In addition to the prevention of corruption, the Group’s compliance management system organizationally encompasses the avoidance of antitrust violations as well as adherence to the data protection processes and media law requirements of the German Interstate Broadcasting Treaty (Rundfunkstaatsvertrag). The major aim is to anchor integrity and lawful conduct in the thoughts and actions of all employees on a lasting basis and hereby prevent violations of laws and regulations from the outset.
In 2019, as in the previous year, no investigations became known against the Group, its subsidiaries or employees of ProSiebenSat.1 Group with regard to antitrust violations. No fines or financial penalties were imposed.
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. 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, for example. 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 Group has laid down basic guidelines and policies in its Code of Conduct. The stipulations therein define the general standards for conduct in business, legal and ethical matters. They serve as a binding reference and regulatory framework for all members of the Executive Board, the management, and the employees of the Group for dealing with each other and with external stakeholders. Another central compliance instrument for ProSiebenSat.1 Group is the whistleblower system, which comprises internal and external reporting channels
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
If you would like to make a note, you can contact the following persons:
Hogan Lovells International LLP
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 information here.
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.