Anti-Corruption and Antitrust Law

Management Approach Disclosures

• GRI 103-1 Explanation of the main topic and its Boundary
• GRI 103-2 The management approach and its components
• GRI 103-3 Evaluation of the management approach

The ProSiebenSat.1 Group believes that sustained economic success in a competitive environment can only be achieved by ensuring that all action taken is in compliance with the applicable laws. Therefore, preventing corruption and violations of antitrust law is highly relevant to business and represents an important success factor for achieving our corporate goals. For this reason ProSiebenSat.1 has implemented a compliance management system (CMS). Compliance management system (CMS)

We have continued to roll out the CMS within the Group over the reporting period. A Unit Compliance Officer has been appointed for 90% of the relevant companies. The compliance e-learning modules have currently been installed in 76% of the relevant companies; the compliance guidelines have been communicated internally in 67% of the companies. Following on from the integration of a compliance check and a supplier’s self-disclosure in the procurement process in the previous year, the procurement process managed by Corporate Procurement has now also been expanded to include a business partner check.

To further improve the protection of whistleblowers, a works agreement to establish an external ombudsperson was concluded in 2018 in accordance with the recommendations of the German Corporate Governance Code. Employees now also have the option of reporting any legal violations anonymously via this ombudsperson. Anti-discrimination

Anti-Corruption

• GRI 205-1 Operations assessed for risks related to corruption
• GRI 205-2 Communication and training about anti-corruption policies and procedures
• GRI 205-3 Confirmed incidents of corruption and actions taken

Fourteen companies underwent a compliance check in 2016. As well as issues such as antitrust and media law and data protection, this check also examined risks related to corruption. The companies assessed included central units such as ProSiebenSat.1 TV Deutschland and SevenOne Media, which generate a high proportion of the consolidated revenues, as well as companies such as maxdome and SevenVentures from the digital area. With regard to the main competition and corruption issues, one of our key focal points is the advertising sales model owing to how financially important it is to the ProSiebenSat.1 business model. This risk assessment remains valid.

At the ProSiebenSat.1 Group, comprehensive training is offered on compliance issues, which includes both an e-learning program and classroom training. The online training (web-based training; WBT), which is offered in English and German and is mandatory for all employees, is intended to provide a basic understanding of the main compliance risks. This training was revised during the reporting period and a Tax Compliance module added. The classroom training is targeted at risk groups and is carried out by Legal Affairs, Group Compliance, HR Law, Corporate Information Security, the Data Protection Officer and the Youth Protection Officer for their individual areas. In addition, ProSiebenSat.1 and the P7S1 Academy offer all-day seminars for the managers of affiliated companies in order to give them a comprehensive overview of their rights and obligations.

In the reporting period, no investigations against the Group, investments or employees of the ProSiebenSat.1 Group due to corruption offenses came to light. No fines or penalties were imposed.

Anti-Competitive Behavior

• GRI 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

In the reporting period, no investigations against the Group, investments or employees of the ProSiebenSat.1 Group due to violations of antitrust law came to light. No fines or penalties were imposed. Since 2008, a civil suit for damages has been pending with RTL 2 Fernsehen GmbH & Co. KG and El Cartel Media GmbH & Co. KG. Risk report