Case study: How ProSiebenSat.1 promotes integrity and compliance

What are the material issues the company has identified?

In its 2016 Sustainability Report ProSiebenSat.1 identified a range of material issues, such as digitalisation and innovation, climate and environmental protection, public value, employees and diversity. Among these, promoting integrity and compliance stands out as a key material issue for ProSiebenSat.1.

Stakeholder engagement in accordance with the GRI Standards

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The organization should identify its stakeholders, and explain how it has responded to their reasonable expectations.”

Stakeholders must be consulted in the process s of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups ProSiebenSat.1 engages with:

How stakeholder engagement was made to identify material issues

To identify and prioritise material issues ProSiebenSat.1 carried out internal workshops, surveyed people in positions of responsibility in various specialist departments and conducted a dialogue with individual interest groups.

What actions were taken by ProSiebenSat.1 to promote integrity and compliance?

In its 2016 Sustainability Report ProSiebenSat.1 reports that it took the following actions for promoting integrity and compliance:

• Promoting data protection
• As a result of the increasing digitalisation of its business operations, ProSiebenSat.1 pays special attention to data protection. Accordingly, ProSiebenSat.1 applies a risk analysis, including compliance review regarding the introduction/amendment of automatic procedures for processing personal data, according to Section 4f of the German Federal Data Protection Act (BDSG). This is to effectively address data-protection-law requirements at an early stage. Additionally, ProSiebenSat.1 implements a process for the legal notification of data protection incidences (unlawful access to personal data by third parties). The process follows Section 42a BDSG and Section 15a of the German Teleservices Act (TMG).

• Implementing a Code of Compliance
• ProSiebenSat.1 applies a Code of Compliance, which includes fundamental guidelines and procedures regarding legal and ethical matters. The Code provides a framework for the Executive Board, the management and the company’s employees for dealing with each other and with business partners, customers, suppliers and other third parties. In addition, the Executive Board supports the Code of Compliance by providing appropriate compliance organisation, along with adequate and effective compliance programs that include consulting, training and measures derived from guidelines.

• Promoting compliance through a Compliance Board
• ProSiebenSat.1 has established a Compliance Board. This Board supports the Executive Board in the implementation, monitoring and strengthening of ProSiebenSat.1’s Compliance Management System (CMS). The Compliance Board meets once a month. Its permanent members are the Chief Compliance Officer (CCO), the Chief Financial Officer (CFO), the Executive Board member responsible for Legal and Compliance and the Head of Group Audit. The Board is responsible for deciding on the focus of the CMS, investigating matters and proposing sanctions. Accordingly, the focal points of ProSiebenSat.1’s CMS are combating corruption, antitrust and media law, and data protection.

Which GRI indicators/Standards have been addressed?

The GRI indicators/Standards addressed in this case are:

1) G4-56: Describe the organization’s values, principles, standards and norms of behavior such as codes of conduct and codes of ethics – the updated GRI Standard is: Disclosure 102-16 Values, principles, standards, and norms of behavior

2) G4-SO3: Total number and percentage of operations assessed for risks related to corruption and the significant risks identified – the updated GRI Standard is: Disclosure 205-1 Operations assessed for risks related to corruption

3) G4-SO4: Communication and training on anti-corruption policies and procedures – the updated GRI Standard is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures

4) G4-SO5: Confirmed incidents of corruption and actions taken – the updated GRI Standard is: Disclosure 205-3 Confirmed incidents of corruption and actions taken

5) G4-PR8: Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data – the updated GRI Standard is: Disclosure 418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data

78% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

7 GRI sustainability disclosures get you started

Any size business can start taking sustainability action

GRI, ISEP, CPD Certified Sustainability courses (2-5 days): Live Online or Classroom  (venue: London School of Economics)

• Exclusive FBRH template to begin reporting from day one
• Identify your most important impacts on the Environment, Economy and People
• Formulate in group exercises your plan for action. Begin taking solid, focused, all-round sustainability action ASAP. 
• Benchmarking methodology to set you on a path of continuous improvement

See upcoming training dates.

References:

1) This case study is based on published information by ProSiebenSat.1, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) http://www.fbrh.co.uk/en/global-reporting-initiative-gri-g4-guidelines-download-page

3) https://g4.globalreporting.org/Pages/default.aspx

4) https://www.globalreporting.org/standards/gri-standards-download-center/

Note to ProSiebenSat.1: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.