Governance & Compliance
The DVFA Scorecard for Corporate Governance is a tool that investment professionals can use to get a good picture of a company's corporate governance performance and compare it with that of other companies. The scorecard is not only based on the German Corporate Governance Code, but also takes into account legal requirements and international standards. In the evaluation of the DVFA Scorecard for Corporate Governance, the companies included in the DAX and MDAX were analyzed again in 2020. ProSiebenSat.1 Media SE ranked 3rd in the MDAX.
The Executive Board of ProSiebenSat.1 Media SE is also convinced that sustainable economic success in a competitive environment can be achieved only by ensuring that business practices comply with the applicable laws. In addition to preventing corruption, the Company particularly focuses on antitrust legislation and media law, as well as legal provisions on data protection. ProSiebenSat.1 Group has implemented a compliance management system (CMS) to monitor compliance with the law. The main objective of the CMS is to ensure that all employees always think and act with integrity and in accordance with the guidelines and regulations, and thus to prevent law- and rule-breaking actions. The Compliance Committee and the Group Compliance department headed by Chief Compliance Officer (CCO) build up the central compliance organisation, which receive assistance in fulfilling its duties from experts in other departments, such as the Legal department. In addition, the associated Group companies have been appointed Unit Compliance Officers (UCO), who are responsible for the CMS there and are in direct contact with the respective subject experts. The CCO is entrusted with implementing the CMS in the Group, carries out risk analyses and training, and advises the Executive Board on the development and implementation of appropriate measures to minimize risks.
ProSiebenSat.1 Group does not tolerate discrimination on the basis of age, disability, ethnic background and nationality, sex and gender identity, religion and ideology, or sexual orientation and identity. The Group promotes a corporate culture that forbids any type of sexual violence or abuse of power. For years, we have taken up a clear position against such behavior with our Code of Conduct. For example, all employees are encouraged to report discrimination or violations of other principles set out in the Code of Conduct to the Company’s Compliance Officers. In addition, we provide the workforce all over Germany with mandatory training on the General Act on Equal Treatment (AGG). Via the private media association VAUNET, we participate in the Themis advice center against sexual harassment and violence, which provides assistance for those affected in the film, television and theater industry. The „15 Minutes" format is also exemplary for socio-politically relevant content on the ProSiebenSat.1 Group stations and a central element in ProSiebenSat.1's efforts to raise viewers' awareness of such aspects. With #Männerwelten and #AShortStoryofMoria, we succeeded in 2020 in using our reach as a media company with special responsibility.
ProSiebenSat.1 Group has laid down basic guidelines and policies in its Code of Conduct. These guidelines define the general standards for conduct in business, legal and ethical matters and also govern how employees can report misconduct in the Company. They serve as a binding reference and regulatory framework for all members of the Executive Board, the management, and the employees of ProSiebenSat.1 Group in dealing with both each other and with business partners, customers, suppliers, and other third parties.
Another central compliance instrument for ProSiebenSat.1 Group is the whistleblower system. In addition to internal reporting channels, it is also possible to report legal violations anonymously via an external Ombuds Office.
In the digital world, more and more personal data is being generated by new business models and processed in a wide variety of ways. This also applies to ProSiebenSat.1 Group with its wide variety of entertainment services and commerce companies in its portfolio. In this context, data protection protects the right to privacy and to information control. Our goal is to handle personal data carefully and protect it from misuse.
Performance of an initial risk analysis including a compliance check in the context of introducing/changing automated procedures for processing personal data in order to meet the requirements of data protection law (Articles 5, 6 GDPR).
Process for legally compliant preparation of agreements under data protection law in order to meet the requirements of Articles 26, 28 GDPR.
Process for legally compliant disclosure of personal data to public authorities.
Legally compliant information and processing of data subjects’ requests for the fulfillment of articles:
- Transparent information (Articles 12 et seq. GDPR)
- Rights of access (Article 15 GDPR)
- Right to rectification and erasure (Article 16 GDPR)
- Right to erasure (Article 17 GDPR)
- Data portability (Article 20 GDPR)
- Rights to object (Article 21 GDPR)
Process for legally compliant reporting of data breaches (= third parties unlawfully obtaining personal data) in accordance with Articles 33, 34 GDPR.
Provisions for the protection of youth are also covered by the CMS in the context of media regulation. A key role is given to the youth protection officers at ProSiebenSat.1 Group, who are tasked with making sure that all TV and online content for which the Group is responsible is offered in an age-appropriate way. The goal is to make it difficult for children and underaged people to gain access to content that is unsuitable for their age group.
Dialogue with employees, customers and business partners is important to us and, along with the Code of Conduct, an important component of our compliance management system. If you have questions, you can contact the following referent person:
Moritz von Merveldt
Chief Compliance Officer
compliance@prosiebensat1.com
If you would like to make a note, you can contact the following persons:
Hogan Lovells International LLP
Karl-Scharnagl-Ring 5
80539 München
You can submit your report in different ways (by phone or by e-mail via the contact details given above). Below you will find the most important information about the processing of your personal data in connection with your report. You can find more detailed informationhere.
If you submit a report, your information will be collected and processed by the law firm, Hogan Lovells LLP (hereinafter referred to as Hogan Lovells; for further information go to: www.hoganlovells.com), to the extent necessary for the processing of your report and the resolution and legal examination of the facts. The data processing is undertaken solely for the stated purposes. If necessary in this context, the data will also be forwarded to ProSiebenSat.1 or, if your report has international reference, to Hogan Lovells' overseas offices.
However, you are not required to provide your name or identity when reporting, and can remain anonymous. In this case, no personal data relating to you will be collected and processed. However, in some cases it makes sense to mention your name, your role in the company and/or your relationship with ProSiebenSat.1, as this often facilitates resolution and allows for successful inquiries.
For external whistleblowers: If you do not submit your report anonymously, your consent is required for the processing of your personal data. If you include your personal data when submitting your report to the email address given above, you also consent to your data being processed by Hogan Lovells LLP as described above and here. You can revoke your consent with future effect at any time and without giving a reason, by sending an informal message to the email address given above.
Please note that questions or complaints concerning our TV program or websites should not be raised with the whistleblower office, but with the respective broadcaster – unless these questions or complaints concern matters of criminal law, such as hate crimes, display of anti-constitutional symbols or similar.
