exo-is/governance-reporting-on-listed-companies huggingface dataset:
Keyword: corruption
confirmed incidents of violation of anti-corruption laws occurred in 2022. 
206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices and their outcomes
No anti-trust regulatory or enforcement action was initiated in 2022. Also refer to the “Contingent Liabilities” section of Linde’s annual 10K filing. 
Spotlight: Water Management at Iguatama
Water scarcity and lack of access to clean water are global challenges affecting individuals, communities, and industries, and the availability 
of water is projected to be further impaired by the effects of climate change.  Linde utilizes water in its operations, primarily for cooling 
processes and in hydrogen production and makes efforts to conserve water and minimize impacts.  As a result, more than 75 percent of 
global
Keyword: corruption
not limited to, incidents of forced or child labor, corruption and bribery, and failure to 
comply with the SCOC’s environmental protection requirements. 
• Integrity Hotline (3) provides various ways of reporting potential issues for employees or 
third parties. 
• No remediation actions as the company received no 
indications of human rights violations that would 
require measures beyond the already established 
mitigation plans.  
• In case of material breach of the SCOC, Linde’s Ts&Cs 
note that may terminate the business relationship, 
subject to contract conditions or other rights or legal 
grounds. 
 
Applicable 
Customers 
• Product safety management steers product stewardship. 
• Worldwide tracking of relevant products and their application with respect to potential 
health and environmental
Keyword: corruption
Anti-corruption 
GRI 3: Material  
Topics 2021 
3-3 Management of material 
topics 
See Sustainable Development 
Report, pages 47–48. 
 
GRI 205: Anti-corruption 
2016 
205-1 Operations assessed for 
risks related to corruption 
See Sustainable Development 
Report, page 55. 
 
205-2 Communication and 
training about anti-corruption 
policies and procedures 
See Sustainable Development 
Report, page 55. 
 
205-3 Confirmed incidents of 
corruption and actions taken 
See Sustainable Development 
Report, page 55. 
 
Anti-competitive Behavior 
GRI 3: Material  
Topics 2021 
3-3 Management of material 
topics 
See Sustainable Development 
Report, pages 47–48. 
 
GRI 206: Anti-competitive 
Behavior 2016 
206-1 Legal actions for anti-
competitive behavior, anti-
Keyword: tax
the impact of tax, environmental, healthcare and other legislation and government regulation in jurisdictions in which the company operates; the cost and 
outcomes of investigations, litigation and regulatory proceedings; the impact of potential unusual or non-recurring items; continued timely development 
and market acceptance of new products and applications; the impact of competitive products and pricing; future financial and operating performance of 
major customers and industries served; the impact of information technology system failures, network disruptions and breaches in data security; and the 
effectiveness and speed of integrating new acquisitions into the business. These risks and uncertainties may cause future results or circumstances to diffe
Keyword: tax
* Adjusted after-tax return on capital is a non-GAAP measure. For definition and reconciliation, please see Appendix to the Investor Teleconference Presentation Fourth Quarter 2022.
** CO₂e: CO₂ equivalents
*** GHG: Greenhouse gas
How We Create Economic, Environmental and Social Value
A global corporation with a presence in more than 80 countries
• Supported 65,010 employees globally with personnel expenses totaling $5.7 billion in 2022, 
including salaries, benefits, Social Security contributions and pensions, and share-based compensation
Committed to Diversity and Inclusion
Commitment to Safety: Approximately 5 million hours of safety training delivered in 2022 to 
employees and contractors
• 28 percent female employees worldwide (28 percent female professio
Keyword: tax
• Adjusted after-tax return on capital*: 22.9 percent
• Industry-leading sale of gas project backlog of
$5.7 billion
Local business model
• Linde manufactures and distributes nearly all 
its products and manages 2+ million industrial 
customers on a regional basis
CUSTOMERS AND INVESTORS
EMPLOYEES
10
Linde 2022 Sustainable Development Report
About Linde
Mission, Vision and Values 
Linde's Sustainable Development Report (SDR) demonstrates how 
we deliver on our mission of making our world more productive—
sustainably. 
We live our mission every day by providing high-quality solutions, 
technologies and services that are making our customers more 
successful and helping to sustain and protect our planet.
Our vision is to be the best performing global industrial
Keyword: tax
introduction of tax credits.
In 2022, Linde made several meaningful project announcements that 
demonstrate our commitment to clean energy, such as:
•
35 MW PEM electrolyzer to be installed at Niagara Falls, NY, U.S., that 
will double Linde’s green hydrogen production in the U.S. 
•
Awarded funding from California’s Energy Commission for the first of 
several planned 5MW PEM electrolyzers at the Ontario facility 
•
Awarded funding from Germany’s Decarbonization of Industry funding 
program and FIDed project to jointly build, own and operate a large-
scale carbon capture and liquefaction facility with Heidelberg Materials
•
Awarded contract for supply of clean hydrogen and other industrial 
gases to OCI’s new world-scale blue ammonia plant in Beaumont, 
TX, U
Keyword: tax
to discuss energy costs, energy efficiency, tax and trade-related issues and the 
environmental benefits of Linde technologies.
40
Linde 2022 Sustainable Development Report
Global
Holds a position 
on the governance 
body
Participates 
in projects or 
committees
Provides substantive 
funding beyond 
routine membership 
dues
Views membership 
as strategic 
Hydrogen Council
x
x
o
x
International Oxygen Manufacturers (IOMA)
x
x
o
o
Americas
American Chemistry Council (ACC)
o
x
o
x
American Fuel and Petroleum Manufacturers Association (Associate Member)
o
x
o
x
American Institute of Chemical Engineers (AICHE)
o
x
o
x
Business Council for International Understanding
o
x
o
x
California Manufacturers and Technology Association
x
o
o
x
Compressed Gas Association (CGA) (U.S.)
x
x
o
x
HR Policy I
Keyword: tax
competitive Behavior, Tax 
 
Organizational Responsibility, Accountability and Incentives 
Linde's Chief Executive Officer (CEO) and the Board of Directors are accountable for the economic health of the company. Responsibility for performance 
lies with the businesses. Performance is consolidated and reported to the Board by the responsible executives: Chief Compliance Officer (CCO), 
Executive Vice President (EVP) and Chief Human Resources Officer (CHRO), vice presidents of Safety, Health, Environment and Quality (SHEQ), 
Sustainability and the Center of Excellence (COE), and Procurement leadership.  
 
Integrity is a corporate value, an expectation of behavior and non-negotiable. Linde’s Code of Business Integrity (CBI) affirms its commitment to 
fairness, transp
Keyword: tax
Tax Strategy 207-1, 207-2, 207-3 
Linde is a leading industrial gases and engineering company with more than 65,000 employees globally, serving customers in more than 80 countries 
worldwide. Linde delivers innovative and sustainable solutions to customers and creates long-term value for all stakeholders. The company is making 
our world more productive by providing products, technologies and services that help customers improve their economic and environmental 
performance in a connected world.
The nature of Linde’s industrial gases business is substantially local. As a result, Linde generates income and pays taxes in jurisdictions in which it has 
business operations. In case of cross-border transactions, the respective Linde parties endeavo
Keyword: tax
economic growth; hence the company supports tax policies that promote capital investment.
Linde is committed to developing new technologies that help its customers increase productivity and achieve environmental benefits in a wide range of 
industries. Linde also supports tax policies that promote innovation and protect the value of intellectual property. Linde’s intellectual property assets 
are primarily developed and maintained in the U.S. and Germany, both geographies that are not typically regarded as low-tax countries. Transfer of 
these assets to low-tax jurisdictions is not part of Linde’s tax planning.
Linde, as a multinational company, supports the continued expansion of a network of bilateral income tax treaties to reduce barriers to cross-border
investment and eliminate doub
Keyword: tax
For all these reasons, Linde advocates for tax policies that drive economic growth, particularly in areas of increased engineering efficiency and 
enhanced local production and development.
Linde has adopted a Code of Business Integrity (CBI), as well as its corporate vision, mission and values — safety, integrity, accountability, inclusion and 
community. The principles in the CBI set out Linde’s commitment to integrity, to its employees, to the company, to its customers and partners and to its 
communities. The CBI provides guidance and insight to navigate compliance and ethical questions and to promote an overall culture of compliance. One 
key guiding principle is full compliance with applicable laws and regulations.
In line with its CBI, Linde manages its tax affairs in a responsi
Keyword: tax
ble and transparent manner that complies with applicable tax legislation. Linde maintains 
processes and controls designed to minimize the risk of errors that could impact the amount of tax that it pays. These processes and controls are 
regularly monitored, reviewed and tested, and support the preparation and submission of its tax returns.
Linde has a responsibility to its shareholders to maximize returns and structure its affairs in an efficient manner, including taxes.
Linde’s effective tax rate and tax exposures are reviewed annually with the Audit Committee of the Board of Directors. Linde discloses its effective tax 
rate publicly, together with the associated risks for the company’s future tax rate, in the company’s 2022 Annual Report (10K) on its website.  
50 
Linde 2022 Sustainable Develop
Keyword: tax
Earnings Before Interests and Taxes (EBIT) are included in Linde’s financial results. Linde does not collect eKPI data for minority holdings and other 
holdings that are not reporting their financials. EKPIs for JVs, which are not fully consolidated into the company financials (at-equity JVs), are collected 
but are only included in external greenhouse gas (GHG) reporting under Scope 3.
301-1 Materials used by weight or volume  
Raw materials are procured through a global Procurement organization under global Procurement standards and expectations that include requirements 
for material sustainability. Linde has supplier expectations that manage sustainability in its supply chain.
Non-Renewable Materials Used
Linde estimates that approximately 1 percent by weight of the raw
Keyword: tax
regulations include the California CAT and the Singapore carbon tax, for example. For details on the 2022 carbon regulation schemes applicable to 
Linde, see Linde’s most recent CDP report, which will be available at the end of July at:                                                              
https://www.linde.com/-/media/linde/merger/documents/sustainable-development/2023-cdp-response-climate-change.pdf.  
 
Calculation Methodology 
Hydrogen plants, which represent the largest source of Linde’s Scope 1 emissions, consume natural gas, both for fuel and feedstock. To determine 
Scope 1 emissions, the amount of carbon produced as product is subtracted. In addition, Linde calculates Scope 1 emissions from gas losses (during 
production and filling processes). These are calculated for nitrous oxide manufa
Keyword: tax
tax-exempt organizations and lobbying firms. In 2022, the total contribution was approximately $3 million, of which more than half was for trade 
associations and tax-exempt organizations.  The actual amounts of the memberships that relate to policy is significantly less. See SOC (18) and SOC (19).
There was no spending on ballot measures or referendums. Political contributions receipts and disbursements are reported in detail and disclosed 
publicly. This detail can be found on the U.S. Federal Elections Commission website at:
https://www.fec.gov/data/committee/C00283440/?cycle=2022.
Linde’s political contributions policy is provided at: https://www.linde.com/-/media/linde/merger/documents/compliance-policies/political-
contributions-lobbying
Keyword: tax
Associations and Tax-exempt 
Organizations* and Lobbying Firms
$1,487
$3,809
$3,329
$3,053
Total 
$1,500
$3,828
$3,339
$3,060
SOC (19): Policy-Related Spending
Units: USD, thousands
* Includes policy-related portion of membership only
416-1 Assessment of the health and safety impacts of product and service categories
Minimizing Product Risk
Linde has a team of business, engineering, operations and safety professionals that examine the potential environmental, health and safety risks of 
every new product. The entire life cycle of the product — from raw material procurement through manufacturing, distribution, use and disposal — is 
reviewed. 403-7
Significant product or service categories are covered by and assessed for compliance with these procedures.
• Risk
Keyword: tax
Tax 
GRI 3: Material  
Topics 2021 
3-3 Management of material 
topics 
See Sustainable Development 
Report, pages 47–48. 
 
GRI 207: Tax 2019 
207-1 Approach to tax 
See Sustainable Development 
Report, page 49. 
 
207-2 Tax governance, 
control, and risk management 
See Sustainable Development 
Report, page 49. 
 
Linde 2022 Sustainable Development Report  
123 
 
207-3 Stakeholder 
engagement and 
management of concerns 
related to tax 
See Sustainable Development 
Report, page 49. 
 
207-4 Country-by-country 
reporting 
See pages 22 and 59 of the 
2022 Annual Report (10K) at: 
https://investors.linde.com/-
/media/linde/investors/docu
ments/full-year-financial-
reports/2022-linde-annual-
report-to-
shareholders.pdf?la=en. 
 
Environmental
Keyword: governance
Governance............................................................................................................................................................................................33
Risk Management..................................................................................................................................................................................36
Engaging Stakeholders..........................................................................................................................................................................37
Economic Topics .........................................................................................................................................................
Keyword: governance
Responsible corporate governance is a key prerequisite for Linde’s 
business success. This means ensuring compliance with the law, 
rules and regulations and voluntary commitments. Linde strives 
continuously to achieve its goals ethically and with the highest 
integrity. Interaction between management, employees and Linde’s 
business partners is expected to be transparent and respectful, 
consistent with our Code of Business Integrity (CBI). Linde’s 
governance of ethics and integrity is described in the management 
approach section for Material Economic Aspects, page 47.
Organization
Linde is a leading global industrial gases and engineering company 
with 2022 sales of $33 billion. The reporting currency is the U.S. dollar. 
All amounts are shown in U.S. dollars ($), un
Keyword: governance
Social and Governance (ESG) investors. See Linde SASB Index at: 
https://www.linde.com/about-linde/sustainable-development/
reporting-center.
2-4 Restatements
None.
Changes in Reporting
Reporting Pro Forma 2018 and Reporting of Numbers for Linde’s SD 
2028 Targets
Data is reported consistent with Linde’s 2021 Sustainable 
Development Report and utilizes pro forma information, as previously 
reported.
“Pro forma” definition: Pro forma means a calculated number or 
result that is not related to the official financial boundaries, reporting 
scope or period. A pro forma number serves as an indicator of what 
the result of a newly merged company would theoretically look 
like if the new company had reported for the complete year and 
applied new company reporting bo
Keyword: governance
others. As indicated in the Governance section, the Board Audit 
Committee reviews certification of employees’ understanding of, 
and compliance with, the company’s Business Integrity and Ethics 
Policy.
In addition, Linde requires that 100 percent of relevant third 
parties whose activities could expose Linde to risk adhere to its 
CBI and Compliance with Laws and Business Integrity and Ethics 
policies, or their own equivalent compliance policies. Linde utilizes 
contractual terms and awareness programs to foster adherence, as 
through its Supplier Code of Conduct.
Integrity & Compliance
Linde Targets*
2018
2020
2021
2022
Target
Status
100% employee certification to Linde Code of Business Integrity 
(CBI), annual % employees certifying
100
100
99
100
100
*All Targets terminat
Keyword: governance
Corporate Governance  2-9
A comprehensive review of Linde’s corporate governance framework 
is provided on our website at: http://www.linde.com/about-linde/
corporate governance. It is also included in the Proxy Statement for 
the 2022 Annual General Meeting of Shareholders in the Corporate 
Governance and Board Matters section. The Proxy Statement also 
contains a section on Environmental, Social and Governance Highlights.
Linde’s Board of Directors consists of 10 Board members. Eight are 
independent non-executive directors. Linde’s CEO Sanjiv Lamba serves 
as an executive director, and the Chairman of the Board Stephen 
Angel was formerly Linde's CEO. The Board currently has five standing 
committees: Audit Committee, Human Capital Committee, Executive 
Com
Keyword: governance
mittee, Sustainability Committee and Nomination and Governance 
Committee. Each is comprised of only independent directors, except for 
the Executive Committee, of which the Chair and CEO are members.
The Board maintains oversight of the company's values and strategy. 
Each year, it conducts a comprehensive long-term strategic review of 
the company's outlook and business plans and provides advice and 
counsel to management regarding the company's strategic issues. 
Linde’s values are considered integral to its long-term sustainable 
success, and executive compensation rewards performance in financial 
and strategic non-financial areas. The Board’s role in these areas, as 
well as in risk management, is described in the company’s annual Proxy 
Statement in the Corporate Governance and Board Matters Se
Keyword: governance
The Board has oversight of key aspects of the corporate governance 
structure in areas of particular interest to the sustainability community, 
such as director independence; split roles of Chairman and CEO; 
appropriate board committees; board effectiveness; shareholder 
outreach and alignment with long-term shareholder interests; 
mechanisms to avoid conflicts of interest; board diversity; limits to 
service; industry experience; and a comprehensive sustainability 
program.
Board members are nominated by the Nomination and Governance 
Committee for election by the shareholders. Nominees are elected each 
year at the Annual General Meeting. The Nomination and Governance 
Committee believes that each director has an established record of 
accomplishment in areas relevant to our business and objectives, an
Keyword: governance
possesses the characteristics identified in our Corporate Governance 
Guidelines as essential to a well-functioning and deliberative governing 
body, including integrity, independence and commitment.
Each Board member has executive management and director oversight 
experience in most, if not all, areas that the Board considers critical 
to conduct of the company’s business, including public policies as 
they affect global industrial corporations, compliance, corporate 
governance, productivity management, safety management and 
sustainable development.
Governance of Non-Financial Matters  2-12
Linde has established five core values: Safety, Inclusion, Accountability, 
Integrity and Community. These are the basis of what the company 
stands for and how it behaves. A code of ethics has been adopted that 
pro
Keyword: governance
Governance of Linde's CBI is described in the Performance section as it 
relates to an SD 2028 target.
It is the view of Linde’s Board that non-financial issues are a component 
of the company's values, culture and performance expectations, and 
are a basis on which employees drive financial results. The Board has 
confirmed the importance of setting non-financial objectives as part of 
variable compensation to reinforce leadership’s focus on maintaining 
a culture that supports both short and long-term sustainable results. It 
has established non-financial goals with respect to elements such as 
safety, environmental responsibility, global compliance, productivity 
and talent management. These measures are described in Linde’s Proxy 
Statement. Annu
Keyword: governance
achieve those objectives. The Nomination and Governance Committee 
periodically reviews the company’s guidelines and policies governing 
its response to important broad public policy issues in the areas of 
corporate social responsibility and corporate citizenship.
Alignment with Compensation 
In January 2022, the Human Capital Committee approved the design 
and goals for the Company’s annual performance-based variable 
compensation program in 2022. In recognition of the importance of the 
Company’s standards for, and impacts from, environmental, social, and 
governance (ESG) considerations, the non-financial component will 
now be comprised of three pillars, each with their own weights. See 
Proxy Statement. 
Coupled with its assessment of performance related to financial goals, 
the Human Cap
Keyword: governance
Governance
2-9
34
Linde 2022 Sustainable Development Report
2022 Strategic and Non-Financial Performance Goals
Examples of 2022 actions include:
•
Reliably and cost effectively delivered products and services to 
customers, despite the challenges posed by global supply chain issues, 
the war in Ukraine, the tight labor market, the energy crisis and the 
continued pandemic.
•
Environmental Sustainability efforts made good progress with 
reduction in greenhouse gas intensity, with continuous year-over-year 
decrease through end of 2022 and on track to achieving a 35 percent 
reduction by 2028.
•
More than $500 million investments in decarbonization initiatives and 
projects since 2018.
•
Maintained DSJI World constituency for 20th consecutive year, 
re
Keyword: governance
Sustainable Development Governance               
Sustainable development is overseen by the Board and executive 
leadership and integrated throughout the company.
Linde’s Board of Directors: In 2021, the Board approved new climate 
change goals, including the 2035 absolute GHG reduction target and 2050 
climate neutrality ambition. The Board previously approved the SD 2028 
targets, and the Board reviews progress on all targets.
In 2021, the Board added a new Sustainability Committee to focus on 
environmental matters and clean energy initiatives. The committee 
receives regular updates on progress against targets, strategy, reporting of 
aspects and emerging topics from the Vice President, Sustainability.
Additionally, the former Compensation Committee was named the Human
Keyword: governance
linde/corporate-governance. In addition, the Board reviews safety matters 
at each meeting. A compliance presentation is made annually by the Chief 
Compliance Officer. A presentation is made annually by the Chief Human 
Resources (HR) Officer on Linde’s program in Diversity and Inclusion.
The Executive Leadership Team is the highest level leadership team. 
They are responsible for economic, environmental and social topics, and 
oversee and approve sustainable development strategies and programs. In 
2022, they reviewed presentations related to ESG that were prepared for 
the Board.
Members of the Executive Leadership Team report directly to the CEO and 
are responsible for their respective regional operating segments of the 
Americas, APAC and EMEA, as well as Engi
Keyword: governance
on the governance 
body
Participates 
in projects or 
committees
Provides substantive 
funding beyond 
routine membership 
dues
Views membership 
as strategic 
Hydrogen Council
x
x
o
x
International Oxygen Manufacturers (IOMA)
x
x
o
o
Americas
American Chemistry Council (ACC)
o
x
o
x
American Fuel and Petroleum Manufacturers Association (Associate Member)
o
x
o
x
American Institute of Chemical Engineers (AICHE)
o
x
o
x
Business Council for International Understanding
o
x
o
x
California Manufacturers and Technology Association
x
o
o
x
Compressed Gas Association (CGA) (U.S.)
x
x
o
x
HR Policy Institute
o
x
o
x
Louisiana Chemical Association
o
x
o
x
National Enhanced Oil Recovery Initiative (NEORI)
o
x
o
x
NY Chemistry Council
o
x
o
x
Puerto Rico Manufacturers
Keyword: governance
The significance of Linde's economic and governance PFs and targets in the context of external benchmarks and stakeholder priorities is explained in
the Materiality, Priorities and Targets: SD 2028 section, page 17.  
204-1 Proportion of spending on local suppliers
Note: This section responds to 204-1 and also responds to 2-6 and 2-8 
Policy
Linde’s Supplier Code of Conduct (Supplier Code) is available on its website at: https://www.linde.com/about-linde/global-procurement. 
Suppliers, contractors and third parties play a critical role in Linde’s ability to operate and provide products and services to its customers. Suppliers' 
actions and practices also reflect on Linde. Therefore, the company chooses suppliers carefully based on merit and a due diligence process. Linde 
expects suppliers
Keyword: governance
405-1 Diversity of governance bodies and employees
Global Diversity and Inclusion is a formal support function operating under Corporate HR and develops strategies and initiatives within four pillars: 
Talent Management, Inclusive Culture, Managerial Training and Marketplace Branding.
Linde's Board of Directors, CEO and Executive Leadership Team monitors results by business group in diverse representation at all levels of the talent 
pipeline, including senior leadership, talent acquisition, talent development and advancement, managerial training and workplace culture and 
engagement. This oversight, which includes quarterly reviews, provides accountability for business leaders and ensures that diversity and inclusion is 
sustained as a top priority for the organizatio
Keyword: governance
• Conflict Minerals: Based on Linde's commitment to governance, compliance and human rights, the most salient human rights issue associated with 
Linde activities and business relationships is the issue of potential "conflict minerals" in its supply chain. Certain minerals (including tin, tantalum, 
tungsten and gold) have been linked with funding killings, violence, rape and other human rights abuses in the Democratic Republic of Congo and 
other conflict zones. These affect all citizens in these regions, particularly women, children and adolescents. 
  
Linde has determined that approximately 12 percent of its 2022 consolidated sales relate to products that Linde manufactures, or contracts to 
manufacture, that may contain necessary conflict minerals. To mitigate potential human rights violations in
Keyword: governance
2) CBI: https://www.linde.com/-/media/linde/merger/documents/corporate-governance/code-of-business-integrity.pdf?la=en&rev=404a1922cef8448ea3c9342d28d94d02 
3) Linde Integrity Hotline information is provided at: https://www.linde.com/about-linde/sustainable-development/reporting-center. 
4) Linde’s Procurement Terms & Conditions are available at: https://www.linde.com/-/media/linde/merger/documents/global-
procurement/linde_general_terms_and_conditions_of_purchase_global-master.pdf?la=en.  
5) Additional activity and reporting are provided for potential suppliers of materials from conflict zones. This is reported annually in Linde’s Form SD and in its Sustainable Development Report, 
both posted on Linde’s website at: http://www.linde.com. 
SOC (17): Human Rights Due Diligence Process  414-2 
Linde 2022 Sustainable Deve
Keyword: governance
2-9 Governance structure 
and composition 
See Sustainable Development 
Report, page 33. See also 
https://www.linde.com/abo
ut-linde/board-of-directors. 
 
2-10 Nomination and 
selection of the highest 
governance body 
See pages 21 and 29 of 
Linde’s Proxy Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html. 
 
2-11 Chair of the highest 
governance body 
See pages 8 and 14 of Linde’s 
Proxy Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html. 
 
2-12 R
Keyword: governance
governance body in 
overseeing the management 
of impacts 
See pages 10–12, 15 and 17 
of Linde’s Proxy Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html. 
 
2-13 Delegation of 
responsibility for managing 
impacts 
See page 11 of Linde’s Proxy 
Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html. 
 
2-14 Role of the highest 
governance body in 
sustainability reporting 
See page 2 of Linde’s 
Sustainability Committee’s 
Charter at 
https://www.lin
Keyword: governance
governance/sustainability-
committee-charter.pdf?la=en. 
2-15 Conflicts of interest 
See pages 19–20 of Linde’s 
Proxy Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html. 
 
2-16 Communication of 
critical concerns 
See page 17 of Linde’s Proxy 
Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html.  
See also page 2 of Linde’s 
Audit Committee’s Charter at 
https://www.linde.com/-
/media/linde/merger/docu
ments/corporate-
governance/audit-
committee-
Keyword: governance
the highest governance body 
See pages 29 and 30–31 of 
Linde’s Proxy Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html.   
 
2-18 Evaluation of the 
performance of the highest 
governance body 
See pages 15–16 of Linde’s 
Proxy Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958b5f
ff-2966-427c-8cb6-
c31bcb7e37b5&shortDesc=Pr
oxy%20Statement%20%28de
finitive%29&format=html.   
 
2-19 Remuneration policies 
See pages 46–53 and 56 of 
Linde’s Proxy Statement at: 
https://irpages2.eqs.com/w
ebsites/lindeplc/English/321
0/us-sec-
filing.html?secFilingId=958
Keyword: governance
207-2 Tax governance, 
control, and risk management 
See Sustainable Development 
Report, page 49. 
 
Linde 2022 Sustainable Development Report  
123 
 
207-3 Stakeholder 
engagement and 
management of concerns 
related to tax 
See Sustainable Development 
Report, page 49. 
 
207-4 Country-by-country 
reporting 
See pages 22 and 59 of the 
2022 Annual Report (10K) at: 
https://investors.linde.com/-
/media/linde/investors/docu
ments/full-year-financial-
reports/2022-linde-annual-
report-to-
shareholders.pdf?la=en. 
 
Environmental  
Materials 
GRI 3: Material  
Topics 2021 
3-3 Management of material 
topics 
See Sustainable Development 
Report, pages 57–59. 
 
GRI 301: Materials 2016 
301-1 Materials used by 
weight or volume 
See Sustainable Development 
Repo
Keyword: governance
405-1 Diversity of governance 
bodies and employees 
See Sustainable Development 
Report, pages 90–91. 
Partial omission. The following is not 
disclosed: Percentage of employees by 
minority group. Reason: Confidentiality 
constraints. Linde considers additional 
information regarding human resources data 
as business confidential and does not 
disclose this publicly. 
405-2 Ratio of basic salary 
and remuneration of women 
to men 
See Sustainable Development 
Report, page 91. 
 
Non-discrimination 
GRI 3: Material  
Topics 2021 
3-3 Management of material 
topics 
See Sustainable Development 
Report, pages 78–79. 
 
GRI 406: Non-
discrimination 2016 
406-1 Incidents of 
discrimination and corrective 
actions taken 
See Sustainable Development 
Report, pages 91–92 .
Keyword: bribe
A Compliance Review Board (CRB) performs quarterly regulatory risk assessments. Dedicated Foreign Corrupt Practices Act (FCPA) and anti-bribery 
audits are also conducted. Since 2012, 51 internal audits have been conducted. These audits are related to anti-trust, anti-bribery and other compliance
matters, and anti-corruption, including the FCPA. Typically, at least three such audits are conducted in any given year.  
Linde operates in certain jurisdictions identified as high risk based on the Corruption Perception Index from Transparency International. The company 
has not identified significant risks other than regular risks that are dealt with through training and certifications of employees.
Linde 2023 Sustainable Development Report 
55
Communication and training about anti-corruption policies and procedures 205-2  
In 2023, Linde’s Board of Directors received training on the C
Keyword: bribe
CBI, which includes a rigorous outline of the FCPA and anti-bribery laws. This is an online training and survey. Training to targeted populations was 
conducted in 2023; the company trained 100 percent of the targeted population.
Confirmed incidents of corruption and actions taken 205-3
Linde takes its commitment to integrity very seriously. Non-compliance with the CBI, depending on the circumstances, can result in serious disciplinary 
action, up to and including termination of employment. Employees are actively encouraged to report suspected complaints and concerns and are 
expected to report violations through several channels, including the Integrity Hotline. Reports through the Integrity Hotline may be made 
anonymously. It is a violation of company policy for any person to retaliate against any indiv
Keyword: bribe
not limited to, incidents of forced or child labor, corruption and bribery, and failure to 
comply with the SCOC’s environmental protection requirements. 
• The Integrity Hotline (3) provides various ways of reporting potential issues for employees 
or third parties. 
• No remediation actions as the company received no 
indications of human rights violations that would 
require measures beyond the already established 
mitigation plans.  
• In case of material breach of the SCOC, Linde’s Ts&Cs 
note that Linde may terminate the business 
relationship, subject to contract conditions or other 
rights or legal grounds. 
 
Applicable 
Customers 
• Product safety management steers product stewardship. 
• Worldwide tracking of relevant products and their application with respect to potential 
health and environmental im
Keyword: corruption
Material Topics for reporting include: Economic Performance, Market Presence, Indirect Economic Impacts, Procurement Practices, Anti-Corruption, Anti-
Competitive Behavior and Tax. 
 
Organizational Responsibility, Accountability and Incentives 
Linde's Chief Executive Officer (CEO) and the Board of Directors are accountable for the economic health of the company. Responsibility for performance 
lies with the businesses. Performance is consolidated and reported to the Board by the responsible executives: Executive Vice President (EVP) and Chief 
Human Resources Officer (CHRO); EVP and Chief Legal Officer; accountable Senior Vice Presidents (SVPs); Chief Compliance Officer (CCO); vice presidents 
of Safety, Health, Environment and Quality (SHEQ), Sustainability and the Center of Excellence (COE); and Procurement leadership.  
 
Integrity is a corporate value, an expectation of beha
Keyword: corruption
Operations assessed for risks related to corruption 205-1, 2-24
Linde administers an annual risk assessment that is circulated to all business managers and functional leaders globally and covers 100 percent of all 
BUs. Potential risks related to corruption are an explicit focus. 
A Compliance Review Board (CRB) performs quarterly regulatory risk assessments. Dedicated Foreign Corrupt Practices Act (FCPA) and anti-bribery 
audits are also conducted. Since 2012, 51 internal audits have been conducted. These audits are related to anti-trust, anti-bribery and other compliance
matters, and anti-corruption, including the FCPA. Typically, at least three such audits are conducted in any given year.  
Linde operates in certain jurisdictions identified as high risk based on the Corruption Perception
Keyword: corruption
Communication and training about anti-corruption policies and procedures 205-2  
In 2023, Linde’s Board of Directors received training on the CBI, which includes anti-corruption policies and procedures. The company also trains all its
relevant employees globally on anti-corruption. The company has an established process to conduct thorough due diligence before contracting third 
parties and agents who interact with the government on the company’s behalf.
Linde’s CBI applies to the company’s directors and employees, including its CEO, CFO and the Senior Vice President and Chief Accounting Officer. This 
CBI, which includes elements of compliance with laws, business integrity and ethics, has been approved by the Linde Board of Directors. To assist 
employees and directors in complying with
Keyword: corruption
Confirmed incidents of corruption and actions taken 205-3
Linde takes its commitment to integrity very seriously. Non-compliance with the CBI, depending on the circumstances, can result in serious disciplinary 
action, up to and including termination of employment. Employees are actively encouraged to report suspected complaints and concerns and are 
expected to report violations through several channels, including the Integrity Hotline. Reports through the Integrity Hotline may be made 
anonymously. It is a violation of company policy for any person to retaliate against any individual who has reported any matter in good faith.
Table SOC (12) provides the aggregate number of hotline reports. Linde also provides a summary of the types of reports received. See the disclosure
Keyword: corruption
they are business confidential. No confirmed incidents of violation of anti-corruption laws occurred in 2023.
Legal actions for anti-competitive behavior, anti-trust and monopoly practices 206-1
No anti-trust regulatory or enforcement action was initiated in 2023. Linde reports material regulatory matters in the “Contingent Liabilities” section of 
Linde’s annual 10K filing.
Environmental Topics
56
Linde 2023 Sustainable Development Report
57
Linde 2023 Sustainable Development Report
Evergreen: Sustaining Ecosystems for the Future
Linde’s commitment to sustainability encompasses a commitment to the natural environment. Employee 
environmental engagement is widely practiced at Linde, and there are many examples of Linde sites working 
alongside local stakeholders and organizations to preserve and protect local ecosystems. 
Tr
Keyword: corruption
not limited to, incidents of forced or child labor, corruption and bribery, and failure to 
comply with the SCOC’s environmental protection requirements. 
• The Integrity Hotline (3) provides various ways of reporting potential issues for employees 
or third parties. 
• No remediation actions as the company received no 
indications of human rights violations that would 
require measures beyond the already established 
mitigation plans.  
• In case of material breach of the SCOC, Linde’s Ts&Cs 
note that Linde may terminate the business 
relationship, subject to contract conditions or other 
rights or legal grounds. 
 
Applicable 
Customers 
• Product safety management steers product stewardship. 
• Worldwide tracking of relevant products and their application with respect to potential 
health and envi
Keyword: corruption
Anti-corruption 
GRI 3: Material  
Topics 2021 
3-3 Management of material 
topics 
See Sustainable Development 
Report, pages 46–47. 
 
GRI 205: Anti-corruption 
2016 
205-1 Operations assessed for 
risks related to corruption 
See Sustainable Development 
Report, page 54. 
 
205-2 Communication and 
training about anti-corruption 
policies and procedures 
See Sustainable Development 
Report, page 55. 
 
205-3 Confirmed incidents of 
corruption and actions taken 
See Sustainable Development 
Report, page 55. 
 
Anti-competitive Behavior 
GRI 3: Material  
Topics 2021 
3-3 Management of material 
topics 
See Sustainable Development 
Report, pages 46–47. 
 
GRI 206: Anti-competitive 
Behavior 2016 
206-1 Legal actions for anti-
competitive behavior, anti-
Keyword: tax
Competitive Behavior and Tax. 
 
Organizational Responsibility, Accountability and Incentives 
Linde's Chief Executive Officer (CEO) and the Board of Directors are accountable for the economic health of the company. Responsibility for performance 
lies with the businesses. Performance is consolidated and reported to the Board by the responsible executives: Executive Vice President (EVP) and Chief 
Human Resources Officer (CHRO); EVP and Chief Legal Officer; accountable Senior Vice Presidents (SVPs); Chief Compliance Officer (CCO); vice presidents 
of Safety, Health, Environment and Quality (SHEQ), Sustainability and the Center of Excellence (COE); and Procurement leadership.  
 
Integrity is a corporate value, an expectation of behavior and non-negotiable. Linde’s Cod
Keyword: tax
Tax Strategy 207-1, 207-2, 207-3 
Linde is a leading industrial gases and engineering company with more than 65,000 employees globally, serving customers in more than 80 countries 
worldwide. Linde delivers innovative and sustainable solutions to customers and creates long-term value for all stakeholders. The company is making 
our world more productive by providing products, technologies and services that help customers improve their economic and environmental 
performance in a connected world. 
 
The nature of Linde’s industrial gases business is substantially local. As a result, Linde generates income and pays taxes in jurisdictions in which it has 
business operations. In case of cross-border transactions, the respective Linde parties ende
Keyword: tax
economic growth; therefore, the company supports tax policies that promote capital investment. 
 
Linde is committed to developing new technologies that help its customers increase productivity and achieve environmental benefits in a wide range of 
industries. Linde also supports tax policies that promote innovation and protect the value of intellectual property. Linde’s intellectual property assets 
are primarily developed and maintained in the U.S. and Germany, both geographies that are not typically regarded as low-tax countries. Transfer of 
these assets to low-tax jurisdictions is not part of Linde’s tax planning. 
 
Linde, as a multinational company, supports the continued expansion of a network of bilateral income tax treaties to reduce barriers to cross-border 
investment and elimina
Keyword: tax
For all these reasons, Linde advocates for tax policies that drive economic growth, particularly in areas of increased engineering efficiency and 
enhanced local production and development. 
 
Linde has adopted a CBI, as well as its corporate vision, mission and values — safety, integrity, accountability, inclusion and community. The principles 
in the CBI set out Linde’s commitment to integrity, to its employees, to the company, to its customers and partners and to its communities. The CBI 
provides guidance and insight to navigate compliance and ethical questions and to promote an overall culture of compliance. One key guiding principle 
is full compliance with applicable laws and regulations. 
 
In line with its CBI, Linde manages its tax affairs in a responsible and transparent man
Keyword: tax
ner that complies with applicable tax legislation. Linde maintains 
processes and controls designed to minimize the risk of errors that could impact the amount of tax that it pays. These processes and controls are 
regularly monitored, reviewed and tested, and support the preparation and submission of its tax returns. 
 
Linde has a responsibility to its shareholders to maximize returns and structure its affairs in an efficient manner, including taxes. 
 
Linde’s effective tax rate and tax exposures are reviewed annually with the Audit Committee of the Board of Directors. Linde discloses its effective tax 
rate publicly, together with the associated risks for the company’s future tax rate, in Linde’s 2023 Annual Report (10k) on its website.   
 
50 
Linde 2023 Sustainable Deve
Keyword: tax
Earnings Before Interests and Taxes (EBIT) are included in Linde’s financial results. Linde does not collect eKPI data for minority holdings and other 
holdings that are not reporting their financials. EKPIs for JVs, which are not fully consolidated into the company financials (at-equity JVs), are collected 
but are only included in external GHG reporting under Scope 3.  
Note that data presented may be rounded.  Therefore, values may appear slightly different from the resulting sum of items in tables or charts.
Materials used by weight or volume 301-1
Raw materials are procured through a global Procurement organization under global Procurement standards and expectations that include requirements 
for material sustainability. Linde has supplier expectations that manage susta
Keyword: tax
Other regulations include the California CAT and the Singapore carbon tax, for example. For details on the 2023 carbon regulation schemes applicable to 
Linde, see Linde’s most recent CDP report, which will be available at the end of September at:                                                              
https://assets.linde.com/-/media/global/corporate/corporate/documents/sustainable-development/2024-cdp-response-climate-change.pdf.  
 
Calculation Methodology 
Hydrogen plants, which represent the largest source of Linde’s Scope 1 emissions, consume natural gas, both for fuel and feedstock. To determine 
Scope 1 emissions, the amount of carbon produced as product is subtracted. In addition, Linde calculates Scope 1 emissions from gas losses (during 
production and filling processes). These are calculated fo
Keyword: tax
tax-exempt organizations and lobbying firms. In 2023, the total contribution was approximately $3 million, of which more than half was for trade 
associations and tax-exempt organizations.  The actual amounts of the memberships that relate to policy is significantly less. See SOC (18) and SOC (19).
There was no spending on ballot measures or referendums. Political contributions receipts and disbursements are reported in detail and disclosed 
publicly. This detail can be found on the U.S. Federal Elections Commission website at:
https://www.fec.gov/data/committee/C00283440/?cycle=2024.
Linde’s political contributions policy is provided at:
https://assets.linde.com/-/media/global/corporate/corporate/documents/compliance-policies/political-contri