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.”

The Bauer Media Group is an international media company operating in the European Economic Area ("EEA") and the United Kingdom ("UK") in the fields of publishing and commercial radio.

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:

• United Nations Universal Declaration of Human Rights
• 10 principles of the Global Compact
• ILO Core Labour Standards

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

The Bauer Medien Group has appointed a person responsible for LkSG risk management. This person is responsible for the ongoing monitoring of the risk management system established to ensure compliance with the due diligence obligations as defined in the LkSG.

Risk analysis

The Bauer Media Group's compliance team supports the operating units in carrying out risk analyses. It should be noted that most of the Bauer Media Group's business areas are non-manufacturing businesses and that the majority of its suppliers are service providers operating in the European Economic Area (EEA) and the United Kingdom (UK) and do not present any significant relevant risks.

Risk analyses in the Publishing Business were carried out repeatedly in 2024. The Audio business conducted initial risk analyses. Selected print and paper suppliers were also analyzed in more detail in 2024.

We have taken further preventive measures in addition to general employee training on our values and expected behavior in parts of the Group.

We have developed a risk-based approach for the risk analyses of our supply chain that takes both country and industry risks into account.

The risk analyses are carried out annually. The relevant decision-makers from the operational business, particularly those responsible for HR and occupational health and safety, are surveyed in a structured manner and the results documented. In addition, suppliers are reviewed according to geographical origin and type of business activity and categorized into risk groups. In the event of higher potential risks, suppliers will in future be subjected to initial and then regular due diligence using a supplier questionnaire.

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.

Bauer Media Group's Code of Conduct for Suppliers (downloads EN; GER; PL) communicates Bauer Media Group's human rights and environmental expectations for suppliers . They are obliged on a risk-based basis to sign this Code of Conduct as part of the onboarding process and to adhere to its requirements. From 2025, the Code of Conduct will also be included in all new contracts with suppliers. New suppliers will be asked to describe their measures to respect human rights and protect the environment as part of a self-assessment. The Bauer Media Group reserves the right, among other things, to agree appropriate contractual control mechanisms with suppliers and to implement them on a risk-based basis.

As part of our partnership-based and responsible co-operation with our suppliers, we attach great importance to clear and transparent business relationships. The following General Terms and Conditions for Procurement (GTCP) form the basis for all deliveries and services between us, the Bauer Media Group, and our business partners.

Please take the time to read through the General Terms and Conditions carefully. If you have any questions, please reach out to our Procurement team.

Documents to download:

• Bauer Media Group General Terms and Conditions for Procurement (GTCP)
• Bauer Media Group Allgemeine Einkaufsbedingungen (AEBs)
• Bauer Media Group General Terms and Conditions for Procurement (GTCP) Poland (engl.)

Bauer Media Group has set up a complaints mechanism with the whistleblowing tool Speak Up, which can be accessed via any Bauer Media Group website, in the respective national language and by means of a QR code, and which enables all employees and workers in the supply chain and other 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 national languages. Corresponding reports received via the whistleblower tool are handled by the Group Compliance team while maintaining the confidentiality of the whistleblower's identity and ensuring data protection. Whistleblowers do not have to fear any disadvantages. We will take all substantiated reports as an opportunity to review the effectiveness of existing processes and measures and improve them where necessary.

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

Entry into force and adjustment

This policy statement was adapted by the Executive Board of the Bauer Media Group at April 1, 2025. It is published and shared externally on the internet at on www.Bauermedia.com and www.Bauermedia.de and internally on the intranet.