Responsible action requires attitude and thrives on continuity. For this, we have a framework of values we live as a Group. We have a social responsibility, and we take it very seriously – also through our commitment to take compliance seriously in our day-to-day business activities. We are committed to forming opinion and promoting democracy and use our coverage for socially relevant issues.
An effective compliance management system (CMS) is the foundation of good corporate governance. It sets the tone on how an organization operates and has an effect both internally and to the market generally.
A well-designed and well-implemented and therefore effective CMS will support ProSiebenSat.1 Group to demonstrate its commitment to comply with relevant laws and regulations not only vis-à-vis third parties, but also internally.
In addition to preventing corruption, our CMS particularly focuses on the prevention of money laundering and financing of terrorism, compliance with sanctions & embargoes, as well as legal provisions on data protection. Important tools for implementation are our code of conduct and whistleblower system.
The Compliance Committee and the Group Compliance department headed by the 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. There is a regular exchange between all members of the compliance organisation.
OurCode of Conduct provides us with orientation and a binding framework – both for our interpersonal relationships and for our business partners, customers, suppliers, and other third parties. The Code of Conduct is binding on all ProSiebenSat.1 Group employees worldwide. The Executive Board, managers and executives are responsible for actively exemplifying the Code of Conduct and setting an example.
For our business partners, customers, suppliers and other third parties, there is therefore a code ofconduct for business partners, which is based, among other things, on the Global Compact of the United Nations (UN), the Guidelines for Multinational Enterprises of the Organisation for Economic Co-operation and Development (OECD) and the labour and social standards of the International Labour Organization (ILO).
Another important component of the CMS besides the Code of Conduct is the whistleblower system. Our whistleblower system guarantees the highest possible protection for whistleblowers and affected persons. There are several points of contact to which our employees as well as external whistleblowers can turn if they have a suspicion of possible violations of the law and want to draw attention to them. We check every report and follow it up consistently. Investigations shall be conducted in the strictest confidence. All information is processed in a fair, fast and secure process.
The ProSiebenSat.1 Group expressly commits itself to the prohibition of discrimination against whistleblowers. Whistleblowers do not have to fear disadvantages or other negative consequences if a statement made by them in good faith turns out to be inaccurate.
We ask our employees and externals to report to us about possible violations of the law. Therefore, we would like to provide a variety of contact points and do not limit the nature of the legal violations to be reported. For reports of (possible) legal violations, the following are available: Group Compliance, the Unit Compliance Officer, the respective HR Business Partners and Legal Affairs. The first and most important point of contact for our employees is their direct supervisor. In addition, employees can of course contact the works council at any time.
Report hints – where and how?
The Group Compliance team led by our Chief Compliance Officer Dr. Anne Meckbach is always available for confidential discussions.
phone: + 49 89 95071715
via letter: ProSiebenSat.1 Media SE, Group Compliance, Medienallee 6, 85774 Unterföhring
via e-mail: email@example.com
External ombudsperson's office
Whistleblowers can contact the Ombudsperson Office at Hogan Lovells by phone, e-mail and letter. They are also available for a personal confidential conversation. All information, to the extent discussed with the whistleblowers, will be forwarded to Group Compliance for further processing. At the request of the whistleblower, the external ombudsperson ensures the anonymity of the whistleblower against ProSiebenSat.1 Group.
phone: +49 89 29012 498 (Mo until Fr 9-18 CET)
via letter: Hogan Lovells International LLP, Karl-Scharnagl-Ring 5, 80539 München
via e-mail: firstname.lastname@example.org
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.