tonnes
7,970 
9,644 
11,055
Recyled waste in percentage of total registered waste
88%
87%
>=85%
l
88%
>=88%
a) 	 Please refer to the “Notes to performance data” section. 
b) 	 The NPS for 2010 was calculated using different measuring points than previous years. In order to compare results the 2010 results have been recalculated.
c)	
The NPS definition for 2012 has changed using different measuring points and weighting by consumer impacts. 2011 is new baseline (index 100). The target for 2012 is 102.
d)	
Measure is omitted due to changes in organisational set-up. New measure and target from 2012 is Employee Net Promoter Score (LEGO EEI).
e)	
Targets are omitted and new measure is Percentage of major quality, EHS and CoC non-conformities found at audits at main LEGO sites solved in accordance with corrective action plans.
f)	
2009 and 2010 numbers have been updated due to changes in definition of material types.
g) 2010 number has been slightly corrected. 
l	
Target met	
l	 Target not met
Consumer
Employee
Partner
Surrounding
environment

46 
46 
Notes to performance data
Note 1, Total no. of employees
2011
2010
2009
Female
5,118
4,790
3,900
Male
5,672
5,053
4,716
Total
10,790
9,843
8,616
Asia
219
184
160
Americas and Oceania
3,286
2,751
2,245
Europe
7,285
6,908
6,211
Total
10,790
9,843
8,616
Top management
50
47
46
Management
335
310
302
Other
10,405
9,486
8,268
Total
10,790
9,843
8,616
Note 8, Total no. of major Code of Conduct  
non-conformities found at suppliers 
High risk countries
57
Intermediate countries
7
Total
64
Note 6, Total no. of suppliers split on  
Code of Conduct risk, end of 2011
Direct
Extended
Total
China/Hong Kong
16
22
38
Mexico
13
0
13
Total high risk countries
29
22
51
Czech Republic
8
0
8
Hungary
7
0
7
Italy
3
0
3
Japan
0
0
0
Korea
2
0
2
Poland
3
0
3
Slovakia
2
0
2
Romania 
1
0
1
Taiwan
0
1
1
USA
7
0
7
Total intermediate risk countries
33
1
34
Austria
2
0
2
Canada
1
0
1
Denmark
30
1
31
Germany
16
1
17
Great Britain
2
2
4
Netherlands
2
0
2
Switzerland
3
0
3
Sweden
9
0
9
Total low risk countries
65
4
69
Total
127
27
154
Only active suppliers with production in high and intermediate risk 
countries are audited.
Note 2, New hires, rehires and terminations
2011
2010
2009
New hires and rehires
1,754
2,731
1,780
Terminations
759
753
515
The number of employees dismissed by the LEGO Group in 2011 
has been calculated at 336. (2010: 367) and 2009: 169)
Note 3, Number of injuries with absence
2011
2010
2009
Americas
10
6
7
Europe
26
38
54
Total
36
44
61
Note 4, Injury rate per million working hours
Q4/2011
2010
2009
Americas
2.4
1.8
2.2
Europe
2.0
3.3
5.6
Total
2.1
3.0
4.8
Note 5, Third party audits for main LEGO sites
Certifications
ISO 
9001
ISO 
14001
OHSAS 
18001
Code of 
Conduct
Billund, Denmark
1
1
1
n/a
Kladno (MC), Czech 
republic
1
1
1
n/a
Kladno (Production), 
Czech republic
1
1
1
n/a
Nyregyhaza, Hungary
1
1
1
n/a
Monterrey, Mexico
1
1
1
1
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
1
n/a
Munich, Germany
n/a
n/a
1
n/a
Total number of audits
6
5
8
1
Total number of major 
non conformities
1
6
4
0
Note 7, Total no. of BOM suppliers audited
Code of Conduct
Quality
Total number of BOM audits
61
47
High risk countries
47
Intermediate risk countries
14
The audits create a dialogue with the suppliers, and the major non-
conformities set the main focus for the continuous improvement 
process.
The 64 major non-conformities for the Code of Conduct area can be 
summerized as:
• 16 related to working hours
• 4 related to wages
• 1 related to environment
• 27 related to health & safety
• 5 related to underage labour
• 1 related to freedom of association
• 4 related to employement terms
• 2 related to disciplinary pratices
• 4 related to integrity, transparency and corruption

47
Definitions and 
calculation methods
Data have been calculated by consolidating data for the parent  
company (LEGO A/S) with data for all subsidiaries. The consolidation 
is based on data of a uniform nature and calculated using the same 
methods. However, data relating to health and safety only include 
data from plants with more than 100 employees. Similarly, environ-
mental data only comprise production facilities. The measurement 
method remains unchanged from last year.
Data measurement methods and the basis of calculations are 
addressed below; 
Consumers	
Number of product recalls
Product recalls are calculated as launched products recalled from 
the market due to product safety issues and calculated per stock 
keeping unit. 
Consumer complaint call rate
The consumer complaint call rate is calculated as the number of 
consumer complaints received relating to products launched in 
the year of reporting as a parts per million (ppm) 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 following 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 from 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.
Employees	
Number of employees
Comprises all employees paid by the LEGO Group, including per-
manently 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 director 
level and above 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 rehires as well 
as dismissals is also stated.
Sick leave
Sick leave is calculated as time lost due to the employees’ own ill-
ness. The sick leave is calculated as the number of absence hours 
as a percentage of the total number of working hours excluding holi-
days and non-business days. Only data from sites with more than 100 
employees and LEGO Brand Retail stores are included.
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. Only data from sites with more than 100 
employees and LEGO Brand Retail stores are included.
Absence rate due to injuries
The number of absence hours as a consequence of occupational 
injuries. The rate is calculated per 1,000 working hours, and the ab-
sence is calculated from the day following the injury. Only data from 
sites with more than 100 employees and LEGO Brand Retail stores 
are included.
Director level and above promotions (externally recruited or 
internally appointed) of female employees
The number of female director levels and above promotions (exter-
nally recruited or internally appointed) is shown as a percentage of 
all promotions into the director level and above group of employees.
Employee Pulse
At the end of the reporting year, a survey, the Employee Pulse, is 
carried out in which all employees are asked to evaluate 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 signifi-
cant target areas at Group and departmental level.
New measure is Employee Net Promoter Score (E-NPS) based on the 
results for the Pulse question “I would recommend the LEGO Group 
as an employer to other people”. The E-NPS is calculated by subtract-
ing number of detractors (1-6 on the 10-point scale) from the number 
of active promoters (answering 9-10). The 13 largest LEGO Group em-
ployment countries are included in the calculation.
Partners	
Percentage of director level and above at LEGO sites trained in 
business integrity biennially
The percentage is calculated as director level and above (employed 
for more than three months) having completed the e-learning pro-
gramme in Business Conduct biennially as a percentage of all direc-
tor level and above (employed for more than three months) in the 
LEGO Group.
Number of audits conducted at main 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.

48 
48 
Number of major non-conformities found at main LEGO sites 
(Quality/EHS/CoC)
The number of major quality, EHS and Code of Conduct non-con-
formities found during third party audits conducted at LEGO sites.
Percentage of major quality, EHS and Code of Conduct non-
conformities found at audits at main LEGO sites solved in 
accordance with corrective action plans
The percentage of major quality, EHS and Code of Conduct non-
conformities found by third party audits at main LEGO sites which 
have a deadline for the corrective action in the reporting year and 
which have been solved within the agreed deadline.      
Data relating to suppliers and business partners
The number of suppliers includes the LEGO Group’s active direct 
suppliers 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 (BOM) components whereas 
extended line suppliers primarily deliver merchandise. Suppliers do 
not include indirect purchases. The number of suppliers who have 
been audited is calculated as the number of suppliers visited with a 
view to formalized monitoring and reporting of compliance with quality 
standards or Code of Conduct. The number of significant discrepan-
cies is reported. These form the basis of the continued dialogue with 
the suppliers in order to continuously work on improvements.
Percentage of major quality non-conformities found at supplier 
audits solved in accordance with corrective action plans
The percentage of major quality non-conformities found at suppliers 
which have a deadline for the corrective action plan in the reporting 
year and which has been solved within the agreed deadline.
Percentage of major Code of Conduct non-conformities found at 
supplier audits solved in accordance with corrective action plans
The percentage of major Code of Conduct non-conformities found 
at audited suppliers which have a deadline for the corrective action 
in the reporting year and which have been solved before the agreed 
deadline. Non-conformities found at ICTI Care certified suppliers are 
not included.
Customer Pulse
To obtain an evaluation of the cooperation with retail customers in 
the reporting year, they are asked to give their perceived evaluation 
of the LEGO Group during January and February of the following 
year. The survey is used to track performance within the following six 
categories: 1) Overall satisfaction, 2) Products - questions are asked 
regarding innovation, packaging, assortment size etc. 3) Marketing 
– performance is tracked on the effectiveness of customer, in-store 
and promotion marketing etc. 4) Service – customers rate the LEGO 
Group regarding e.g. order lead-time, quality in delivery, on-time de-
livery etc. 5) Partnership – performance is tracked on joint planning, 
information sharing etc. 6) Value – questions related to stock turns, 
trading terms etc. are in focus. The consolidated data are shown in 
this Progress Report with 2005 as index basis.
Surrounding environment	
Raw materials
Raw materials are calculated as plastic granulate used in manufac-
turing at LEGO sites. 
Water consumption
Water consumption is calculated as the quantity of water supplied to 
the LEGO Group. Only data from LEGO Group sites with production 
are included.
Energy consumption
Energy consumption is calculated as the total energy in the form of 
electricity and heating supplied to the LEGO Group. Only data from 
the LEGO Group sites with production are included.
Energy efficiency improvement
The energy efficiency improvement is calculated as the rate between 
energy consumption and raw materials used. The data is shown with 
the previous year as baseline. Only data from LEGO Group sites with 
production are included.
Waste
Waste is calculated as the recorded quantities of waste disposed 
from the LEGO Group. Only data from LEGO Group sites with produc-
tion are included.
Recycled waste
The recycled waste percentage is calculated as the recycled quanti-
ties of waste disposed compared to total quantities of waste disposed. 
Only data from LEGO Group sites with production are included.

49
Assurance statement
Assurance Statement for LEGO Group’s stakeholders from the 
independent auditor.
We have reviewed the consolidated non-financial data of the LEGO 
Group’s Progress Report for 2011 as expressed on pages 45-46.
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 47-48. These 
contain information concerning which of the Group’s business areas 
and activities are included in the reporting, types of data, and Man-
agement’s reasons for choosing the data included. The non-financial 
data are factored in accordance with the accounting policies de-
scribed on pages 47-48.  
Delegation of responsibility
Company Management is responsible for preparing the Progress Re-
port’s non-financial data, including for establishing registration and 
internal control systems with a view to ensuring reliable reporting, 
specifying acceptable reporting criteria as well as choosing data to 
be collected. Our responsibility is, on the basis of our work, to ex-
press an opinion on the 2011 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 
purpose of obtaining limited assurance that the non-financial data 
presented on pages 45-46 have been computed in accordance with 
the stated criteria.
The obtained assurance is limited compared to that of an engage-
ment with reasonable assurance. Our work has thus - based on as-
sessment of materiality and risk – comprised inquiries regarding 
applied registration systems and procedures, review of data used 
in connection with preparation of the 2011 non-financial data, and 
review of underlying documentation, including review of whether the 
scope of the 2011 non-financial data complies with described ac-
counting policies for the 2011 non-financial data. During the review 
process, we have visited entities in Billund, Kladno and Enfield.
Conclusion regarding the 2011 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 Pro-
gress Report of LEGO Group for 2011 have been presented in ac-
cordance with the stated criteria.
Copenhagen, 21 February 2012
PricewaterhouseCoopers
Statsautoriseret Revisionspartnerselskab
Henrik Kragh
State Authorised Public Accountant
Birgitte Mogensen
State Authorised Public Accountant

50 
50 
GRI and Global Compact 
overview and index
Section
GRI (Profile / Performance Indicator)
GC (principle no.)
Welcome to Progress Report 2011
1.2, 2.1, 3.2, 3.3, 3.5, 3.6, 4.12, 4.15, 4.17
1-6, 10
Table of contents
3.4
2011 highlights
Sustainability - the LEGO way
Message from the CEO
1.1, 2.8
The LEGO way
Our sustainability issues
Sustainable play 
4.16, PR8
Learning through systematic creativity 
Build The Change: Building our Green City of the 
Future  
 
4.16
 
Quality systems in place 
4.13, PR1
Meeting our consumers’ needs and exceeding their 
expectations
4.16
Consumer complaints
4.16
Product safety
PRI, PR3
Marketing to children
PR6
Online safety
PRI, 4.16
Environment
7, 8, 9
Our production
9
Our global material approval process 
EN1
7
Zero waste 
EN2, EN22
8
Smaller boxes meet consumer needs and save CO² 
and waste
EN26
9
Design for Disassembly of LEGO® elements 
EN26
9
Sustainable packaging 
EN26, EN27
9
Climate
7, 8, 9
Energy efficiency and consumption 
EN3, EN5, EN6, EN7
8, 9
Greenhouse Gas Account  
EN7, EN16
8
Improving transport  
EN18, EN29
9
Employees
1-6
Safety at the LEGO Group
LA7, LA8
EHS non-conformities at main LEGO sites 
LA7
Increased focus on diversity in 2012
LA13
Occupational health of the LEGO employees 
LA2
Motivation and satisfaction 
Work-life balance
Cultural and gender diversity 
LA13
Attracting and integrating new talent globally
Stakeholder dialogue
4.14, 4.16
Lobbying activities 
4.13, 4.16, SO5
Dialogue with NGOs
4.16
Tax and other economic impacts 
Engaging with consumers  
4.16
Consumer satisfaction 
4.16
Knowing our customers better 
4.16
Co-operation in 2011 
Human rights
HR6, SO1
1, 2
Human rights strategy  
4.8
1
Human rights impact assessment process
1
Children’s rights 
HR6
2
Our Code of Conduct
4.8, SO3, SO4
1-6, 10

Section
GRI (Profile / Performance Indicator)
GC (principle no.)
Governance
Good governance in a family-owned company 
2.3, 2.6, 4.1, 4.2, 4.9
Board of Directors 
2.3, 4.1, 4.2, 4.3, 4.7, 4.9, 4.10
Business integrity training
SO3
Corporate Management 
2.3, 4.1, 4.2, 4.6, 4.9
Creating value with four promises
4.8
Policies 
4.9
Whistle Blower 
4.4
10
The LEGO Foundation 
EC1
Related Foundations
4.16, EC10
Care for Children in Need
4.16, EC10
Care for Education
4.16, EC10
Care for LEGO Local Communities
4.16, EC10
Capital of Children
SO1
Performance data
2.8, 4.16, EN1, EN4, EN8, EN22, HR2, LA1, LA7, PR2, 
PR5, PR8 EC1, EC10
1-6, 8, 10
Notes to performance data
2.5, LA1, LA13
Definitions and calculation methods
Assurance statement
3.13
GRI and Global Compact overview and index
3.12

The LEGO Group
Aastvej
7190 Billund
Denmark
Tel.: +45 79 50 60 70
www.LEGO.com
Annual Report
In the Annual Report you will find 
detailed information on the LEGO 
Group’s financial results for 2011.
http://aboutus.lego.com