UN Global Compact principles: I, III, VI

Every day, approximately 130,000 people in about 50 countries work to ensure Bertelsmann’s success, growth and continuous development. That is the reason why, for generations, the company has made responsibility toward its employees a priority. Bertelsmann wants to create a working environment of participation and partnership for all employees.

To be an attractive employer for a diverse workforce, retain employees long-term, and remain competitive, Bertelsmann promotes the development of its employees, and creates the prerequisites for enabling Creativity & Entrepreneurship in a fair and healthy workplace setting. In particular, these include freedom, trust, and respect. Bertelsmann aspires to this all over the world, honoring widely varying social, economic, regulatory and cultural conditions in the process.

In addition, employees of all generations increasingly attach particular importance to meaning in the work they perform for their employer. To attract the best talent, employers are expected to have and convey a greater “sense of purpose.” Only if employees are able to identify with their company, its values and strategic goals, they are able to actively implement and ensure that these goals are achieved. This applies particularly in times of change.

Bertelsmann strives to offer its employees fair framework conditions for their work. In addition to the protection of human and personal rights, partnership and trustworthy cooperation with employees and their representatives, workplace safety, fair distribution of benefits, flexible working arrangements, and fair treatment of freelancers and external service providers are crucial aspects of fair working conditions at Bertelsmann.

Motivated employees are key to creativity, innovation, and continued business success. The Executive Board Guidelines for HR work at Bertelsmann are based on this principle, which is enshrined in the Corporate Constitution and the Bertelsmann Essentials. Supplementary rules are laid down in the Bertelsmann Code of Conduct, which is binding for all employees (see GRI 102-16  ).

The Chief Human Resources Officer (CHRO) is responsible for dealing with employee matters across the whole Group. As Head of the Corporate HR department, which supports the coordination of tasks and development of relevant HR policy, the CHRO cooperates closely with the HR directors of the divisions. The main focus of his work throughout the Group includes setting the strategic HR agenda, aligning management development with the Group’s strategic priorities, talent management, Bertelsmann University, ensuring the standardization and IT support for important HR processes, further developing the corporate culture and implementing corporate responsibility in the Group.

To ensure the coordination of procedures throughout its decentralized structure, Bertelsmann’s HR function is organized according to a “dotted-line” concept, with complementary reporting as well as supervisory relationships. This allows Group-wide HR topics to be implemented in accordance with the Executive Board’s decisions.

Another important aspect of Bertelsmann’s HR work is the exchange of information in committees:

• The HR Committee determines the basic aspects of HR work in the interest of the entire Group. Its members include the CHRO, the heads of HR of the divisions, and senior executives from the Group’s Corporate HR department.

• HR Country Coordination Meetings are designed for cross-divisional coordination within a region and ensure the implementation of HR initiatives across the Group. Its members include the heads of HR of the Group’s largest companies or those with the largest number of employees in a specified country.

• The Nomination & Compensation Committees of the divisions and Corporate Center decide on the implementation of remuneration and staffing policies in their areas of responsibility.

Responsibility for ensuring fair working conditions is decentralized, meaning it lies with the management of the local businesses. Bertelsmann provides Group-wide framework conditions that enable local businesses to fulfill this responsibility. Collective regulations (e.g., Group company agreements) and Executive Board Guidelines on certain topics, like those on remuneration and the use of external employees, are also relevant in this regard. In addition, various formats such as the Bertelsmann Group Dialog Conference, and a working group, deal with topics such as a culture of partnership and fair working conditions. As the key contact person for the various bodies representing employee interests, Bertelsmann’s CHRO accompanies or presides over these formats.

In addition, there are external regulations, such as the standards of the International Labour Organization, the OECD Guidelines for Multinational Enterprises and Bertelsmann’s voluntary commitment in accordance with the UN Global Compact (see GRI 102-12  , 102-16  ).

At Bertelsmann, remuneration issues are an essential part of the topic of fair working conditions. The compensation system is designed to ensure that remuneration is driven by market, function and performance, taking into account business-specific characteristics. Employee profit sharing at Bertelsmann and many of its subsidiaries in Germany is based on the same criteria as the measurement of variable remuneration components of board members and executives. Many domestic and foreign Group companies have similar success and profit-sharing models adapted to local requirements. In 2020, nearly €100 million of the 2019 profit was distributed as part of such schemes.

Participation in decision-making processes and the granting of the greatest possible freedom contribute to employee loyalty and satisfaction. To support a healthy work-life balance, this also includes offering employees flexible arrangements about where and when they work. Working-time models that focus on results rather than physical presence, as well as trust-based working hours, are widespread. Especially in times of a pandemic such as the one that dominated all areas of life in 2020, this basic idea has enabled and favored the extensive shift to working from home and mobile office solutions. For many businesses, this also confirmed that they should increase their focus on flexible forms of work in the future.

The flexibility requirements of a rapidly changing world of work also mean that knowledge and expertise need to be sourced from outside the company to ensure satisfied customers during peak phases. The company relies on staffing agencies and employs external personnel in addition to permanent employees where the specifics of the tasks allow and require this. Bertelsmann defines external personnel as self-employed persons, service providers and consultants, or as agency staff who work for a Group company. The employment of external personnel must be in accordance with the company’s values. The Executive Board Guideline on the Engagement of External Personnel requires standard processes to ensure compliance with legal requirements. This is supplemented by the Supplier Code of Conduct, which also obliges service providers (see GRI 102-16  ).

UN Global Compact principle: III

Bertelsmann sees the continuous dialog between employee representatives and company management as a key element in its company culture. Additionally, regular dialog with employees and their representatives makes it possible to continually review workplace conditions, identify possible improvements and derive measures. Digital transformation is changing the work environment and every individual’s tasks. At Bertelsmann, this process also includes the restructuring of several traditional businesses. Parallel to this, some parts of the company are being dismantled while others are reorganized, expanded or newly built. Seeing change as both a challenge and an opportunity, the Group’s management seeks to shape those changes together with employees.

Although, as a media company, Bertelsmann falls under Germany’s tendency protections and its Supervisory Board is therefore not subject to statutory co-determination requirements, the company has voluntarily granted its employees four seats on the Supervisory Board of Bertelsmann SE & Co. KGaA. Three of them are occupied by leading Works Council members at Group companies. The seat assigned to the Bertelsmann Management Representative Committee, which was vacant at the end of 2020, was filled in May 2021. In addition, the workforce, managers, employees with disabilities, and trainees have platforms for exchanging ideas, advancing topics and constructively voicing their concerns. One proven format is the Bertelsmann Group Dialog Conference, at which the Corporate Works Councils of Bertelsmann, RTL Deutschland, and Gruner + Jahr meet with the Group Chairman & CEO and the Chief HR Officer for consultation and discussion. In 2020, this led to intensive collaboration and cross-divisional exchange beyond the scope of the committees required by law, for example to tackle challenges posed by the coronavirus pandemic and to initiate projects such as a Bertelsmann platform for cooperating on IT matters. The same applies to Representatives for Employees with Disabilities in the Group for implementing the Inclusion Action Plan in the German Bertelsmann companies.

Employees are also involved in the development and improvement of working conditions through standardized HR tools (Performance and Development Dialogs, Agreements on Objectives, and Team Talks), as well as the Bertelsmann Employee Survey. The Employee Survey has been a key element of Bertelsmann’s corporate culture since 1977. In 2020, in response to the coronavirus pandemic, numerous pulse surveys were conducted in the divisions and among top managers. In addition, the frequency of the international Employee Survey was shortened to two years.

UN Global Compact principle: I

To create a health-promoting working environment and prevent work-related health risks, Bertelsmann aims to continually expand occupational health management (OHM) at its German sites. Bertelsmann Health Management develops and supervises the Group’s health strategy in cooperation with a cross-functional Strategy Committee. The Committee includes the heads of the Group Occupational Health and Safety department, Company Medical Services, the Bertelsmann Company Health Insurance Fund (Bertelsmann BKK), Bertelsmann University, the Sports and Health and Corporate Responsibility departments, as well as the Group Representative for Employees with Disabilities. The Head of HR Coordination and Shared Services chairs this committee and directs the implementation of the health strategy.

He is supported by the cross-divisional “Health Community”, in which employees from the Health and HR departments, Works Council Members and Representatives for Employees with Disabilities address issues such as “Minimum Health Standards” at German companies. These Minimum Standards include qualification of managers on matters of health, the implementation of a Working Group on Health, the provision of health offers and information for employees, and access to company social counseling. Bertelsmann’s in-house Health Management Consulting, a cooperation between Bertelsmann Health Management and the Bertelsmann BKK, also provides needs-based advice on the development and implementation of occupational health management. Health Managers and Health Contact Persons at the divisions’ sites work to promote the implementation of health management. In addition, there is a Company Integration Management implemented that is supported by local integration teams.

Due to the coronavirus pandemic, the focus in 2020 was on immediate health protection of all employees worldwide. This included the establishment of central and local crisis teams, which developed and implemented prevention and protection measures in accordance with the applicable laws. The most important measure was the Group-wide shift to working from home wherever this was compatible with operational considerations (see GRI 403-3  ).

In addition, the results of the third Germany-wide evaluation of the “Minimum Health Standards” and the health-related recommendations based on the Group-wide Employee Survey (2019) were communicated to the German companies in 2020. Most companies drive the implementation of the Minimum Standards and have thus already established the first basic structures for occupational health management.

UN Global Compact principle: I

Bertelsmann’s Central Occupational Health and Safety department is responsible for approximately 25,000 employees at Arvato, Bertelsmann Accounting Services, and Bertelsmann Corporate. The Group’s own Company Medical Services (see GRI 403-3  ) supports about 14,000 employees in the Gütersloh region and at other Bertelsmann sites in Germany. The Central Occupational Health and Safety department and the Company Medical Services advise numerous other German Bertelsmann companies on occupational health and safety requirements and standards.

At Bertelsmann, responsibility for implementing occupational health and safety, and thus also for corresponding management systems, is decentralized to the divisions. For the most part, these divisions have multi-site occupational health and safety management systems which align with common occupational health and safety standards, e.g., the Occupational Health and Safety Standards (OHSAS, now ISO45001), and take into account German legal requirements regarding occupational health and safety. In some cases, occupational health and safety is integrated into the company’s HSSE (Health, Safety, Security & Environment) organization.

Platforms within the divisions are used to map the company structures and data required under German occupational health and safety law on a daily basis and in compliance with data privacy protection requirements, e.g., the number and training status of safety officers, documentation of recurring instructions, monitoring of training and appointment of company emergency responders, and company-relevant preventive medical checkups. At all the companies included, employees with various occupational health and safety tasks are involved in this, e.g., safety representatives and contact persons for accidents, health, and risk assessment.

UN Global Compact principle: I

The legally mandated risk assessment is carried out and documented at the German sites of the corporate divisions. In-house checklists, templates from the German Social Accident Insurance Institution, and validated questionnaires are used to do so. In some cases, site inspections are carried out for additional identification of existing potential hazards, as well as further measurements of noise, brightness, and climate. The findings, as well as any workplace accidents, are discussed at Health and Safety Committee meetings. Some operations have additionally established processes for dealing with incidents and near-accidents.

Bertelsmann Health Management supports the Group companies in Germany in implementing the legal requirements for assessing mental stress in work contexts. In cooperation with the “Health Community,” a toolbox for mental risk assessment was made available to the companies. In addition, the Group-wide Employee Survey (2019) was analyzed from a health perspective and a divisional health index was calculated. In 2020, health-related action areas were identified based on these analyses, and recommendations were communicated to the German divisions.

UN Global Compact principle: I

In Germany, the deployment of company physicians, their qualifications and their tasks are prescribed by law and by the regulations of the German Social Accident Insurance Institution. In addition to its own company medical service, Bertelsmann works with external company physicians at the respective sites to ensure that these requirements are met (see GRI 403-1  ). In order to ensure a similar range of services at all sites, the external company physicians are guided by the portfolio of Bertelsmann’s own Company Medical Services in Gütersloh. The range of services offered by the company doctors and their communication materials are displayed both on the company intranet and on a central Bertelsmann website.

In the 2020 year of the pandemic, the focus was on the immediate health protection of all employees (see GRI 103 Management approach  ). Bertelsmann’s Company Medical Service played a pivotal and advisory role throughout Germany. The Company Physician was a permanent member of the company’s central Crisis Task Force and of local crisis teams. Local crisis team activities focused in particular on hygiene and behavioral matters, such as business trips to risk areas, the establishment of (PCR) testing capacities, infection prevention, protective equipment (especially masks), the development and implementation of return policies, including necessary organizational adjustments and provision of information to employees.

UN Global Compact principle: I

The legally required Occupational Safety Committee meetings and the meetings of Working Groups on Health are organized by the German divisions on a quarterly basis and implemented locally. Participants include the employer or a management representative appointed by the employer, two members to be determined by the Works Council, the Company Physician, the Occupational Safety Officer, the Safety Representative and the Representative for Employees with Disabilities. Responsibility for all decisions and measures taken lies with the management of each company. The company physician, the occupational safety officer, and the safety representative are involved as advisors without the right to issue instructions. The representatives of the Works Council exercise a supervisory function in the interests of the employees. The meetings of the Occupational Health and Safety Committee and/or the Working Group on Health serve to analyze and discuss occupational health and safety issues and to develop targeted measures.

UN Global Compact principle: I

The legally required instructions and the organization of other relevant training courses are carried out independently by the German divisions. Depending on the activity and the degree of risk, employee training takes place online and/or in person and is documented.

UN Global Compact principle: I

Bertelsmann’s divisions provide their employees with numerous offers to promote physical and mental health and preventive healthcare. The local health working groups identify action areas, and Health Contact Persons provide support in their implementation. Bertelsmann BKK also provides support in the form of new health offerings tailored to the work situation, such as digital presentations on sleep, stress management or managing virtual teams, which the divisions can access. In addition to the Company Social Counseling Services offered throughout Germany, some locations cooperate with an external family service that offers care options for children and relatives in need of care. The offers are presented on the intranets of the various divisions and in some cases on a central Bertelsmann website.

In the 2020 year of the pandemic, a large proportion of the health promotion offers were provided digitally, so that employees throughout Germany can also take part in e.g., fitness and exercise offers (“Moving Break”), relaxation and mindfulness courses, or health days while working from home. In particular, the “Fit for Work” campaign has encouraged and motivated many employees across Germany to add more exercise to their daily work routine. Other health projects are also being carried out in some divisions, e.g., on health-oriented leadership, ergonomics in the home office, strengthening mental health and resilience.

UN Global Compact principle: I

The assurance of product safety for customers is anchored in the Bertelsmann Code of Conduct (see GRI 102-16  ): “Our products and services must not contain defects or unsafe features that could lead to the endangerment of health (...)” (see GRI 417  ).

If external parties work for the company, their deployment and employment must be in accordance with Bertelsmann’s corporate values (see GRI 401  ). In the case of cooperation with external companies, safety briefings are ensured. Some German companies already employ external company coordinators. These coordinators monitor and check the activities of external organizations, e.g., building cleaners, repair companies, maintenance companies, and inspection organizations.

UN Global Compact principle: I

Due to the decentralized organizational Occupational Health and Safety structures, this data is not available centrally at Bertelsmann (see GRI 403-1  ). A central collection of this data is not currently planned.

UN Global Compact principle: I

Due to the decentralized organizational Occupational Health and Safety structures, this data is not available centrally at Bertelsmann. A central collection of this data is not currently planned.

UN Global Compact principle: I

A company’s success is determined by its employees’ qualifications and efforts. Major changes such as the digital transformation of media, services and education, the demographic shift, or repercussions of the coronavirus pandemic, can only be tackled with qualified and motivated employees.

The more and more rapidly changing business environment constantly gives rise to new challenges for all employees in their workaday routine. The better Bertelsmann manages to keep qualifying employees in success-critical skills, the more successful the business can be, and beyond this, the more attractive it is for its workforce and for applicants. Vocational education and training are therefore considered a long-term investment in the future and in the stability of society, for both Bertelsmann and its employees.

Bertelsmann University

Bertelsmann University aims to continuously develop success-critical skills and competencies in employees and managers, thereby empowering them to adapt to ever-changing requirements. In this way, Bertelsmann University also contributes to maintaining its workers’ employability long-term.

The central learning organization systematically targets its international offering at top executives and Bertelsmann talents across the Group in the areas of strategy and leadership, at creative experts in the areas of creativity and innovation, and at employees specifically in the fields of technology and data. It also offers Bertelsmann employees a wide-ranging digital curriculum from leading, international providers of online training on various topics. Thanks to these digital formats, learning content is flexibly available to employees and managers, and the time and place of learning is geared to individual needs and organizational requirements.

Bertelsmann University is supplemented by division-specific and local offerings from Bertelsmann divisions and companies. Together with the Bertelsmann divisions, Bertelsmann University promotes a culture of digital, effective learning with innovative, cross-divisional initiatives to strengthen adaptive skills and a flexible mindset.

Bertelsmann University is a main department at the Corporate Center. It is led by the Chief Learning Officer, who reports to the Chief Human Resources Officer. The Executive Board, Group Management Committee and HR Committee regularly discuss and review Bertelsmann University’s orientation and activities. It is supported by the Divisional Learning Committee, where Learning and Development representatives from the divisions connect, coordinate and collaborate with each other.

Training in Germany: A Wide Range of Offers

In Germany, the Group offers young people industrial and commercial training options in more than 45 different professions. In addition to traditional apprenticeship programs, this spectrum also includes a variety of dual-study programs. With its nationwide offer, Bertelsmann is one of Germany’s largest apprentice-training companies and is a protagonist in shaping the vocational training landscape. Among the challenges to be overcome is the future-proofing of training programs to prevail in the intensified competition for highly qualified junior employees.

The Central Education department is responsible for training measures at the Gütersloh location. It develops offers based on the company’s changing needs and requirements, and ensures that they reflect the company’s values of Creativity & Entrepreneurship. The department works closely with the executives and HR managers of the training companies, as well as the Works Council. In Gütersloh alone, more than 650 young people are taking the opportunity to learn a profession or to complete a part-time Bachelor of Arts or Bachelor of Science degree at Bertelsmann. Of these, approximately 200 students are undergoing industrial and commercial training at the Group’s own vocational school.

In 2020 the most important measures in the field of learning were:

• In response to the global coronavirus pandemic, Bertelsmann University suspended all in-person events from March 2020 and continued its international programs in the areas of strategy, leadership, and transformation in digital form.

• As part of the further development of digital offerings with a focus on tech skills, new, international learning curricula were introduced in the areas of data, cloud and artificial intelligence. In addition, the 3-year Udacity scholarship program entered its second round with a total of 50,000 seats, open to employees as well as external applicants. In 2020, the in-house graduation rate for Nanodegree candidates was approximately 20 percent of graduates.

• The promotion of a learning culture and social learning was the focus of other initiatives, such as the cross-divisional “Your Campus” program, a digital, international peer-to-peer learning offer.

• In Germany, Bertelsmann’s training and study programs were also adapted to the changed conditions brought about by the coronavirus pandemic: among other things, by adapting the learning environments and increasingly using digital working methods.

UN Global Compact principle: I

Total training

in hours

2020	2019
353,363	325,080

Basis: all training data entered on the digital HR platform “peoplenet”

Share of digital learning hours

in percent

2020	2019
53	33

Basis: all training data entered on the digital HR platform “peoplenet”

Absolute hours of training in IT skills

2020	2019
188,546	33,635

Basis: all training data entered on the digital HR platform “peoplenet”

The absolute number of training hours increased in 2020 compared to 2019. Due to the coronavirus pandemic, the proportion of digital training hours also increased significantly from 33 percent to 53 percent, as did training hours in the area of IT skills in particular.

Bertelsmann does not currently report training hours broken down by gender and other employee categories, since this information is not available centrally. Bertelsmann is continuing to develop its data collection in this respect, and plans to report on this in the medium term.

UN Global Compact principles: I, VI

A diverse workforce enhances creativity, innovation, and performance, as well as employee motivation. A holistic approach to Diversity, Equity & Inclusion not only serves to increase diversity in the workforce, but also promotes a culture of valuing diversity and authenticity. In combination with a constant, ongoing review and adaptation of structures and processes, the aim is to enable all employees to develop their full potential. This creates the right conditions for the diversity of perspectives in heterogeneous teams – based on diverse competencies, backgrounds and experiences – to have a positive impact on corporate decision-making processes. Having a diversity of perspectives in the workforce is essential in order to represent the diversity of society in the content to be disseminated, and for meeting specific needs in media, products and services – with the aim of reaching diverse target groups. The importance of Diversity, Equity & Inclusion (DEI) for the company’s success is also reflected in the steadily increasing requirements from business partners. Moreover, Diversity, Equity & Inclusion helps to strengthen a company’s attractiveness as an employer.

For Bertelsmann, the diversity of its workforce is a prerequisite for long-term business success. This is expressed in the Bertelsmann Essentials. In pursuing a more holistic approach in 2020, the Bertelsmann Executive Board’s Diversity Statement was further developed into a Diversity, Equity & Inclusion Policy  , which was adopted in April 2021. In this policy, the Bertelsmann Executive Board affirms its intention to further increase the diversity of the workforce at all levels and in all respects, and to create an environment that embraces employee involvement, collaboration, and appreciation. A culture of respect and inclusion, where employees are valued for their diverse backgrounds, perspectives and talents, makes Bertelsmann a more inclusive company. The Bertelsmann Code of Conduct also mandates a respectful and appreciative treatment of all employees (see GRI 102-16  ). The Executive Board Guideline on Principles of Hiring Policy also serves as a guideline for addressing diversity. Beyond this, Bertelsmann’s overall diversity strategy takes its cue from legal regulations to ensure equal opportunity at listed companies, even if the company does not fall within their scope.

The Executive Board bears the strategic responsibility for DEI within the Group. The DEI strategy is implemented by the Corporate Responsibility department, which is responsible for matters of DEI, with support from a Group-wide and other divisional working groups. Moreover, executives, human resources and communications managers in particular are responsible for visibly modeling and implementing DEI in practice through their function as role models. In 2020, the focus was placed on the dimensions “gender,” “disability,” and “sexual orientation/identity.” In line with the Group’s decentralized structure, some of the divisions also set additional priorities in line with the local conditions and business models. An overview of DEI measures at Bertelsmann and in the divisions can be found on the Bertelsmann website at www.bertelsmann.com/diversity  .

To enhance diversity at the management levels, Bertelsmann aims to achieve the goal of having women occupy one-third of positions in top and senior management across all divisions by the end of 2021. As a consequence, the targeted proportion of women in the respective Group-wide talent pools was set at one-third for the Top and Senior Management Pools and 50 percent in the Career Development Pool. These targets were reached in 2019/2020. Moreover, the proportion of women in Top Management increased from 22 percent in the previous year to 27 percent (see GRI 405-1  ). The proportion of women in Senior Management remained constant at 30 percent. The degree of target achievement is reported annually to the Bertelsmann Supervisory Board and Executive Board.

Bertelsmann Action Plan for Inclusion 2019 - 2024 (API) has the objective of designing processes and structures at German companies in such a way that employees with disabilities can work in as barrier-free an environment as possible at Bertelsmann and thus contribute to the company’s success to their full potential. The API comprises 27 goals and 69 measures. The first evaluation of the implemented measures took place as scheduled after one year and can be accessed on the Bertelsmann website: www.bertelsmann.com/disability-and-inclusion  .

Bertelsmann’s LGBTIQ employee network be.queer continued its activities in 2020 and advanced the international networking between LGBTIQ networks in the divisions. A wide range of other measures were also implemented in the divisions in 2020. In particular, the divisions launched initiatives to combat racism and supported the “Black Lives Matter” movement.

Gender-neutral compensation

The equal treatment of women and men set out in the Code of Conduct explicitly applies to compensation as well. Bertelsmann’s remuneration policy is to establish consistent remuneration structures in the Group. The compensation system is intended to ensure that remuneration is exclusively driven by the market, function and performance – and is therefore gender-neutral. Where explicit employment descriptions or compensation exist, these are likewise completely gender-neutral. Women and men in comparable markets, in comparable positions, and delivering a comparable performance have equal earning opportunities.

UN Global Compact principles: I-II, VI

The Code of Conduct and the Supplier Code of Conduct (see GRI 102-16  ) contain a clear prohibition of discrimination and intimidation, which is also expressed in the Bertelsmann Diversity, Equity & Inclusion Policy (see GRI 405  ). In addition to the aforementioned reporting channels, AGG contact persons have been appointed at all German locations. Employees can contact them in the event of suspected breaches of Germany’s General Equal Treatment Act (AGG). Employees are informed about their rights under the AGG by means of brochures, posters and information provided on the company intranet. Throughout the Group, employees were sensitized to the issue of anti-discrimination in Code of Conduct tutorials and made aware of their rights. These and other international activities are being continuously developed. In the United States, for example, the Group has stepped up training to prevent sexual harassment and racism in the workplace.

UN Global Compact principles: I-III

The protection of human rights within the company and in the supply chain is a priority for Bertelsmann. Bertelsmann is committed to the principles of the Universal Declaration of Human Rights and to the principles of the UN Global Compact, to the United Nations Guiding Principles on Business and Human Rights, and the International Labour Organization (ILO) core labor standards. Ensuring fair working conditions is an integral part of Bertelsmann’s corporate culture. Bertelsmann sets binding human rights standards in the company as well as in the global supply chain, which must be adhered to by all employees and business partners. Key corporate guidelines that address the issue of human rights and codify these standards are the Bertelsmann Code of Conduct, the Bertelsmann Supplier Code of Conduct as well as the Executive Board Guideline on Anti-corruption & Integrity (see GRI 102-16  ).

The Code of Conduct and the Supplier Code of Conduct reaffirm the right to freedom of association and the right to engage in collective bargaining, in accordance with applicable laws and regulations, for all employees of Bertelsmann companies as well as those of business partners. At Bertelsmann violations of this principle may be reported via the aforementioned whistleblowing channels of Bertelsmann’s compliance management system, both by employees and by third parties (see GRI 102-17  ).

UN Global Compact principles: I-II, V

Bertelsmann does not tolerate child and forced labor, and expects its business partners to share this position. The Code of Conduct and the Supplier Code of Conduct contain accordingly explicit prohibitions (see GRI 102-16  ). In addition, Bertelsmann and individual Group companies issued statements in accordance with the UK Modern Slavery Act  that condemn all forms of modern slavery, forced labor and child labor, exploitation, and discrimination, and present the measures taken in 2020 to prevent these human rights violations.

UN Global Compact principles: I-II, VI

See GRI 408  .

UN Global Compact principle: I

Bertelsmann sees itself as part of society. Responsibility is deeply rooted in its corporate culture and hence in the daily activities of the Group, its divisions and companies. The Bertelsmann Essentials, which focus on the values of Creativity & Entrepreneurship, form the basis for this. According to the Essentials, Bertelsmann is mindful of its impact on society and the environment, and it seeks to make a positive difference. This also includes the Group contributing its media, services and education competence, and the expertise of its employees where help and support are needed outside the company.

As a media, services and education company, Bertelsmann’s activities are interwoven with societal developments around the world. Society and our employees expect the company to fulfill its responsibility as a corporate citizen beyond its own businesses. Bertelsmann’s corporate social responsibility efforts, on the Group (see GRI 201-1  ), divisional and company level, encompass a wide range of measures and sponsorship programs that involve and develop local communities. These efforts contribute to the company’s success by supporting its “license to operate”; that is, enhancing the community’s acceptance of Bertelsmann.

Donations, sponsorship, funding for charitable projects, and memberships both at the Group and divisional level are an expression of responsible behavior and support Bertelsmann’s role as a good corporate citizen worldwide. Carefully planned and professionally executed measures boost the company’s reputation and anchor Bertelsmann as a responsible partner.

The Executive Board’s Guideline on Donations, Sponsorships and Memberships ensures that support measures in the form of donations, sponsorship and membership comply with legal and fiscal requirements and are consistent with the company’s strategy.

In line with the principle of decentralization, the divisions independently decide on their collaborations, sponsorship projects, and donations, steered by the Executive Board Guideline and in coordination with Corporate Communications. The Chair and CEO decides on one-off donations and sponsorships exceeding €100,000, as well as regular commitments exceeding €50,000. All commitments must be reported annually to the Group tax department, to ensure that the Executive Board can fulfill its related due diligence and compliance obligations. Group companies are also required to define and document their donation activities and sponsorship concepts and keep these documents for a period of five years. The general prerequisites of the Executive Board Guideline on Anti-corruption & Integrity are thus complied with. Any cases of doubt are to be coordinated and clarified with the Integrity & Compliance department.

Based on the Executive Board Guideline on Donations, Sponsorships, and Memberships, Bertelsmann’s priorities for its corporate citizenship activities are as follows:

• Education, especially for socially disadvantaged groups and media-related issues (e.g., reading promotion, media literacy),
• Culture, particularly the promotion of cultural heritage and young talent in fields closely associated with Bertelsmann (e.g., literature, TV, movies),
• Academic Research, especially on topics closely associated with Bertelsmann, such as economic and social sciences, as well as media and communications science,
• Freedom of creativity and media, especially freedom of expression and press freedom, protection of intellectual property, content responsibility, and editorial independence,
• Networking activities with relevant stakeholders.

The creative industry is an engine for economic growth and jobs. To ensure that the Group can continue to invest in high-quality creative and professional content, Bertelsmann advocates for strong copyright protection and a convergent media order in the digital age.

Bertelsmann’s public affairs managers offer political decision-makers access to expert dialog partners within the Group, communicate the latest positions and facts, and provide helpful information. Joint positions are developed by in-house working groups and through association and other organizational memberships.

In addition to functioning as a discussion forum and committee of experts, Bertelsmann’s liaison offices in Brussels and Berlin, and the divisional public affairs officers, introduce policymakers to the Group’s various business models in the media, services and education sectors. Their activities include presenting Bertelsmann’s digital businesses and the international media group’s cultural activities. Bertelsmann SE & Co. KGaA is registered in the Transparency Register of the European Union and is a signatory to its Code of Conduct.

UN Global Compact principles: I,VIII

In their production and distribution of products and services as well as in their advertising and marketing communications, all Bertelsmann companies comply with legal provisions and the highest quality standards as a matter of course. The Bertelsmann Code of Conduct (see GRI 102-16  ) codifies this as a binding principle. Responsibility for the protection of media users and customers, as well as compliance with related requirements, standards and commitments, rests with the management of the individual companies. Bertelsmann and its companies use a variety of principles and procedures for product labeling, reflecting the diversity of their products and services. Particularly relevant areas where labeling is used include the protection of minors (see MSD “Content creation and dissemination”  ), as well as environmental and climate protection (see GRI 300  ).

Product safety is a focus topic that plays a special role in the production of children’s books at Penguin Random House. The company adheres to the strictest safety standards in connection with the manufacturing and production of its books, toys and related products to ensure that all Penguin Random House products are risk-assessed and safety-tested for such things as choking hazards and toxicity.

UN Global Compact principles: I-II

In the production and distribution of its media, services and education, Bertelsmann deals with customer data. In the service segment particularly, many of the world’s largest corporations entrust our company with parts of their value chain, such as the management of supply chains or customer communications. Careful and confidential handling of personal data also plays a decisive role in contact with media users.

Privacy is a fundamental human right. The objective of customer data protection is to protect people’s right to determine who has what knowledge about them, and when. This also means that personal information, or information that could identify a person, must be handled in accordance with legal requirements and adequately protected against unauthorized access, and that data subjects are able to exercise their statutory data subject rights. There are various ways for data subjects to contact Bertelsmann, including via email inboxes set up specifically for this purpose. Bertelsmann attaches great importance to protecting customer data. This includes safeguarding the personal data of company customers, as well as personal data provided to Bertelsmann by its business partners regarding their customers. In addition to the legal requirements and the Bertelsmann Code of Conduct and Supplier Code of Conduct (see GRI 102-16  ), customer data protection within the company is governed by the Executive Board’s Information Technology and Information Security Policy, the Bertelsmann Cloud Policy and, for the German companies of the Bertelsmann Group, by the “Corporate Privacy Handbook” as well.

Bertelsmann operates in a highly regulated environment as pertains to handling customer data. In all the core countries where Bertelsmann does business the protection of customer data is already required by law, and compliance with it is also part of company’s self-image. European legislators in particular are enforcing further data protection regulations against the background of Economy 4.0. and stipulate heavy fines for serious infringements within the framework of Europe’s “General Data Protection Regulation” (GDPR).

Responsibility for customer data protection is decentralized and rests with the management of the Group companies. To ensure compliance with data protection law governing customer data protection, subsidiaries use a Group-wide data protection management system that addresses in particular implementation of the documentation and accountability obligations under GDPR. In addition, German subsidiaries have a data protection organization consisting of central data protection officers and local data protection coordinators. The latter report to the local management, as well as annually or on an event-driven basis to the central data protection officers, who in turn report to the Executive Board annually or as required by events. A similar organization exists at Group companies outside Germany. An information security management system (ISMS) based on industry-standard ISO 27001 creates the technical and organizational framework for confidential data processing. The ISMS features a regular and structured survey of relevant processes and procedures to ensure compliance with statutory information security requirements, a systematic recording of risks and the derivation and monitoring of related mitigation measures to minimize risk.

UN Global Compact principles: I-II

Media is an integral and necessary part of our social order – they are simultaneously an economic and a cultural asset. Media report, clarify, classify and reflect the diversity of opinions in society. Bertelsmann takes the social responsibility that this implies seriously: for its business and journalistic activities, as well as the production and distribution of content and formats worldwide. In providing outsourcing, print and education services, the company gives top priority to professionalism and customer focus, service quality, and the protection of personal information.

The Bertelsmann Essentials define Creativity & Entrepreneurship as important guiding principles in the manufacturing and distribution of media products and services. In addition, the Bertelsmann Code of Conduct (see GRI 102-16  ) specifies key principles for the responsible production and distribution of media and services that are consistent and binding for all Bertelsmann companies. Compliance with legal requirements and the highest quality standards is a matter of course for Bertelsmann and is fundamental to the company’s success.

At Bertelsmann, content responsibility means considering the impact of the content production and distribution so as to protect the rights and interests of media users, customers and third parties in the best possible way. In accordance with the Editor-in-Chief Principle practiced at Bertelsmann, responsibility for the production and dissemination of media content lies solely with the content managers in the companies’ editorial teams and creative departments, who are free from influence from the Group’s owners or local management. Overriding principles and guidelines of media ethics are set by national and international laws governing the press, broadcasting and multimedia; by voluntary commitments to external guidelines such as the ethics codes of national press councils; and within the company by the Bertelsmann Code of Conduct. It commits Bertelsmann’s editorial and creative staff among other things to “respecting privacy and to the responsible treatment of information, opinion and images.” As a result, the company expects careful research, high-quality reporting and transparency in case of errors. Thorough journalistic craftsmanship is more important than ever in the face of online disinformation (“fake news”). In addition, content responsibility is anchored at the divisional, company and editorial-department level in a variety of ways. The representation of social diversity, as well as regulations to avoid discriminating or stereotyping content and “fake news”, also play an important role.

A special responsibility in the creation and dissemination of content applies to children and adolescents, because they experience the world as “digital natives.” The media policies and laws to protect minors from harmful media serve to examine media content to determine whether it could impair the development of children or adolescents. If such an effect is suspected, various restrictions on the content’s distribution come into force. The intent is to ensure that such media content is only accessible to age groups with the necessary maturity to put the possibly disturbing or unsettling content into context and process it appropriately. Bertelsmann gives high priority to the protection of children and young adults in the production and dissemination of its creative content, and complies with the relevant requirements. These include broadcast time restrictions as well as content and product labeling. Some divisions and companies go beyond the regulations that exist at the EU and national level, particularly in broadcasting (e.g., the Audio Visual Media Services Directive). Bertelsmann companies are also continuously involved in organizations for the protection of children and adolescents in media.

UN Global Compact principles: I-II

As a key skill of our time, media literacy has major implications for the education and development opportunities of children, adolescents and adults as well as their maturity in an increasingly digital reality of life. By promoting relevant measures, especially in literacy and reading, Bertelsmann makes an important contribution to societal and individual development.