Governance information

The following sections are covered in the governance information chapter:

Business ethics

Strategy, governance and IROs

Sonova is committed to ethical business conduct across the organization at all levels, and in our dealings with stakeholders. We are committed to following the laws and regulations of every country in which we operate, as well as to abiding by our own Code of Conduct and other internal policies and standards. Business ethics is defined as shaping corporate culture and following our Code of Conduct by fighting fraud, corruption, bribery, and anti-competitive practices, along with whistle-blower protection.

Material impacts, risks and opportunities related to business ethics:

IRO (risk assessed as if unmitigated)

Occurrence

Expected time horizon

Risk: Sustainability regulations The sustainability-related regulatory landscape is quickly changing and becoming more fragmented. Not being able to comply with existing and upcoming regulations (in time) can lead to reputational damage and fines.

Entire value chain

Increase in short-, medium-, long-term

Risk: Ethical behavior Unethical behavior and non-compliance with legal requirements can lead to the loss of large contracts or key accounts.

Entire value chain

Increase in short-, medium-, long-term

Risk: Protection of whistleblowers Whistleblowers play an important role in maintaining ethical conduct. A lack of their protection can lead to reputational and legal risks.

Entire value chain

No change expected

To conduct business ethically is a priority and the foundation of delivering on our strategy and providing value to our customers and consumers. We operate in a global legal environment that requires a proactive approach to uphold high standards. This includes setting and communicating our standards, training our employees, undertaking our due diligence process, and taking mitigating actions. For the regulatory risks, the expected increase in short-, medium- and long-term is foreseen due to the increasing amount and fragmentation of legislation as well as due to business growth.

The ultimate oversight for business ethics lies with the Board of Directors. The Audit Committee receives quarterly compliance reports, and an annual compliance report is provided to the Board of Directors. The Compliance and Digital Ethics committee, which is composed of Management Board members, reviews and assesses adherence to compliance standards by individual business units and Sonova as a whole. The Compliance and Data Privacy function oversees adherence to the policies and standards. This function is headed by the Senior Director Compliance and Data Privacy who reports to the Group General Counsel, and with a dotted line to the CEO and the Chair of the Audit Committee. In addition, business ethics and adherence to regulations and policies are part of the internal audit process for Group functions and at a Group company level. The results of the internal audits are presented to the Audit Committee.

Policies and actions

Sonovaʼs Code of Conduct defines general principles for ethical behavior and applies to all employees of the Sonova Group, its subsidiaries, and any third parties such as distributors, agents, or suppliers while they are performing work for Sonova. An acknowledgment of the Code of Conduct is part of every new employment and third-party contract. The Code of Conduct is approved by the Board of Directors, reviewed regularly, revised when necessary, and governs all relevant aspects of Sonovaʼs business operations. It covers compliance with laws and regulations, conflicts of interest, and anti-competition, along with Sonovaʼs commitment to social and environmental responsibility such as human rights, diversity and inclusion, non-discrimination, and workplace safety. Sonovaʼs Code of Conduct training is mandatory for all employees worldwide and is delivered through our eLearning platform or periodically via classroom training for employees who do not have access to a computer in performing their role. It provides guidance on how to act with integrity and how to identify and report potential violations such as conflict of interest, harassment, fraud, discrimination, corruption, or breach of secrecy. Third parties are regularly instructed to ensure adequate understanding and compliance with the Code of Conduct.

The principles of the Code of Conduct are further refined in various internal guidelines and policies, including – but not limited to – antibribery, interactions with hearing care professionals, anti-competitive practices or infringement of intellectual property, human rights, data protection, securities trading, public disclosure, and reporting. Non-compliance with the Code of Conduct or Sonovaʼs internal policies and guidelines triggers disciplinary action, up to and including termination of the employment contract. Sonovaʼs distributors, suppliers and vendors go through an onboarding due diligence process before being contracted for their services. This helps ensure that our upstream and downstream partners conduct their business in accordance with Sonovaʼs Code of Conduct and in compliance with the relevant individual policies. In addition, Sonovaʼs Supplier Code of Conduct also serves as a binding principle for its suppliers. Suppliers are required to provide written certification that they will always adhere to these requirements in all of their business transactions, operations, goods, and services pertaining to Sonova.

Sonovaʼs Anti-Bribery Policy prohibits all forms of corruption and provides the framework for ethical interaction with customers, consumers, and third parties – with a particular focus on Sonovaʼs interactions with hearing care professionals (HCPs) and health care organizations. The Anti-Bribery Policy has been communicated to all Sonova employees, and third parties must commit to complying with the principles described in the Anti-Bribery Policy. The content of the Anti-Bribery Policy is integrated in the annual mandatory Code of Conduct training and in addition, mandatory yearly training on the Anti-Bribery Policy has been rolled out to employees in defined high-risk functions such as sales and marketing, finance, as well as senior and middle management and Group company roles such as Managing Directors and company controllers. The training offers an in-depth understanding of anti-bribery principles, incorporating case studies and real-world applications. Sonovaʼs Global Competition Law Policy describes the basic principles of fair competition while conducting business. All Sonova employees worldwide have access to the policy and must comply with the principles it sets out.

Sonova strongly encourages every employee, contractor or other stakeholder who knows of or suspects a violation of applicable laws, regulations, the Code of Conduct, or related internal policies and procedures to report it through the SpeakUp reporting platform. To further support the culture of SpeakUp, Sonova has implemented a SpeakUp Policy which outlines the escalation process to handle and report SpeakUp complaints. The complaints are classified according to their impact (global/local) and/or the implicated person. The escalation process includes the handling of local matters by local management under the guidance and oversight of the Global Compliance team. All matters with global impact (both in severity and/or where senior members of management are implicated) are investigated by the Global Compliance team. Sonovaʼs SpeakUp platform and process are compliant with the EU Whistleblower directive and have been audited and verified by external auditors. Employees may report a concern to their line manager, their local HR function, a compliance manager, or directly via the SpeakUp platform, which is available online and via phone. The SpeakUp platform is operated by an independent third-party provider and ensures the anonymity of the reporter. We also include the SpeakUp Policy in our annual Code of Conduct training for all employees.

All reported violations are promptly investigated and treated confidentially to the extent that it is reasonably possible to do so. Sonova does not tolerate any form of retaliatory action against any employee who, in good faith, reports suspected wrongdoing or complains about violations of the Code of Conduct or other internal policies. The Audit Committee is informed quarterly about concerns received through the SpeakUp process, the number and types of cases, and the measures taken. Regular training programs on the SpeakUp process reinforce the importance of reporting violations, along with the process and channels for doing so. SpeakUp statistics are published on Sonovaʼs internal platforms to increase trust and assure employees that concerns are addressed promptly.

In the 2024/25 financial year, Sonova revised the due diligence process for business partners, including suppliers and distributors. The revised process incorporates pre-engagement assessment to ensure that new partners align with our commitment to ethical business practices and core values. In addition, our newly launched Supplier Code of Conduct reinforces our dedication to responsible and sustainable business operations across the value chain by clearly outlining our expectations for upstream value chain partners and emphasizing critical areas such as ethical behavior, the protection of human rights, and the reduction of environmental impact.

Performance metrics and targets

Key ESG target:
We achieve an annual on-time employee Code of Conduct training completion rate of >95%.

In the 2024/25 financial year, the target was achieved with an overall on-time completion rate of 98%. We remain committed to achieving a high Code of Conduct training completion rate for the coming financial year.

On-time completion rate of Code of Conduct training 
✔ Data externally assured (limited assurance)

% of employees that completed the Code of Conduct training on time during the annual launch1

2024/25

2023/24

2022/23

On-time Code of Conduct training completion rate

98.0

97.4

93.8

1)For definition and methodology see Sustainability note 4 - Other social topics.

In the 2024/25 financial year, a total of 245 SpeakUp complaints were reported. All allegations were promptly addressed by the internal investigations team, supported by external experts as needed. 34% of the complaints were substantiated and followed up with appropriate actions ranging from verbal or written warnings up to termination of employment.

SpeakUp complaints
✔ Data externally assured (limited assurance)

Number of SpeakUp complaints1

2024/25

Total complaints

Substantiated complaints

Number of SpeakUp complaints

245

84

1)For definition and methodology see Sustainability note 5 - Business ethics.

No fines or non-monetary sanctions for non-compliance, including violation of anti-corruption and anti-bribery laws were levied against Sonova in the 2024/25 financial year.

Supplier relations

Sonova is committed to building and maintaining responsible and fair partnerships with our suppliers, and we have integrated environmental, social, and governance considerations into our supplier selection and management. In the 2024/25 financial year, we sourced direct materials from 933 suppliers across our businesses. Over 95% of our supplier relationships have spanned more than 5 years, reflecting stability and trust. Sonovaʼs relations with suppliers are guided by the Sonova Supplier Code of Conduct, the Sonova Code of Conduct and the General Conditions of Purchase, forming the foundation of all supplier agreements. Suppliers must certify in writing that they will always comply with these standards and principles in all of their Sonova-related dealings, activities, products, and services. Sonova includes this certification in all supply agreements and periodically requests suppliers to renew their adherence.

In 2024/25, we continued to embed sustainability in our core procurement processes. Sustainability remains an integral part of the predictive procurement risk assessment matrix and critical supplier assessment process, both based on EcoVadis scorecards and risk pre-screening. Sustainability requirements are also increasingly included in new supplier agreements and RFx (request for proposal, information, or bid) processes. Sustainability aspects such as ESG risk profiles, material compliance and decarbonization potential are discussed monthly within the procurement function and we offer training on the topic for buyers and category leaders. Our suppliers who register for an EcoVadis assessment also receive access to EcoVadis Academy e-learning courses. We further support our suppliers through one-to-one engagement about their specific needs, such as building their decarbonization capability, successfully completing the EcoVadis assessment, or creating corrective action plans.

Key ESG target:
We aim to conduct assessments of >90% of direct material suppliers with potential high ESG risk by 2024/25.

During the 2024/25 financial year, we expanded the scope of the target to include direct material suppliers for our Consumer Hearing business and our Hearing Instruments business. Out of 706 relevant suppliers screened, 20 were identified as high or very high inherent ESG risk, and these suppliers were requested to self-assess via EcoVadis. By the end of the 2024/25 financial year, 90% of the high or very high ESG risk suppliers were assessed, reaching our target.

Assessed high ESG risk suppliers
✔ Data externally assured (limited assurance)

% of high ESG risk suppliers that have been assessed in EcoVadis

2024/25

2023/24

2022/23

High ESG risk suppliers assessed

90%

100%

78%

Suppliers with low assessment scores are engaged and helped to develop an action plan to improve their practices. In 2024/25, one supplier was identified with improvement needs and engaged to put an action plan in place to ensure meaningful improvement. In addition to the assessment of high ESG risk suppliers, 20 suppliers (based on largest spend, high carbon emissions and strategic tenders) were asked to conduct the self-assessment. In total, 77% of our direct material spend in 2024/25 was covered by the EcoVadis assessments. In addition, our Consumer Hearing business conducted four onsite audits, and our Hearing Instruments business more than 75 supplier visits, which included assessment and discussion of sustainability aspects.

Sonova maintains and continuously assesses a critical supplier list, which included 30 suppliers at the end of the 2024/25 financial year. Critical suppliers include those whose materials have a direct impact on the performance of our products or come into direct contact with the skin of users, those whose items or materials are not substitutable and those who supply high volumes. The classification of critical suppliers is carried out at the beginning of each new supplier relationship and is reviewed regularly.

Public affairs

Sonova operates in a highly regulated environment, and our public affairs efforts focus on active engagement in public discussions and providing insights on evolving policy changes. These changes include regulations affecting the market placement of hearing instruments and consumer products, as well as public access to medical technology. We work to raise awareness about the societal impact of hearing loss and the benefits of hearing care, all while upholding high standards of business ethics and integrity in compliance with applicable laws. In line with our Global Anti-Bribery Policy, Sonova does not permit donations to political parties.

To share our specialist knowledge and support high quality standards for hearing instruments and cochlear implants, we participate actively in multiple associations and external initiatives, including:

  • European Hearing Instrument Manufacturers Association (EHIMA)
  • Hearing Industries Association (HIA)
  • Medical Device Manufacturers Association (MDMA)
  • Hearing Instrument Manufacturersʼ Patent Partnership (HIMPP)
  • Hearing Industry Research Consortium (IRC)
  • European Telecommunications Standards Institute (ETSI)

Sonova is actively represented on the governance bodies of several key associations. Our CEO, Arnd Kaldowski, serves as the current President of EHIMA. Stefan Launer, VP of Audiology and Health Innovation, is the Chair of HIMPPʼs Board of Directors. Alistair Simpson, President/GVP of Cochlear Implants, is a board member of MDMA, and Nicholai Dessypris, President of Sonova USA, is a board member of HIA. We are also involved in various professional and scientific associations related to our field. In November 2024 under Sonovaʼs leadership, EHIMA launched a sustainability committee to share best practices and improve understanding of ESG metrics and regulations affecting the sector. Since 2016, Sonova has been a signatory to the UN Global Compact and is part of both the global and Swiss networks.

In the 2024/25 financial year, we contributed more than CHF 1.44 million in membership fees to trade associations and non-commercial organizations. Our largest contributions went to the HIA, EHIMA and Swiss Medtech. We made no contributions to political organizations, parties, candidates, ballot measures, or referendums.

Animal welfare

We recognize the importance of animal welfare in advancing medical research and are committed to ethical practices and the responsible treatment of animals in compliance with international standards. Sonova does not conduct any animal testing in-house and works with only a small number of third-party organizations. We adhere to ISO 10993-1, which requires animal testing in certain cases to demonstrate the biological safety of medical devices that come into contact with the human body. As part of our research contributions, we provide components of cochlear implants to a few selected research centers and universities. We are dedicated to the Three Rs principle – replacement, reduction, and refinement – to minimize the need for animal testing.

Three Rs principle

Description

Replacement

• We use non-animal alternative methods, including testing with 3D skin models or assessment with computational toxicology models, where these methods are appropriate and are accepted by regulatory bodies. • We promote the development and regulatory acceptance of new in-vitro methods by collaborating with test method developers and actively participating in working groups of the international standardization process.

Reduction

• We apply strategies to reduce the number of animals used in testing. • We strive to avoid completely any unnecessary or duplicated testing by using previously evaluated or historically established biologically safe materials whenever possible and taking advantage of prior research among the various Sonova companies around the world. • We emphasize risk assessment to clearly evaluate any need for animal testing.

Refinement

• Whenever possible, we select test methods that minimize the distress caused to animals. • We conduct all animal testing for biological safety evaluations through appropriately accredited testing laboratories in which all tests are carried out in accordance with good laboratory practice. We conduct animal testing for research collaborations only through universities and research laboratories where experiments are reviewed, approved, and overseen by the respective ethics committees.