Communication on Progress for the UN Global Compact

October 2008 – October 2010 2 // 3

Hartmut Ostrowski, Chairman and CEO, Bertelsmann AG

“The principles of the United Nations Global Compact stand for socially and ecologically sustainable business in a globalized world. So for us it is a matter of course to acknowledge and support these principles.” Bertelsmann Human Chairman‘s at a Glance Rights Letter 4 8 6

Labour Code of Environment 22 Conduct 30 50

Corporate Anti- Contact Responsibility Corruption 55 Portal 46 54 4 // 5 Bertelsmann at a Glance

Bertelsmann at a Glance

First-class media content and services The leading European The leading global entertainment group book publisher

Worldwide leading positions in the core Revenues: €5.4 billion 1) Revenues: €1.7 billion 1) businesses of TV, books, magazines, Employees: 12,520 2) Employees: 5,432 2) media clubs and media services 39 TV channels and 32 radio stations More than 120 editorially independent Creativity and entrepreneurship in 10 countries imprints in 16 countries A magnet for creative and entrepreneurial talent RTL Group broad-casters reach More than 11,000 new books published more than 200 million viewers in annually worldwide Internationality Europe each day A globally active media company with The most Nobel Prize winners of any more than 100,000 employees in over More than 300 productions in book publishing group 50 countries 57 countries

Corporate culture Partnership as the foundation of entrepreneurial success

www.bertelsmann.com www.rtlgroup.com www.randomhouse.com

1) 2009; 2) Dec 31, 2009 Communication on Progress for the UN Global Compact

Europe‘s biggest The internationally networked media Leading media clubs and direct magazine publisher and communications services provider marketing

Revenues: €2.5 billion 1) Revenues: €4.8 billion 1) Revenues: €1.2 billion 1) Employees: 13,571 2) Employees: 60,323 2) Employees: 10,087 2)

More than 500 magazines and digital 270 subsidiaries in 35 countries Approximately 14 million customers offerings in more than 30 countries Media and communications Lines of business: Media clubs, Quality journalism at its best: thoroughly services provider in book stores, publishers, and researched, informative, inspiring over 30 languages distribution companies in 12 countries and entertaining More than 650 million Network of more than 600 club Bertelsmann‘s stake: 74.9 percent consignments per year centers and bookstores (25.1 percent owned by the Jahr publishing family)

www.guj.com www.arvato.com www.directgroup-bertelsmann.com 6 // 7 Chairman‘s Letter

Dear readers,

Corporate responsibility is an integral part of the corporate culture and business activities of Bertelsmann AG. What dis- tinguishes Bertelsmann from many other companies, however, is its decentralized organizational structure.

Bertelsmann is a global enterprise that employs some 100,000 people in over 50 countries. The principle of decentralization is an intrinsic component of our corporate philosophy, which has developed and proved its worth over a period of decades. Communication on Progress for the UN Global Compact

We at Bertelsmann are firmly convinced binding guidelines for legally appropriate principles. In this first progress report, we that the executives on the ground in each and ethically responsible behavior within outline the areas in which we promote the country and market are in the best posi- our company. It is the first code of conduct ten Global Compact principles. I hope you tion to know what is good for their busi- to apply to every one of our employees will enjoy reading this report. ness and their employees – but also what throughout the world, and it is based on the is good for the society in which they build goals and fundamental values of the Ber- and operate that business. telsmann Essentials that guide our actions.

One thing is clear: a company’s decentral- The principles of the United Nations Global ized structure can only function properly Compact promote socially and ecologically on a foundation of common values. The sound economic behavior in a globalized Bertelsmann Code of Conduct, which was world. Therefore, it goes without say- Hartmut Ostrowski introduced at the end of 2008, provides ing that we recognize and support these Chairman and CEO, Bertelsmann AG 8 // 9 Communication on Progress for the UN Global Compact

Human Rights

The media are both a business and a cultural asset. // Whenever we create, bundle or disseminate media content and products, we fulfill important functions in society: to inform, entertain and educate. This is associated with a special degree of responsibility. 10 // 11 Human Rights // Overview

COMMITMENT TO human rights means actively supporting freedom of the press and giving a voice to the weak Media – more than a mere commodity As a media company, we bear special responsibility. The content we create and disseminate on a daily basis is of great importance for understanding and assessing political and societal issues. Our viewers, readers and users trust us to present important events in an understandable way, to expose injustices and to call attention to wrongful conduct.

We are committed to the principle of writ- We consider it our obligation to use this in- ing, broadcasting, printing and circulating fluence to make a difference: to help peo- information that is relevant and of interest ple, to draw attention to pressing problems to people. And we do so in a discerning, in our society and to expose wrongdoing factual and unbiased way – for quality can- and injustice. not be achieved without professionalism and high standards. However, responsibility for the media is not limited to media producers. The buzz- Ultimately, professionalism is part of the word “media literacy” hints at the respon- special responsibility we bear. But tak- sibility of each citizen. And because media ing responsibility can also mean setting skills need to be learned, Bertelsmann boundaries; not everything that is possible companies have many individual projects can be justified. This is true with respect to in place around the world to help parents, both information and entertainment. teens and children deal responsibly with the great opportunities of media diversity. We are conscious of the fact that the content we create and disseminate reaches millions of people worldwide every day. Communication on Progress for the UN Global Compact

COMMITMENT TO human rights means actively supporting freedom of the press and giving a voice to the weak

Many of our products reflect sustainability- related issues. 12 // 13 Human Rights // Some selected examples from the Corporate Center and the divisions

Bertelsmann establishes an International Academy of Journalism

In September 2010, Bertelsmann founded a ceremony to mark Bertelsmann’s 175th The “International Academy of Journal- an Academy of Journalism that will advo- year. Each year, the Academy will convey ism” will be built up in the months ahead cate the spread of the ideals of press free- the tools of the trade for the digital future of and officially take up its teaching activity dom and promote expertise and network- journalism to a selected group of journalists at the end of 2011. It will be established in ing among journalistic talent worldwide. worldwide by means of on-site workshops close cooperation between Bertelsmann The “International Academy of Journalism” and e-learning modules. Its primary target and the Group’s two acclaimed schools reconfirms and underscores the compa- group is aspiring journalistic talents, mainly of journalism: the Henri-Nannen-School ny’s commitment to press freedom, quality from countries where press freedom is non- in Hamburg and the RTL School of Jour- journalism and corporate responsibility on existent or at risk. Candidates should have nalism in Cologne. The Academy will also the occasion of its 175th anniversary. José a track record of advocating press freedom pursue partnerships with organizations and Manuel Barroso, President of the European in their previous work, make imaginative institutions that advocate freedom of the Commission, acted as the patron of the use of the opportunities of the new me- press and of opinion. founding act, which took place in Berlin at dia and be talented, courageous writers.

Andreas Wolfers, director of the Henri-Nannen-School of Journalism in Hamburg (left), joins “Stern“ José Manuel Barroso, president of the European reporter Katja Gloger and Peter Kloeppel, RTL Television editor-in-chief and director of the RTL School Commission, pointed out the Academy’s important of Journalism, in announcing the establishment of the International Academy of Journalism. mission of strengthening democracy. Communication on Progress for the UN Global Compact

European Charter on Freedom of the Press

On May 25, 2009, the first European Char- ter on Freedom of the Press was signed at Gruner + Jahr headquarters by 48 editors- in-chief and leading journalists from 19 countries. In 10 articles, the document for- mulates principles for the freedom of the media from censorship and government interference of any kind. So far some 500 print, radio and television journalists from 34 countries have affirmed the charter by signing it online. The goal is to create a Eu- ropean media region with uniform, liberal standards and to enable journalists to in- voke this document when freedom of the press is violated.

More information about the European Charter on Freedom of the Press can be found at: www.pressfreedom.eu

Protecting young people on the Internet

Wer-kennt-wen.de has joined with other tary declaration includes a commitment to major German network operators under comprehensive privacy setting options for the Freiwillige Selbstkontrolle Multimedia- users, a way to submit complaints about Diensteanbieter (Voluntary Self-Monitor- violations against the rules of the com- ing of Multimedia Service Providers) um- munity directly, the option of “ignoring” brella to develop extensive and consistent other users, and building users’ awareness industry standards for the protection of mi- of these options through clear advisories nors and of personal information in social within the platform. Further information is networks. Among other things, the volun- available from www.fsm.de 14 // 15 Human Rights // Some selected examples from the Corporate Center and the divisions

The ”Lesespaß” (Joy of Reading) initiative in Gütersloh

In September 2010, to commemorate its Big launch party for children, with RTL cates and the interested public. Guests 175th anniversary, Bertelsmann and its presenter Nina Moghaddam were treated to an open-air stage program partners – the Stiftung Lesen (Reading The launch of “Lesespaß” was celebrated emceed by RTL presenter Nina Moghad- Foundation) and the Goethe-Institut e.V. on September 1, 2010 with a large party at dam: from music and clowns to magicians – launched the “Lesespaß” (Joy of Read- the Gütersloh city library, attended by lots and break-dancers – all the stage acts and ing) initiative in the company’s hometown of children, parents, preschool and elemen- promotions were related to the day’s big of Gütersloh. The aim of the two-year pro- tary school teachers, local literacy advo- topic of reading. gram is to promote reading among children from families in which reading is not “Lesespaß” – a special approach a priority. What sets “Lesespaß” apart is its comprehensive approach and the fact that “Reading is a prerequisite for education many complementary measures to pro- and vocational training“ mote reading are concentrated in a spe- According to “Reading in Germany 2008,” cific time and place. A combination of a study commissioned by the Federal tried-and-tested techniques and inno- Ministry of Education and Research, read- vative activities to promote reading will ing habits are on a decline across the hopefully result in a long-term improve- country. The younger generation tends ment in the reading skills of children to read very selectively, mostly skim- and teens. This has for some time been ming content. The Federal Literacy As- regarded as a promising approach in the sociation and Stiftung Lesen estimate theory of literacy promotion but has rarely that there are between three and four been put into action to date, so the bun- million functional illiterates in Germany. dling of measures in this project can ef- The “Lesespaß” initiative has the aim of fectively be described as unique. Bertels- slowing and ideally reversing this trend mann and its partners Stiftung Lesen and locally. “Reading is the foundation for ac- Goethe-Institut intend to make all project tive participation in society, reading is a concepts and the logo available for use. prerequisite for education and vocational The initiative can then serve as a template training, reading is a fundamental cultur- for integrated projects to promote reading al technique. ‘Lesespaß’ is our gift to the skills in other town and cities. city of Gütersloh,” declared Bertelsmann Chairman and CEO Hartmut Ostrowski. Communication on Progress for the UN Global Compact

From left to right: Goldmann author Hatice Akyün, Prof. Dr. Klaus-Dieter Lehmann of the Goethe-Institut, Gütersloh Mayor Maria Unger, Bertelsmann Chairman and CEO Hartmut Ostrowski, RTL moderator Nina Moghaddam and Sabine Uehlein of the foundation Stiftung Lesen.

Nina Moghaddam and Ingo Bingo were at the Gütersloh city library for the kickoff. 16 // 17 Human Rights // Some selected examples from the Corporate Center and the divisions

Long-term assistance in disaster areas Natural disasters quickly disappear from the headlines, but the people affected have to live with the consequences every day, and long-term aid is needed.

Assistance in rebuilding SOS Children’s Villages in the aftermath of the tsunami

Thanks to the generosity of Bertelsmann’s land, Pondicherry is one of the SOS Chil- partment and learning center and many at- companies and employees, at least 250 dren’s Villages founded immediately after tractive services for the surrounding area. tsunami orphans were taken care of: a total the tsunami to give new homes to children The children also have the opportunity to of €1.4 million has been donated to fund six who were bereaved by the disaster or work on their education and hobbies at the SOS Children’s Villages in Indonesia, India whose parents are no longer able to care Children’s Village own learning center. Its and Thailand. Children in these villages will for them over the long-term. library now has a good 2,000 books, and in be provided with food, housing, clothing, As the oldest of the “Tsunami Children’s the computer room, they learn how to use medical care and education for a minimum Villages,” Pondicherry has now estab- PCs, software and the Internet. of ten years. Like Medan, Banda Aceh and lished itself as a fully-fledged children’s Meulaboh in Indonesia and Phuket in Thai- village with a kindergarten, outpatient de- Communication on Progress for the UN Global Compact

“Bertelsmann Hope School” opens in China

The “Bertelsmann Da Long Hua Hope School” was officially christened at the end of April during a ceremony in the school’s sports grounds. Since September 2009, classes have been taught at the primary school in expanded and renovated class- rooms, and Bertelsmann made it all possible: several of the Group’s companies in China, among them Arvato, G+J, Fremantle Media, the local Corporate Center as well as the Ber- telsmann Asia Investments supported the “Hope School” project of the Beijing Youth Development children’s relief organization in cooperation with the municipal government.

Earthquake relief in China: construction of Guangping Middle School completed

It’s been more than two years since a ma- the disaster. A total of €610,000 was col- children’s relief organization Plan Interna- jor earthquake struck the Chinese province lected in the Bertelsmann employees’ fund tional as its partner in the relief operation in of Sichuan, killing 70,000 people and de- drive in May 2008. Bertelsmann had set up order to help the most vulnerable victims in stroying an estimated five million build- a €500,000 relief fund for the victims of the the disaster area: the children. ings. At Guangping Middle School in Han earthquake immediately after the disaster. Zhong, there is no trace of this destruction At the same time, all employees of the me- to be seen today. The rapid reconstruction dia company were called upon to increase of the badly damaged school building was this fund with their own donations. Ber- made possible by money from the relief telsmann then matched these donations fund Bertelsmann set up immediately after to double the sum. Bertelsmann chose the 18 // 19 Human Rights // Some selected examples from the Corporate Center and the divisions

Pulling together to help Haiti after the Earthquake in January 2010

€100,000 was the sum provided by Ber- foundation had given €100,000 from its up with the newspaper Le Figaro for the telsmann as emergency relief to the vic- own emergency relief fund. Among other campaign Sauvons les enfants d’Haïti, rais- tims within days of the catastrophic earth- things, this money will be used to rebuild ing money for the rebuilding and running quake in Haiti. The aid has since been the orphanage in Trichet, which was spon- of orphanages, kindergartens, schools and coordinated by Plan International, a chil- sored by an RTL Spendenmarathon, but clinics. M6 also ran a trailer campaign in dren’s relief agency that Bertelsmann has completely destroyed in the earthquake. In which its news anchors called on viewers worked with since the aftermath of 2008’s France, Groupe M6 and RTL Radio teamed to support Unicef’s relief efforts. severe earthquake in southern China.

Shortly after the earthquake hit Haiti on January 12, 2010, RTL Group began call- ing on its viewers and listeners to donate funds. In less than two weeks, RTL Group companies helped to raise over €45 million for emergency and long-term relief. In the Netherlands, RTL’s flagship channel RTL 4 teamed up with public broadcaster Nederland 1 and commercial channel SBS 6 to simultaneously broadcast the charity programme Nederland Helpt Haiti. This raised €41.7 million in donations, which was matched by the Dutch government. Most commercial radio stations, including RTL Nederland’s Radio 538, also supported this joint initiative.

Grupo Antena 3 in Spain launched the Ayu- da a Haití campaign to raise funds via text messages. Within 48 hours, the campaign had generated €1.3 million in donations, which went directly to the Red Cross. In Germany, Mediengruppe RTL Deutsch- land launched a trailer campaign on RTL Television, Vox, N-TV and Super RTL. So far, viewers have donated more than €3.1 million. In addition, the company’s charity Communication on Progress for the UN Global Compact

“Stiftung Stern” foundation – help for people in need

The foundation “Stiftung Stern – Hilfe für tions for concrete aid efforts, which allows Menschen e.V.” is a nonprofit association. it to quickly provide practical help to people Since the 1970s, the magazine “Stern” has in need. It is also continuing its partnerships been involved with a variety of relief actions with a variety of aid organizations. However, aimed at assisting people in need. It initially the foundation retains control over the use focused on collecting direct donations for of the resources it provides. various aid organizations. In December of Current human-rights projects include ini- 2003, the association “Stiftung Stern” – Hil- tiatives related to bride kidnapping in Kyr- fe für Menschen e.V.” was established as an gyzstan, families in need, drought in Kenya independent foundation. It collects dona- and child poverty in Germany.

“Let’s work so that inmates leaving prison never have to return”

Several humanitarian organizations, as man Rights has condemned the country for posed to inmates and to help with the dy- well as doctors and personnel working on “inhuman and degrading treatments” hap- namics of rehabilitation by providing training site have pointed the finger at disastrous pening in French prisons. In this context, in the audiovisual trades, among many other and indignant life conditions of inmates in Groupe M6 created the Fondation M6 with initiatives. To that end, a budget of € 2.5 mil- French prisons. The European Court of Hu- the aim to support audiovisual projects pro- lion has been set for the next five years.

Community Technology Center in Gurgaon, India

In 2008, Arvato Services founded a Com- munity Technology Center in India together with Microsoft. The objective is to offer underprivileged members of society access to electronic media. Arvato Servic- es is providing facilities and trainers. The program will offer young people from poor backgrounds instruction and continuing training via Microsoft training programs. 20 // 21 Human Rights // Developments with regard to the principles of the UN Global Compact

The Principles Developments of the UN Global Compact (October 2008 to present)

Businesses should support • In 2008, Bertelsmann implemented a and respect the protection Global Code of Conduct that under- of internationally pro- scores its commitment to human rights. 1 claimed human rights. The Code was distributed to all employees worldwide and is also often used in dealings with business partners.

Businesses should make • Bertelsmann reiterated its long-standing • In September 2010, Bertelsmann sure they are not complicit commitment to human rights as part of founded an Academy of Journalism in human rights abuses. Code of Conduct training for all employ- that promote ideals of press free- 2 ees, which launched in 2009. dom and expertise and networking among journalistic talent worldwide. • As part of the Code and training initia- The “International Academy of Jour- tive, employees are instructed about nalism” reconfirms and underscores the comprehensive means that the the company’s commitment to press company puts at their disposal to safe- freedom, quality journalism and cor- ly report any human rights violations. porate responsibility on the occasion The company makes various channels of its 175th anniversary. available for reporting violations: ombudspersons, Internet-based whistle- • In September 2010, Bertelsmann bowing system and the Bertelsmann started the two-year literacy initia- Ethics & Compliance Department. tive “Lesespaß” (= Joy of Reading) in its founder`s town Gütersloh to • The E&C Department assures that promote children`s reading skills. reports are promptly reviewed and investigated by the appropriate functional Department. In 2008, a Corporate Compliance Committee was formed and meets regularly to monitor whether all reports have received adequate and timely scrutiny.

Communication on Progress for the UN Global Compact

Goals (present to October 2011)

• The Code of Conduct will be reviewed in the context of a periodic programmatic evaluation.

• Training for newly hired employees • The “International Academy of Jour- is administered on an ongoing basis. nalism” will be built up in the months Refresher training for all employees ahead and officially take up its is anticipated for 2012. teaching activity at the end of 2011. It will be established in close coopera- • Ongoing monitoring of compliance tion between Bertelsmann and the with human rights violations occurs Group’s two acclaimed schools of based on a review of reports received journalism: the Henri-Nannen-School through the comprehensive whistle- in Hamburg and the RTL School of blowing channels. Journalism in Cologne. Headquar- tered in Hamburg, the Academy will • Compliance risk assessment, including also pursue partnerships with organi- a review of the risk of human rights zations and institutions that advocate violations, occurs on an annual basis. freedom of the press and opinion.

• Annual workshops and regular ex- • Several literacy programs will be changes with more than 100 Ethics & started within the “Lesespaß” Initia- Compliance Representatives from tive, the literacy project of Bertels- subsidiaries will continue to occur. mann in Gütersloh, Germany. Human Rights 22 // 23 Communication on Progress for the UN Global Compact

Labour

Every day, more than 100,000 employees in over 50 countries are engaged in ensuring the success and ongoing development of our company. We attach especially high priority to our responsibility to our employees. 24 // 25 Labour // Overview

COMMITMENT TO labour principles means giving employees a voice and ensuring a healthy work-life balance Helping shape tomorrow’s company Why are healthy and motivated employees so important for us? They are the driving force behind the innovative powers of the company. Our task is to fully develop this potential and to create an equitable and motivating work environment for every member of our workforce.

BeFit – Bertelsmann AG’s in-company health management system

More exercise, healthier foods and compre- With this in mind, in 2008 Bertelsmann hensive preventive healthcare: getting into AG introduced the BeFit program to bring shape and remaining fit are enormously im- together various aspects of in-company portant for everyone. health management; its components have steadily expanded ever since. Along with Motivating Bertelsmann’s employees at ev- activities and information on exercise, med- ery site to play an active role in ensuring ication, prevention and protection for non- their own health, getting into shape and re- smokers, there are such initiatives as health maining fit – this is the goal of our in-com- weeks, action days and exercise programs pany health initiative BeFit. Bertelsmann during lunch breaks, as well as cooperative creates optimal conditions for employees arrangements with nearby fitness centers. to achieve their own individual health goals. Bertelsmann’s company sports program is BeFit helps them move toward an all-round a very popular way of offering employees healthier life with respect to exercise and opportunities for physical activity and in- nutrition, medication and prevention, work- cluded more than 490 events in 2009. life balance and lifelong learning. Over the past two years, nearly 100 Bertelsmann’s corporate culture, based on health action days were held in coopera- the principle of partnership, underlies the tion with local partners. In Erfurt, Baden- company’s commitment to health-related Baden, Munich, Wuppertal and Stralsund, issues. There is evidence that employees for example, over 2,500 employees took are healthier when they have a certain de- advantage of the opportunity for health gree of freedom, identify with the company checkups developed specifically for these and enjoy partnership-based leadership. events, including a back-health checkup Communication on Progress for the UN Global Compact

COMMITMENT TO labour principles means giving employees a voice and ensuring a healthy work-life balance

Many G+J employees came to celebrate the opening of the new in-house health club.

using the MediMouse, a stress test and a health club was opened at Gruner + Jahr’s checkup using an InBody body composi- Am Baumwall headquarters in early 2009. tion analyzer. The facility was designed in cooperation with partner DanTrim and reflects employ- The publishing company Gruner + Jahr in ee requests and input. A team of qualified Hamburg also attaches great importance trainers creates individualized training to employee health. The company’s sports plans and monitors employees’ prog- association Sportgemeinschaft G+J of- ress. Gruner + Jahr has already received fers a variety of activities, and an in-house awards for its achievements in this area. 26 // 27 Labour // Some selected examples from the Corporate Center and the divisions

Running Bertelsmann wins to stay healthy second health award

Exercise keeps us fit and is always a good In the spring of 2010, 128 employees from In 2008, for the second time in a row, Bertels- way to offset the demands of everyday life, Random House in New York ran 1,000 me- mann AG received the Deutscher Unterneh- which is why many Bertelsmann employees ters farther as part of the 34th JPMorgan menspreis Gesundheit (German Company like to run. As part of the “Gütersloh läuft” Chase Corporate Challenge in Central Park. Prize for Health) from the Federal Association (Gütersloh runs) event, nearly 300 employ- The runners were supported by colleagues of Company Health Insurance Funds in recog- ees went out on the 4.6-kilometer running from the Human Resources department nition of its BeFit health promotion activities. track during each of the past two years. The and the Random House running group. As It also received an award from the European runners were assisted by the BeFit team, with other events of this kind, the emphasis Union under the “Move Europe” campaign. which provided the necessary running gear was on being active together rather than In 2009, the BeFit program won a “Move - as well as refreshments at the finish line. setting new records. Europe–Partner Excellence” certificate.

Beate Dembkowski and Gero Hesse took the award for the BeFit Team.

Random House employees just before the JPMorgen Chase Corporate Challenge in Central Park. Participants set off on „Gütersloh läuft“. Communication on Progress for the UN Global Compact

The 2010 Bertelsmann Employee Survey

This year marked the third Bertelsmann worldwide employee survey after the 2002 and 2006 editions. In all, 81,612 employees from 47 countries were invited to participate, with 69,454 colleagues following through – a participation rate of 85.1 percent. Inciden- tally, performing the employee survey worldwide was an enormous organizational and logistical challenge. A Corporate HR team spent months preparing the survey together with nearly 300 colleagues from the divisions. In all, 81 different versions of the questionnaire were created in a total of 15 languages. More than 80,000 printed questionnaires, 82,000 information fly- ers, 4,800 posters and 7,685 stickers were shipped to around 400 destina- tions all over the world. In addition, nearly 9,000 results reports were distributed in early September. 28 // 29 Labour // Some selected examples from the Corporate Center and the divisions

The Principles Developments of the UN Global Compact (October 2008 to present)

Ensuring freedom of as- • The company’s third international employee meet at least once a year. A total of 81 sociation and effective survey was conducted in June 2010 to meetings were held in 2009. In addition, recognition of the right to gather employees’ opinions regarding a an HR summit was organized in early collective bargaining number of topics. Once again, a record 2009, the first international conference for 3 was set with a participation rate of 85.1 the company’s HR directors. percent. The responses of nearly 70,000 employees from 47 countries were com- • A zero-tolerance policy with respect to piled into over 9,000 reports. They are any kind of discrimination: clear proce- Elimination of any kind of now being used as a basis for in-depth dures and sanctions, including dismissal, discussion of the results within teams and were defined. Representatives of severely forced Labour. individual companies. disabled employees enjoy the active sup-- port of Bertelsmann AG. They monitor ad- 4 • Bertelsmann worked closely together with herence to the rights of disabled employ- elected employee representatives. At all ees and work hard to promote integration. levels, there have been in-depth exchanges of views and trust-based cooperation Percentage of severely disabled employ- between representatives of employees ees and other individuals with that status Abolition of child Labour. and the employer side. For example, the in Germany: 2008: 3.7% | 2009: 3.9% Corporate Center has provided support for the establishment and efforts of several • All employees of Bertelsmann AG, 5 employee representative committees and including Group companies and affiliated made sure that contact persons are avail- companies, have employment contracts able to assist them in their ongoing work. that are based on voluntary employment and include provisions for termination. • Over 100 continuing education events for Moreover, Bertelsmann supports em- Elimination of discrimina- employee representatives (2008–2010). ployee compensation in line with market tion in respect of employ- conditions and adheres to existing collec- ment and occupation. • In the area of human resources as well, a tive bargaining agreements as far as great deal of effort was made to inform possible. 6 and train employees, in the interest of maintaining a consistently high standard. • Providing training for young people is HR coordinating committees are in place a corporate responsibility that Bertels- in all of the countries and regions in which mann embraces. In the German Group Bertelsmann does business, and they companies, a total of 1,359 individuals Communication on Progress for the UN Global Compact

Goals (present to October 2011)

were employed as trainees or interns or • Continued active support for the attended a school of journalism at the efforts of employee representatives. end of 2009. All 226 individuals com- pleting their training were guaranteed a • Based on the results of the employee job in the summer of 2009 despite the survey, an analysis will be conducted effects of the economic crisis. and follow-up measures will be determined and implemented within • Number of trainees in Germany the individual companies and divisions. 2008: 1,412 | 2009: 1,359 • HR coordinating committees will • Involvement by Bertelsmann companies continue to be actively involved in in training future employees outside developing HR-relevant projects of Germany as well, depending on local and processes, taking advantage of circumstances. the specialized knowledge that exists in the various regions. Another HR • for the second time in a row, in-com- summit will be held in the spring pany health management activities of 2011. under the heading of “BeFit” were awarded the Unternehmenspreis • further expansion of in-company Gesundheit (German Company Prize health management activities in for Health) in 2008. Germany, as well as support for foreign sites in adopting successful • More than 90 health action days were initiatives. held in 2008 and 2009, and activities were expanded at the local sites.

• Participation in the sports program in Germany 2008: 7,900 | 2009: 8,500

• Participants in health action days 2008: 680 | 2009: 1,343 Labour 30 // 31 Communication on Progress for the UN Global Compact

Environment

Conscientious use of natural resources // Any company that prints and publishes books and magazines, ships CDs and DVDs or offers a wide range of different services inevitably enters into a complex interrelation- ship with the environment. Though the media sector has less impact on the environment than other branches of industry, we at Bertelsmann take this responsibility very seriously. Treating natural resources responsibly at every stage of our supply chain is an elementary part of our idea of corporate responsibility. 32 // 33 Environment // Overview

Environmental protection means handling resources responsibly and ENCOURAGING one’s employees to act accordingly Bertelsmann’s Carbon Footprint “Climate change is real, and it is one of the foremost challenges of the 21st century. Sustained growth is only possible if we, the private sector, also act sustainably and reduce our emissions. That is one of the reasons why we at Bertelsmann are taking action,” said Bertelsmann CEO Hartmut Ostrowski, explaining the Executive Board’s 2008 decision to calculate the company’s carbon footprint. This international balance of greenhouse gas emissions measures the Bertelsmann Group’s impact on the Earth’s atmosphere for the first time. It also forms the basis for a coordinated improvement in the company’s energy efficiency. Because at the company and divisional level the environment and climate change have already been an issue for years.

Corporate responsibility is firmly anchored bon dioxide (CO2), GHGs include other calculation. PwC assessed the data collec- in Bertelsmann’s company principles. The gases like methane and nitrous oxide. tion procedure at the Group level and the Bertelsmann Essentials obligate Bertels- These gases are “converted” into carbon methodology used to calculate the car-

mann’s employees and companies to “act dioxide and shown as CO2 equivalents bon footprint for accuracy, reliability and

responsibly toward [..] the environment.” (CO2 eq), giving a standard measurement pertinence. Through PwC, we have been Based upon this, Bertelsmann’s Executive by which the impact on climate change able to verify that our approach conforms Board launched a climate protection strat- can be expressed. to current common, relevant standards egy in August 2008. As the first pillar in this To calculate our carbon footprint, the and practices. At the same time, we also strategy, a Group-wide, international in- Group’s consumption of electricity and received recommendations for compiling ventory of greenhouse gas emissions (the fossil fuels (especially gas, heating oil, future carbon footprints. “carbon footprint”) was drawn up in 2009. gasoline and diesel) as well the amount The IFEU Institute for Energy and Envi- of business travel (flights, train trips, etc.) ronmental Research in Heidelberg has was determined. The resulting greenhouse calculated Bertelsmann’s carbon foot- gas emissions are derived using conver- print, which describes how much green- sion factors. We commissioned the audit- house gas (GHG) a business is responsible ing firm PricewaterhouseCoopers (PwC) to for emitting in a given period. Besides car- certify the quality of our carbon footprint Communication on Progress for the UN Global Compact

Environmental protection means handling resources responsibly and ENCOURAGING one’s employees to act accordingly Our carbon footprint // Bertelsmann’s Gruner + Jahr divisions as well as Prinovis. 2008 carbon footprint amounted to more Like many industrial plants, the printing

than 1.5 million tons of CO2 equivalents. machines need large amounts of electric- Most of our GHG emissions are caused ity, natural gas and heat. This is reflected by the printing plants in the Arvato and accordingly in the carbon footprint.

10,208 t (0.7%) Corporate Center

68,700 t (4.5%) Random House

72,783 t (4.8%) RTL Group

30,708 t (2.0%) Direct Group

336,906 t (22.0%) Prinovis

790,130 t (51.6%) Arvato

222,535 t (14.5%) Gruner + Jahr

Carbon Footprint of Bertelsmann AG in 2008:

1,531,969 t CO2 eq 34 // 35 Environment // Some selected examples from the Corporate Center and the divisions

The “be green” experts

The “be green” team is an international strategy. Since May 2003, environmen- our ecological efforts. Best practices workgroup comprising environmental tal experts from Bertelsmann AG and all from the divisions and companies are experts at Bertelsmann AG and all of its Bertelsmann company departments – en- presented, new developments at the in- corporate divisions. The task force shares vironmental officers, production heads ternational, European and German level ideas and experiences on environmen- and chief paper buyers – have met regu- are discussed, and strategies for more cli- tal topics and develops Bertelsmann’s larly in this interdivisional, international mate protection throughout the Group are environmental and climate protection task group to discuss issues related to jointly developed.

Bertelsmann AG/Corporate Center: RTL Group: Arvato: Thorsten Strauß Oliver Herrgesell Klaus Markus Executive Vice President Executive Vice President Head of Corporate Communications Corporate Communications Corporate Communications, Public Affairs & Marketing, Environmental Chief Officer Andreas Henrichs Katrin Gaertner Environmental Affairs Coordinator Head of Berlin Representation Office Tun Van Rijswijck Corporate Communications Chief Operating Officer, BCE Direct Group: Matthias Wulff Stephan Schumacher Random House: Head of Corporate Communications Head of Brussels Liaison Office Stuart Applebaum Corporate Communications Executive Vice President, Random House USA Oliver Lanka Vice President Purchasing Barbara Kutscher Stephen Esson Director Corporate Responsibility Group Production Director, Random House UK Prinovis: Corporate Communications Alexander Adler Wolfgang Michael Hanke Head of Corporate Communications Bettina Grab General Production Director, Director Government Relations Verlagsgruppe Random House Hans-Friedrich Süßmann Corporate Communications Technical Services Manager Gruner + Jahr: Luigi Sanfilippo Thilo von Trott Head of Property Management Department Head of Public Affairs & Corporate Responsibility

Jack Seifert Head of Paper Purchasing

Sven Wolter Head of Internal Services Communication on Progress for the UN Global Compact

How emissions are caused at Bertelsmann

(in tons of CO2)

43,852 t (2.9%) Business travel

44,088 t (2.9%) Transport

1,444,029 t (94.2%) Energy

By far the largest proportion of GHG emis- power stations of our electricity suppliers In offices the ratio is somewhat reversed, sions is caused by the provision of energy and in the provision of fuels is taken into with heating generally having the biggest in the form of electricity and heat. Bertels- account. At the printing plants, electricity impact on climate. Business travel includes mann’s direct emissions result from the consumption is a key factor in the carbon the GHG emissions caused by air and rail use of fuels such as gas and heating oil in footprint because, all over the world, much travel and the use of rental cars. The trans- our heating systems and at our production of the electricity is generated by burning port segment represents the emissions facilities. In the case of electricity, our pro- coal, oil or gas in power stations. from our various company-owned fleets of portionate share of CO2 emissions at the vehicles. 36 // 37 Environment // Some selected examples from the Corporate Center and the divisions

The be green Days 2010 at Bertelsmann around the world

Leave your car at home and bike to work, These events took place on and around arvato finance Random House avoid printing out documents whenever June 1 and encouraged employees to services Ireland UK possible, and turn on the light only when think about and get involved in environ- it’s really needed: There are many ways mental issues. Environmental officers in to protect the environment in a business the divisions put together action-packed setting. To mark World Environment Day, programs and got many of their sites established by the United Nations, Ber- excited about participating in “be green telsmann companies organized action Day” with ideas of their own. The action days known as “be green Days” at more days received extensive coverage on Ber- than 35 different sites in ten countries. telsmann’s intranet.

RTL Belgium Brussels Bertelsmann AG regards climate change and environmental protection as central issues in our business and in society today.

Therefore, in partnership with employees and stakeholders, we strive to reduce our- direct and indirect greenhouse gas emis sions as part of our overall drive to limit our Direct Group RTL Radio environmental impact. France, Paris France, Paris

Our strategy will be subject to constant improvement.

Pursuant with our decentralized corporate philosophy, we expect our divisions to take responsibility for sustainable management The Bertelsmann be green contributing to climate and environmental mission statement. protection. Communication on Progress for the UN Global Compact

arvato Gruner + Jahr, arvato services arvato services government RTL Nederland Hamburg Stralsund Polska services UK

Bertelsmann RTL Radio Direct Group Unter d. Linden 1, Deutschland, Berlin Berlin Berlin

arvato digital arvato services, Corporate Center services, Gütersloh Gütersloh Gütersloh

Direct Group/ Mohn Media Corp. Center Gütersloh arvato, Gütersloh

Prisma Presse, Paris

RTL Group Verlagsgruppe arvato telco arvato services Corporate Center Random House, services Erfurt Chemnitz Luxembourg Munich

European Bertelsmann sites which participated in the be green Day 2010 38 // 39 Environment // Some selected examples from the Corporate Center and the divisions

RTL Group – the environment is part of the program

Since spring 2008, the “environMIND- later, the environmental officers from WWF (World Wildlife Fund) proclaimed team” has been supporting environ- each company agreed on targets to re- March 28, 2009 “Earth Day” and called mentally friendly actions and behavior at duce greenhouse gas emissions by 20 on all people around the world to turn off RTL Group. “Numerous green initiatives percent and a timetable lights for one hour, several RTL have been launched to keep the staff for achieving them by Group channels supported this informed and promote or encourage 2020. Many RTL Group symbolic action. At the same their environmental conduct,” says channels are also in- time Michael De Maegd, a news Oliver Herrgesell, Environmental Chief creasingly covering envi- presenter for the Belgian TV Officer at RTL Group. “These include an ronmental issues in their channel RTL-TVI, took off from interactive website with practical eco programs. “For example, Sydney in an ultra-light aircraft tips, our ‘environMINDday,’ the com- RTL Radio in France has for the “WWF Earth Challenge.” pany mission statement, an environmen- had a monthly theme The documentary expedition car- tal brochure and initiatives for organic day - ‘L’Expédition RTL’ - ried out jointly with WWF gave the menus at the canteen in Luxembourg.” since October 2008, which presents vari- RTL-TVI team some impressive pictures of At the second “environMINDday” on De- ous regions of the world where the con- regions threatened by climate change. “It cember 1, 2009, RTL Group presented sequences of climate change are severely was an extraordinary, ecological adven-

its first CO2 balance sheet. A few weeks felt,” continues Herrgesell. And when the ture,” said Oliver Herrgesell.

RTL-TVI moderator Michael De Maegd boarded an ultra-light plane from Sydney to Brussels for the “Earth Challenge WWF”. Communication on Progress for the UN Global Compact

Random House – paper from sustainable forests

All around the world Random House strives to produce its books in the most eco- friendly way possible. In Germany, for example, the local publishing group gets its paper from suppliers who can prove they use resources from water cycle-oriented, sustainable forestry. “For almost all of our book production, i.e., for all paperbacks and hardcovers, we only use paper variet- ies that are certified by the FSC,” said Wolf- gang Michael Hanke in Munich, joint head of production responsible for the issue. And now the producers of illustration-printing paper have followed suit, so that Verlags- gruppe Random House’s entire color range can now be printed almost exclusively on FSC-certified paper as well. Random House Deutschland won the FSC Global Partner Award in September 2010 for outstanding services rendered to the FSC. Great importance was also attached to the certification of all printers. “At the Arvato subsidiaries Mohn Media and GGP Media, we’re in ex- tremely good hands in this respect,” said Hanke. In 2007, Verlagsgruppe became the first publishing group in Germany to have its carbon footprint calculated by Climate- Partner. Random House is active in environmental protection outside Germany as well. In the U.S. the proportion of recycled paper in book production will be increased to 20 percent and targets for reducing greenhouse gas emissions will be introduced. The Riemann imprint is all about environmental And in Britain, an action plan will save 250 protection: its production processes are as eco- tons of carbon dioxide each year. friendly as the content of its publications. 40 // 41 Environment // Some selected examples from the Corporate Center and the divisions

Gruner + Jahr – offsetting research travel

Gruner + Jahr’s sustainable climate protection project: here, a valley in Nepal

At a publishing company like Gruner + Jahr the resulting greenhouse gases in coop- allowed us to more precisely break down in Hamburg or the division’s other sites, eration with ‘Geo Saves the Rainforest’ how much of the footprint is attributable to there are many ways to save energy or nat- through a sustainable environmental proj- such travel.” New “Geo” subscribers also ural resources for the benefit of the envi- ect in Nepal,” says von Trott. Reforesta- have the option to waive their promotional ronment. For example, G+J magazines are tion, efficient cooking stoves and biogas gift and donate a tree to a reforestation printed on 98.5 percent environmentally plants are the most important elements project in Ecuador. More than 20,000 new certified paper. “But if journalists, say from for offsetting carbon emissions generated trees have already been planted as a result. ‘Geo’ magazine, want to report from vari- by unavoidable research trips by G+J edi- ous regions of the world – even on environ- torial staff. “This project is based on the mental topics – then they have to travel, and calculation of the total amount of carbon usually by plane,” says Thilo von Trott, who dioxide that Gruner + Jahr releases into the is responsible for environmental affairs at environment at all its locations - its carbon Gruner + Jahr. “ Gruner + Jahr will offset footprint,” says von Trott. “The analysis Communication on Progress for the UN Global Compact

Arvato – in league to protect the forests

If a print product carries the seal of the ous about our efforts to combine economic further underscored by our membership in internationally recognized Forest Steward- success with environmentally friendly ac- the WWF Wood Group,” a voluntary initia- ship Council (FSC), then this means that tion,” said Andreas Henrichs, Arvato envi- tive of companies who each sign individual any wood used in its production comes ronmental affairs coordinator. “This fact is agreements with the WWF. from sustainable forestry. The same is true for the printing company itself: its FSC cer- In much of their business, Arvato companies tificate proves that they are part of an entire use paper from FSC-certified forestry production chain (chain of custody) from forest to finished product. If this chain is without gaps, a product is given the FSC la- bel. Eleven Arvato companies in Germany, Italy, Spain, Portugal and the U.S. are now certified according to the stringent criteria of the FSC. “This shows that we are seri-

The packaging of the topgreen line consists entirely of recycled or recyc- lable material, is produced in an environmentally friendly manner, and is printed with inks and lacquers that are free of petroleum and solvents. 42 // 43 Environment // Some selected examples from the Corporate Center and the divisions

Direct Group – 400,000 trees for climate protection

for example, 100 percent FSC- certified paper is used. Following Der Club Bertelsmann and Círculo de Lectores, all subsidiaries are now gradually gaining FSC certification. Since 2007, Direct Group has also been proving its environmental commitment Books play a major role at Direct Group. less traceability of the composition and in a very different business. For every cus- This makes it all the more important that origin of their raw materials.” Direct Group tomer who books a tour of Turkey with the the division strive to make its paper pro- also places special emphasis on ensur- Turkish partner Deha Tur via a Direct Group curement and printing processes as eco- ing that the producers of paper used in company, a tree is planted in the area around friendly as possible. “Under no circum- its books are certified to credible environ- the provincial capital of Denizli - thereby re- stances do our companies use paper from mental standards. In so doing, it seeks to plenishing the declining tree population in forests under protection or from non-sus- support concepts central to sustainable the region. This helps Direct Group to offset tainable forestry,” explains Oliver Lanka, forest management – i.e., reforestation, the impact of pollution caused by the travel. Vice President Purchasing at Direct Group. careful use of water and energy, and the By the end of this year the 400,000th tree “We only use suppliers who provide seam- prevention of illegal logging. In Germany, will have been planted. Communication on Progress for the UN Global Compact

Prinovis – environmentally friendly combined heat and power plant

Late in the summer of 2009, the gra- vure printing group Prinovis joined the Klimaschutz- und Effizienzgruppe der deutschen Wirtschaft (Climate Protec- tion and Efficiency Group of German Industry.) The members of the initiative regard climate change and energy efficiency as opportunities for a successful economic future. They therefore wish to mobilize the motivation and willingness of companies to protect the climate more and substantially increase energy efficiency - and act as role models in the process. “In doing this we are going be- yond what is required by law in many cases,” says Christine Uhde-Leischner, whose tasks at Prinovis include coordinating environmental protection. “For example, we have introduced an energy management system at our sites to cen- trally record energy consumption, com- pare it with the values of other locations, and develop suggestions for how to save energy,” she adds. Alongside an integrated quality and environmental management program that has been running for years at Itzehoe and Dresden, Prinovis uses an environmentally friendly combined heat and power (CHP) plant to generate electricity and heat onsite at the company’s Itzehoe, Nuremberg and Liverpool sites. “By operating at over 90 percent efficiency we can save a lot of fuel and avoid greenhouse gas emissions,” explains Uhde-Leischner. Prinovis’s eco-friendly power plant in Liverpool 44 // 45 Environment // Developments with regard to the principles of the UN Global Compact

The Principles Developments of the UN Global Compact (October 2008 to present)

Businesses should • Bundled all climate protection • Developed Group-wide climate pro- support a precautionary measures in the “be green” team, an tection strategy called “be green” and approach to environmental international work group comprised launched it throughout the Group, 7 challenges. of environmental managers/officers achieved first milestones (see below) from the corporate divisions

Businesses should • Positioning of the issue on top level • Produced and published a “be green” undertake initiatives to by the Chairman & CEO (statements/ motivation film for employees (Ger- promote greater environ- interview) man/English) with the aim of making 8 mental responsibility. climate protection more tangible and • Bertelsmann has measured and pub- encouraging employee involvement lished its first worldwide carbon foot-

print (for 2008: 1.532 million tonnes CO2 • Set up an ongoing “be green” section eq.), calculated by an outside environ- on the Bertelsmann intranet dedicated mental institute (IFEU). to the topic of environmental protection (approx. 30 news articles and • Carried out international “be green” dossiers on climate protection) days in the lead-up to the UN’s World Environment Day on June 4, 2010, with • Integrated a question about environ- comprehensive environmental and cli- mental protection in the worldwide mate protection activities for employees employee survey at over 35 sites in 10 countries and for employees worldwide in intranet

Businesses should • Carried out a benchmark study on • Held a workshop on energy efficiency encourage the develop- environmental protection in nine media and Green IT for the environmental ment and diffusion of companies and published it in-house managers/officers 9 environmentally friendly technologies. • Carried out “Green Innovations in Practice” study about green business models and published it in-house Communication on Progress for the UN Global Compact

Goals (present to October 2011)

• Achieve further milestones and con- • Continue developing Bertelsmann’s tinue to develop the Group-wide “be Environment Policy green” climate protection strategy • Continue developing the Bertelsmann Paper Policy

• Draw up and publish the worldwide • Expand “be green” communications to carbon footprint 2010 (calculated every the in- and outside, including ongoing two years) publication of “green news” on the Ber- telsmann intranet and Bertelsmann’s • Carry out another international “be Corporate Responsibility Portal green” Day • Intensify and formalize stakeholder • Train & coach Bertelsmann apprentices dialog on environmental and climate to be “climate ambassadors” and act as protection multipliers for climate protection during their training segments

• Update and expand the benchmark • Carry out further workshops on topics study on environmental protection at including energy efficiency media companies Environment 46 // 47

A scene from the employee training materials for the Code of Conduct Communication on Progress for the UN Global Compact

Anti-Corruption

Global Code of Conduct // Bertelsmann published the Bertelsmann Code of Conduct in 2008 as a binding guideline for law-abiding and responsible conduct within the company. 48 // 49 Anti-Corruption // Overview

COMMITMENT TO fighting corruption means above all else informing and educating one’s own employees The Global Code of Conduct What do important concepts such as fairness, honesty, integrity, respect and responsible corporate management and control mean in the context of everyday business? This question is crucial when it comes to taking specific action - because economic success and good corporate citizenship are two inseparable objectives for our company. Corporate responsibility and ethical behavior toward employees, customers, business partners and government agencies play an integral part in our value system at Bertelsmann.

Ethics & Compliance

The Bertelsmann Ethics & Compliance program assists the company and its subsidiaries in maintaining compliance with laws, regulations and company policies and in promoting an ethical culture consistent with the values and principles stated in the Bertelsmann Essentials and the Bertels- mann Code of Conduct.

The channels of the Bertelsmann Whistleblowing System. Communication on Progress for the UN Global Compact

COMMITMENT TO fighting corruption means above all else informing and educating one’s own employees

Our Code Of Conduct

The Bertelsmann Code of Conduct fol- lows international standards. It is based on ethical principles, legal requirements and Bertelsmann’s own in-house rules and regulations. At the same time, the Code of Conduct is grounded in the Bertels- mann Essentials, which convey our goals and basic values. The Bertelsmann Code of Conduct consists of 20 principles that govern corporate responsibility, workplace conduct, business and financial transactions, and media and technology. The 20 principles address specific topics such as data protection, anti-corruption and independent and responsible reporting in Ber- telsmann’s published media.

For more information about the Code of Conduct and the whistleblower system please refer to www.ethics.bertelsmann.com

Training and whistleblowing scheme for employees To familiarize our employees worldwide with the Code of Conduct, the Ethics & Compliance Department has developed an interactive training program in twelve languages, which is available in both Web- based and traditional formats and was implemented in June 2009. 50 // 51 Anti-Corruption // Code of Conduct The Bertelsmann Code of Conduct launched in 2008

Corporate Responsibility Interpersonal Conduct in the Workplace

Compliance We comply with all applicable local, Mutual trust & We treat each other in a mutually re- with the law national and international laws and respect spectful and trusting manner at work and regulations wherever we do business. seek to create a workplace environment that does not allow for discrimination, harassment, bullying or intimidation. Human rights The respect for and protection of human rights is part of our corporate culture. Freedom to speak We encourage our employees to speak without fear of up freely and without fear of retaliation. Environment, Environmental protection, health and retaliation We do not retaliate against employees health & safety are integral parts of our corporate who raise good-faith workplace concerns. safety responsibility.

Data privacy & We collect, retain, use and transmit Product We create and develop safe products protection personal data and information in compli- safety and services for our customers. ance with applicable law and policy.

Governmental We conduct proper and legally impec- Responsible We deal with company property, prod- & regulatory cable relations with all government use of assets ucts and resources responsibly and relations regulators and agencies. appropriately and use them only for their intended business purposes.

Conflicts of We disclose potential or actual conflicts interest of interest in the workplace in a timely manner for proper review and resolution. Communication on Progress for the UN Global Compact

Business & Finance Media & Technology

Financial We conduct our business and manage Intellectual We respect and protect all forms of intel- integrity & recordkeeping and reporting with integ- property lectual property and protected content antifraud rity and transparency. protection regardless of whether they are created by our companies or by third parties.

Anti-corruption We do not engage in corruption, bribery, & anti-bribery kickbacks or other illegal transactions Information We make proper business use of work- with private, commercial or governmental technology use & place information technology and help to parties. security protect systems and equipment against internal and external threats.

Gifts & When giving or receiving business entertainment gifts or entertainment, we do so in a Confidentiality & We protect company, product, service transparent manner that complies with public relations and other confidential business company policy, industry standards information from unauthorized disclosure and applicable law. and use.

Antitrust We comply with applicable antitrust Honest We do not knowingly engage in or compliance and competition laws and consult expert statements promote misrepresentation or fraud in company counsel on antitrust and regarding prod- the marketing or advertising of our competition issues. ucts & services products and services.

Insider trading We comply with applicable insider trad- Media We observe editorial and journalistic ing laws and company policy regarding independence & independence in news gathering and material nonpublic information that we responsibilities distribution. learn about our own or other businesses. 52 // 53 Anti-Corruption // Developments with regard to the principles of the UN Global Compact

The Principles of the Developments UN Global Compact (October 2008 to present)

Businesses should • In 2008, Bertelsmann implemented a • The Ethics & Compliance Department work against corrup- Global Code of Conduct that incorpo- has also conducted workshops and tion in all its forms, rates clear guidance on topics such webinars with more than 100 Ethics & 10 including extortion as financial integrity, antifraud, anti- Compliance Representatives from and bribery. corruption, anti-bribery and conflicts subsidiaries around the world, to of interest. The Code was distributed promote the integration of compliance to all employees worldwide and is also into business processes, including often used in dealings with business compliance with anti-corruption partners. requirements.

• As part of the Code and training • The Corporate Audit department has initiative, employees are instructed undergone training in specific tech- about the comprehensive means that niques for investigating fraudulent the company puts at their disposal to behavior. safely report concerns about corruption or similar violations of company • With the help of mass data analyses policy. The company makes various and red flag tests, preventive (rather channels available for reporting vio- than case-specific) procedures have lations: ombudspersons, an Internet- been implemented to identify corrup- based whistleblowing system and the tion in sales. Bertelsmann Ethics & Compliance Department.

• The E&C Department assures that reports are promptly reviewed and investigated by the appropriate department. In 2008, a Corporate Compliance Committee was formed and meets regularly to monitor whether all reports have received adequate and timely scrutiny. Communication on Progress for the UN Global Compact

Goals (present to October 2011)

• A review of the Code of Conduct is • The annual compliance risk assess- planned for 2011 in the context of a ment includes a review of corruption larger programmatic review. risks.

• Training for newly hired employees • Annual workshops and regular is administered on an ongoing basis. exchanges with more than 100 Refresher training for all employees is Ethics & Compliance Representatives anticipated for 2012. from subsidiaries will continue to occur. • Ongoing monitoring of compliance with anti-corruption requirements • Preventive procedures will be further occurs based on a review of reports developed, including spot checks received through the comprehensive to identify corruption in sales, in ac- whistleblowing system. cordance with guidelines formulated for that purpose. Anti-Corruption 54 // 55

More details about how Bertelsmann bears its Corporate Responsibility can be found at www.bertelsmann.com/responsibility Communication on Progress for the UN Global Compact

More details about how Bertelsmann bears its Corporate Responsibility can be found at

Publishing information

Publisher Bertelsmann AG Corporate Communications Corporate Responsibility

Contact Bertelsmann AG Corporate Communications Barbara Kutscher Director Corporate Responsibility [email protected] www.bertelsmann.com/responsibility

Design and production medienfabrik Gütersloh

Reproduction in whole or in part is permitted only with the approval of the publisher.

October 2010