Foreword by the Executive Board of Bauer Media Group

“Trusting that we are upholding the highest standards is a fundamental part of the strong, successful relationships we have developed over time with our customers, suppliers, partners and each other. And it’s the foundation on which our corporate reputation is built. Misconduct by just one of us can overshadow the hard work of thousands. Our commitment to impeccable conduct is more important than ever. As a transnationally active media group, Bauer Media Group acknowledges its responsibility to respect human rights and to protect the environment and is committed to meeting this responsibility. In accordance with the United Nations Guiding Principles on Business and Human Rights and pursuant to Section 6 (2) LKSG, we express this commitment in this policy statement.”

Bauer Media Group is an international media company operating in the European Economic Area (“EEA”) and United Kingdom (“UK”) with business areas in publishing and commercial radio and Online Comparison Platforms.

Bauer Media Group sets high ethical standards for all of its business activities. We believe that all people in the world should be treated with dignity, fairness and respect. We are seriously committed to the health and safety of our employees. Bauer Media Group has zero tolerance to slavery and human trafficking and condemns any degrading treatment of individuals or unsafe working conditions and opposes child and forced labor. We value fair working conditions and are committed to complying with applicable health and safety regulations. We support diversity and equal opportunities and respect the legal rights of employee representatives.

Therefore, we are committed to respecting the following international standard:

• the UN Guiding Principles on Business and Human Rights.
• the United Nations Sustainable Development Goals or the UN Global Compact
• the ILO Core Labour Standards

We request compliance with human rights from all our employees as well as from external partners and suppliers, who are obliged to comply with our guidelines.

Bauer Media Group appointed a person responsible for the LkSG risk management. This person is responsible for the ongoing monitoring of the risk management system set up to ensure compliance with the due diligence obligations as defined by the LkSG.

Risk analysis

The Compliance Team of Bauer Media Group supported the operating units in conducting an initial risk analysis as part of the implementation of the LKSG. It should be noted that most of Bauer Media Group's business areas are non-manufacturing businesses and that most of the suppliers are service providers that operate from the EEA and the UK and do not present any significant relevant risks. Workshops and interviews to implement the risk analysis were conducted at Publishing Business Area and will be continued at Audio Business Area in 2024.

In the producing part of the business area publishing, we prioritised the topics of paper and printing inks as well as supplementary chemicals, water consumption, air pollution and waste disposal. We analysed the working conditions, the health and safety in the workplace and environmental impact of our activities. In our own business area, we conducted interviews and reviewed documents. In our supply chain, we first checked whether we work with suppliers from high-risk countries. In the next step, we reviewed those and suppliers from the paper and printing sectors and obtained an overview of whether they have meaningful certifications and compliance standards, in particular in the area of human rights and checked the plausibility of the results by further interviews and background checks.

The risk analyses are to be repeated annually in future. The relevant decision makers, in particular those from the operations, HR managers, the health and safety managers and the central and decentralised procurement organisations will be interviewed in a structured manner and the results documented. In addition, supplier inventories will be reviewed according to geographic origin and type of business activity and divided into risk groups. In the case of higher potential risks, suppliers will be subject to a background check. In future, all suppliers will be subject to initial and then regular due diligence using a supplier questionnaire.

If risks or violations are identified as part of the analysis or on an ad hoc basis, we will immediately take suitable and appropriate preventive or remedial measures.

Bauer Media Group has introduced a Code of Conduct for employees in which the company's human rights and environmental expectations of employees are defined. Every employee is first trained on the Code of Conduct and then contractually obliged to comply with the requirements of the Code of Conduct.

The Bauer Media Group's Code of Conduct for Suppliers (downloads EN; GER; PL) communicates the human rights and environmental expectations of the Bauer Media Group to its suppliers. Every supplier is obliged to sign this Code of Conduct and to adhere to its requirements. The Bauer Media Group reserves the right to agree on appropriate contractual control mechanisms with its suppliers and their risk-based implementation.

Since the second half of 2023, we have started to introduce a new onboarding process for suppliers. We request Suppliers to sign a Code of Conduct and to explain via a self-assessment how they respect human rights and protect the environment.

Bauer Media Group has set up a complaints mechanism with the whistleblowing tool Speak Up, which can be accessed via every Bauer Media Group website in the respective local language and by means of a QR code and which enables every employee and employees in the supply chain as well as third parties to report human rights and environmental risks and violations.

Rules of procedure

Bauer Media Group's Speak Up Policy explains the complaints procedure and the procedures within the reporting process in the respective local languages. Corresponding reports received via the whistleblower tool are managed by the Group Compliance team while maintaining the confidentiality of the whistleblower's identity and guaranteeing data protection. Whistleblowers do not have to fear any disadvantages. We will take all well-founded reports as an opportunity to review existing processes and measures for their effectiveness and to improve them if necessary.

The Bauer Media Group reports annually on the implementation and further development of its due diligence obligations here on its website www.bauermedia.com.

This policy statement is published on the internet and intranet.

Documentation

The fulfilment of due diligence obligations is continuously documented internally by the Bauer Media Group.

Entry into force and adjustment

This policy statement was put into effect by the Executive Board of the Bauer Media Group on December 21, 2023 and published and shared both externally on the Internet at www.Bauermedia.com and www.Bauermedia.de and internally on Bauer Media Group’s intranet.