UN Global Compact principles: I, III, VI

Every day, 145,000 employees in about 50 countries work to ensure Bertelsmann’s business success, growth, and continuous development. This is the reason why, for generations, the company has made responsibility toward its employees a priority. Bertelsmann strives to create a working environment that is based on participation and partnership for all employees.

To be an attractive employer for a diverse workforce, retain employees long-term, and remain competitive, Bertelsmann promotes the development of its employees, and creates the prerequisites for enabling both fair working conditions and a safe and healthy working environment. In particular, these include freedom, trust, and respect. Bertelsmann aspires to this all over the world, honoring widely varying social, economic, regulatory, and cultural conditions in the process.

In addition, employees of all generations increasingly attach particular importance to meaning in the work they perform for their employer. To attract future employees, employers are expected to have and convey a greater sense of purpose. Only if employees are able to identify with their company, its values, and strategic objectives, they are able to actively implement and ensure that these objectives are achieved. This applies particularly in times of change.

Bertelsmann strives to offer its employees fair framework conditions for their work. In addition to the protection of human and personal rights, partnership and trustworthy cooperation with employees and their representatives, workplace safety, fair distribution of benefits, flexible working arrangements, and fair treatment of freelancers and external service providers are among the key aspects of ensuring fair working conditions.

Motivated employees are the most important asset for Bertelsmann’s business success and are essential to creativity and entrepreneurship. This corporate identity – anchored in the corporate constitution and the Bertelsmann Essentials – is the basis for the Executive Board Guidelines on HR work. Supplementary regulations are specified in the Bertelsmann Code of Conduct, which is binding for all employees (see GRI 102-16  ).

The Chief Human Resources Officer (CHRO) is responsible for employee matters across the Group. The CHRO heads the corporate HR department, which supports the coordination of tasks and development of relevant HR policy and cooperates closely with the HR directors of the corporate divisions. The main focus of his work includes setting the strategic HR agenda, aligning management and talent development with the Group’s strategic growth priorities, the re- and upskilling and learning activities at Bertelsmann University, ensuring the standardization and IT support for HR processes, and further developing Corporate Responsibility (CR) and the corporate culture.

To ensure stringent procedures in a decentralized organization, Bertelsmann’s HR function is organized according to a “dotted-line” concept, with complementary reporting as well as supervisory relationships. This allows Group-wide HR topics to be implemented in accordance with the Executive Board’s decisions.

Another important aspect of Bertelsmann’s HR work is the exchange of information in committees:

• The HR Committee determines the basic aspects of HR work in the interest of the whole Group. Its members are the heads of HR at the corporate divisions, who report to the CHRO and senior executives from the Group’s corporate HR department.

• HR Country Coordination Meetings are designed for cross-divisional coordination within a region and ensure the implementation of Group-wide HR initiatives. Its members include the heads of HR of the Group’s largest companies or those with the largest number of employees in the country concerned.

• The Nomination & Compensation Committees of the corporate divisions and Corporate Center decide on the implementation of remuneration and staffing policies in their areas of responsibility.

Responsibility for ensuring fair working conditions is decentralized, meaning it lies with the management of the local businesses. Bertelsmann provides Group-wide framework conditions that enable local businesses to fulfill this responsibility. Collective regulations (e.g., Group company agreements) and Executive Board Guidelines on certain topics, such as remuneration and the use of external employees, are also relevant in this regard. In addition, various formats e.g., the Bertelsmann Group Dialog Conference in Germany and an international, cross-divisional working group deal with topics such as a culture of partnership and fair working conditions. As the key contact person for the various bodies representing employee interests, Bertelsmann’s CHRO accompanies or presides over these formats.

Bertelsmann is also subject to international conventions on the protection of human rights and fair working conditions, such as the UN Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN “Free & Equal” Standards, the ILO Core Labor Standards, the OECD Guidelines for Multinational Enterprises, and Bertelsmann’s voluntary commitment in accordance with the UN Global Compact (see GRI 102-12  ).

At Bertelsmann, remuneration issues are an integral part of fair working conditions. The compensation system is designed to ensure that remuneration is driven by market, function, and performance, taking into account business-specific characteristics. Numerous domestic and foreign subsidiaries have operational/divisional success and profit-sharing models adapted to local requirements. In 2021, a total of €88 million was distributed as part of such participation schemes globally.

Participation in decision-making processes and the granting of the greatest possible freedom contribute to employee loyalty and satisfaction. To support a healthy work-life balance, this also includes offering employees flexible arrangements about where and when they work. Working-time models that focus on results rather than physical presence have become widespread, partly also because of the coronavirus crisis. In 2021, Bertelsmann developed and communicated a Group-wide basic approach to New Work and set up a cross-divisional exchange format.

The flexibility requirements of a rapidly changing world of work also mean that knowledge and expertise need to be sourced from outside the company to ensure satisfied customers during peak phases. The company relies on staffing agencies and employs external personnel in addition to permanent employees where the specifics of the tasks allow and require this. Bertelsmann defines external personnel as persons who work for the company as self-employed, for service providers, consultancies, or as temporary agency staff for a Group company. The employment of external personnel must be in accordance with the company’s values. The Executive Board Guideline on the Engagement of External Personnel requires standard processes to ensure compliance with legal requirements. This is supplemented by the Supplier Code of Conduct, which is also binding for service providers (see GRI 102-16  ).

In 2021, the company defined strategic objectives relating to fair working conditions and developed measures from those, as part of the Bertelsmann CR Program (2021–2023). These include the further development of a Group-wide management approach to fair working conditions and respecting human rights, the further development of processes for identifying risks concerning human rights issues, and the continuous advancement of knowledge on these topics.

UN Global Compact principle: III

Bertelsmann sees the continuous dialog between employee representatives and company management as a key element in its company culture. Additionally, regular dialog with employees and their representatives makes it possible to continually review working conditions, identify possible improvements, and derive measures. Digital transformation is changing the work environment and every individual’s tasks. At Bertelsmann, this process also includes the restructuring of several traditional businesses. Parallel to this, some parts of the company are being dismantled while others are reorganized, expanded, or newly built. The management sees change as both a challenge and an opportunity and seeks to shape change together with its employees.

Although Bertelsmann, as a media company, is free to determine its political direction as defined in the German Works Constitutions Act (“Tendenzschutz”) and therefore is not subject to statutory co-determination in the Supervisory Board, the company nevertheless makes four positions on the Supervisory Board of Bertelsmann SE & Co. KGaA available to employees on a voluntary basis. Three of them are occupied by leading Works Council members of German Group companies. Since June 1, 2021, Núria Cabutí, Chief Executive Officer of Penguin Random House Grupo Editorial, has been a member of the Supervisory Board in her capacity as Chair of the international Bertelsmann Management Representative Committee. In addition, managers, general workforce, employees with disabilities, and trainees all have platforms for exchanging ideas, advancing topics, and voicing their concerns. A proven format is the Bertelsmann Group Dialog Conference where the Chief Executive Officer, Chief Human Resources Officer, and members of the Works Councils from the corporate divisions in Germany meet for consultation and discussion. In 2021, this led to intensive collaboration and cross-divisional exchange beyond the scope of the committees required by law, e.g., to analyze measures from the Employee Survey and to address the impact of the coronavirus pandemic on the framework conditions for cooperation. In addition, a Group Inclusion Agreement was concluded for the first time for all operations of Bertelsmann SE & Co. KGaA and its Group companies in Germany. In German Bertelsmann companies, it improves the participation of people with disabilities alongside the implementation of the Bertelsmann Action Plan for Inclusion (2019–2024)  .

Employees are also involved in the development and improvement of working conditions through standardized HR tools (Performance and Development Dialogs, Agreements on Objectives, and Team Talks), and through Bertelsmann’s international Employee Survey. The Employee Survey has been a key element of Bertelsmann’s corporate culture since 1977 and was carried out in 2021 as scheduled. An improvement in the survey results was achieved for all questions at Group level.

UN Global Compact principle: I

Bertelsmann aims to create a health-promoting working environment and conditions for avoiding occupational health risks. The Corporate Responsibility (CR) department is responsible for developing and implementing the Group-wide Health & Well-being strategy. Jointly with an international, cross-divisional working group established in 2021, it defines the strategic framework for health-related topics.

In Germany, employees from the Health and Human Resources (HR) departments, Works Councils members and Representatives of Employees with Disabilities work together in a “Health Community,” e.g., on the further development of minimum health standards. At the sites of the corporate divisions, contact persons for health drive forward their implementation. In addition, there is an Operational Integration Management (“Betriebliches Eingliederungsmanagement,” BEM), which is supported by local integration teams.

In 2021, Health & Well-being was confirmed as a Group-wide CR priority, defined as a Group-wide focus of the Chief Human Resources Officer and further developed as part of the Bertelsmann CR Program (2021–2023). In addition to the strategic and organizational further development of the Health & Well-being topic and the management of the coronavirus crisis, two other relevant fields were defined. These include the empowerment of executives to create a healthy and safe working environment and corporate culture; and the support of employees to adopt healthy working habits and lifestyle, with measures also being taken to enhance individual resilience. On the level of measures, the focus in 2021 was initially on strategic and organizational anchoring.

Due to the ongoing coronavirus pandemic, the immediate health protection of all employees worldwide remained critical in 2021. Emphasis of infection control was placed on the vaccination against the coronavirus, the development of the necessary infrastructure in the corporate divisions, and other prevention and protection measures (see GRI 403-3  ).

UN Global Compact principle: I

At Bertelsmann, responsibility for implementing occupational health and safety, and thus also for corresponding management systems, is decentralized to the divisions. For the most part, corporate divisions already have cross-site occupational health and safety management systems which are guided by common occupational health and safety standards, e.g., the Occupational Health and Safety Standards (ISO45001), and take into account the relevant statutory occupational health and safety requirements. In some cases, occupational health and safety is integrated into the company’s Health, Safety, Security & Environment (HSSE) organization.

In Germany, the Bertelsmann Occupational Safety team in the Bertelsmann Real Estate & Services department at the Corporate Center supports about 15,000 employees of Arvato, Bertelsmann Accounting Services, and Bertelsmann Corporate. The Group's own Company Medical Services (see GRI 403-3  ) are responsible for about 14,000 employees in the Gütersloh region and at other Bertelsmann sites in Germany. The Bertelsmann Occupational Safety team and the Company Medical Services advise numerous other German Bertelsmann companies on occupational health and safety obligations and standards set out in the German Occupational Safety Act (“Arbeitssicherheitsgesetz”).

The company’s internal IT platforms are used to map structures and data required under German occupational health and safety law on a daily basis and in compliance with data protection requirements, e.g., the number and training status of safety officers, documentation of recurring instructions, monitoring of training and appointment of company emergency responders, and company-relevant preventive medical check-ups. For this purpose, employees with various occupational health and safety tasks, e.g., occupational safety specialists, safety officers, and contact persons for accidents, health, and risk assessment, are involved at all associated companies.

UN Global Compact principle: I

At Bertelsmann, responsibility for hazard identification, risk assessment, and incident investigation is decentralized to the corporate divisions. Internationally, occupational health and safety risk assessments are conducted at individual Bertelsmann companies. For this purpose, internal checklists and validated questionnaires are used. In some cases, site inspections are carried out for additional identification of existing hazard potentials as well as further measurements of noise, brightness, and climate.

In Germany, the findings as well as any workplace accidents, are discussed at Occupational Safety Committee meetings. Several German companies have established processes (reporting system) for dealing with incidents and near-accidents. In addition, a legally mandated mental health risk assessment is implemented.

In 2021, for early hazard identification of psychosocial issues, workshops with health working groups were held at the divisional level in Germany based on health-related results of the Employee Survey. Communication materials on health-related action fields were made available throughout the Group.

UN Global Compact principle: I

In Germany, the deployment of company physicians, including their qualifications and tasks, is prescribed by law and by the regulations of professional associations (“Berufsgenossenschaften”). In addition to its own Company Medical Services, Bertelsmann works with external company physicians at the respective sites to ensure that these requirements are met (see GRI 403-1  ). In order to ensure a similar range of services at all sites, external company physicians are guided by the portfolio of Bertelsmann’s own Company Medical Services in Gütersloh. The range of services offered by the company physicians and their communication materials are displayed on the company’s internal intranet.

In 2021, the Group-wide focus was on the immediate health protection of all employees and the provision of a vaccination offer, subject to the respective regional legal regulations (see GRI 403 Management approach  ). Bertelsmann’s Company Medical Services played a pivotal, advisory role in Germany. The Company Physician was a permanent member of the central Crisis Task Force and of local crisis teams. All employees in Germany received a vaccination offer through the Company Medical Services or regional company physicians. Vaccination centers for employees and their families were also established in the Gütersloh region and in Cologne.

At the German sites, the local crisis teams implemented hygiene and protection measures, such as working from home or providing masks, disinfectants, and coronavirus-testing facilities. In cooperation between the local crisis teams and health working groups, a wide range of support services were provided to maintain mental and physical health and were accompanied by extensive internal communication activities.

UN Global Compact principle: I

At Bertelsmann, responsibility for employee participation, consultation, and communication on occupational health and safety is decentralized to the corporate divisions. At individual Bertelsmann companies, health and occupational safety committees have already been established and meet regularly, e.g., to analyze relevant topics and develop targeted measures.

In Germany, Occupational Safety Committee meetings are required by law, are organized quarterly, and carried out locally. Participants include the employer or a management representative appointed by the employer, members appointed by the Works Council, the Company Physician, the Occupational Safety Specialist, the Safety Officer, and the Representative for Employees with Disabilities. Responsibility for all decisions and measures taken lies with the management of each company. The Company Physician, the Occupational Safety Specialist, and the Safety Officer are involved as advisors without the right to issue instructions. The representatives of the Works Council exercise a supervisory function in the interests of the employees.

UN Global Compact principle: I

Occupational health and safety trainings for employees and the organization of other relevant measures are carried out independently by the Bertelsmann corporate divisions. Depending on the function, activity, and degree of hazard, such trainings are conducted online and/or (moderated) in person and are documented.

UN Global Compact principle: I

Bertelsmann’s corporate divisions provide their employees with numerous offerings to support mental and physical health and preventive healthcare. In 2021, a large proportion of the health support offerings was provided in a digital format to ensure participation of employees working from home. The focus was in particular on mental health and corresponding digital and in-person support services, e.g., on the topics of resilience, relaxation, mindfulness, mental health first aid, and family support during the coronavirus pandemic. In this context, the Company Social Counseling Service (Germany) and the Employee Assistance Program (international) were continuously promoted. In addition, digital fitness and exercise offerings were used to encourage more physical activity in the daily work routine. The offerings are presented in the company’s internal intranets.

In addition, other health-related projects were implemented at the divisional level in Germany, such as the “Digital Moving Break” offering, the “Fit for Work” campaign, training courses on health-oriented leadership, ergonomics in the home office, and health days. Here, the Bertelsmann Company Health Insurance provides health-related offerings tailored to the work situation, such as the “Phileo” app for supporting mental health or the “Running Coach,” which the Bertelsmann corporate divisions have access to.

UN Global Compact principle: I

Product safety for customers is anchored in the Bertelsmann Code of Conduct (see GRI 102-16  ): “Our products must not contain defects or unsafe features that could have adverse effects on health or property” (see GRI 417  ).

If external parties work for the company, their assignment and employment must be in accordance with the corporate values of Bertelsmann (see GRI 401  ). In the case of cooperation with external companies, the implementation of safety briefings is ensured subject to the situation concerned. In several German companies, external company coordinators are already employed. They accompany and monitor the activities of external companies, e.g., cleaning services of buildings, repair companies, maintenance companies, or inspection organizations.

UN Global Compact principle: I

Due to the decentralized organizational occupational health and safety structures, this data is not yet centrally available in a systematic manner at Bertelsmann (see GRI 403-1  ).

UN Global Compact principle: I

Due to the decentralized organizational occupational health and safety structures, this data is not yet centrally available in a systematic manner at Bertelsmann.

UN Global Compact principle: I

For Bertelsmann, training and education are a long-term investment in the company’s future and in the stability of society. In order to be successful and attractive as a company, it is crucial to continuously train employees in success-critical skills and competencies. Major changes, such as the digital transformation of media, services, and education, the demographic shift, or repercussions of the coronavirus pandemic, can only be tackled with qualified and motivated employees.

Bertelsmann thus aims to empower employees at all levels to adapt to the challenges of a quickly changing environment and to continuously learn from and with one another. This is reflected, among other things, in the fact that the topic of learning (“upskilling”) was highlighted as an important enabler in Bertelsmann’s new strategy framework. Great importance is also attached to an open learning culture that embraces experimentation as an element of creativity in the Bertelsmann Essentials.

In 2021, the company defined strategic objectives relating to learning as part of the Bertelsmann CR Program (2021–2023). These include developing a re- and upskilling approach, empowering and networking managers to facilitate the future-oriented design of the Bertelsmann transformation, expanding the offerings on business-critical competencies for all employees (e.g., tech & data), and promoting a learning culture.

With regard to measures, a target-actual analysis of tech & data roles was carried out in 2021 to identify qualification gaps. In addition, the company launched the digital program series “Be-Ready” for top executives with a focus on “Strategy in the Transformation.” The three-year Udacity technology scholarship program was continued for the third year, providing 50,000 scholarships for which both Bertelsmann employees and external candidates are eligible to apply. A new tech & data offering was also added to the Group-wide digital peer-to-peer learning format “Your Campus.”

Bertelsmann University

This central learning organization systematically addresses three target groups with its international offering. For top executives and talents across the Bertelsmann Group, it offers programs on strategy and leadership; for creative experts programs on creativity and innovation; and for all employees programs on tech & data. The central focus areas for learning are supplemented by division-specific training initiatives. Employees worldwide are thereby given access to central and division-specific training courses and to more than 15,000 freely accessible online courses by LinkedIn Learning and almost 2,000 online courses by CreativeLive. Thanks to these digital formats, learning content is flexibly available to employees and executives. Time and place of learning is geared to individual needs and organizational requirements.

Bertelsmann University is a main department at the Bertelsmann Corporate Center. It is led by the Chief Learning Officer, who is responsible for the Group’s learning strategy and reports to the Chief Human Resources Officer. The Executive Board, Group Management Committee (GMC), and Human Resources (HR) Committee regularly discuss and review Bertelsmann University’s orientation and activities. It is supported by the Divisional Learning Committee, in which Learning & Development representatives from the corporate divisions coordinate, exchange, and collaborate with each other.

Training in Germany

In Germany, Bertelsmann offers young people industrial and commercial training options in more than 40 different disciplines. In addition to traditional apprenticeship programs, this spectrum also includes a variety of dual-study programs. With its offering, Bertelsmann is one of Germany’s largest apprentice-training companies and a protagonist in shaping the vocational training landscape. Bertelsmann is also involved in regional and national working groups and committees to address education policy issues and drive forward important developments. Among the major challenges to be overcome is the future-proofing of training programs to prevail in the intensified competition for highly qualified junior employees and enable young people in Germany to get off to a good start in their professions.

The corporate Education department is responsible for training measures at the Gütersloh site. It develops offerings based on the company’s changing needs and requirements and ensures that they reflect the company’s values of creativity and entrepreneurship. The department works closely with the executives and HR managers of the training companies as well as the Works Council. In Gütersloh alone, more than 630 young people are currently learning a profession or completing a part-time Bachelor of Arts or Bachelor of Science degree. Of these, about 200 students are undergoing industrial and commercial training at the Group’s own vocational college. Bertelsmann also cooperates with universities to offer part-time master’s degree programs in IT Management and Business Consulting & Digital Management. The introduction of another master’s degree program in Data Science is in planning. In 2021, Bertelsmann’s corporate Education and the cooperating departments were once again recognized for their high quality by the independent Institute of Research & Data Aggregation – they are among the “top 1% of German apprentice-training companies.”

UN Global Compact principle: I

Total training

in hours

2021	2020
305,334	353,363

Basis: all training data entered on the digital HR platform “peoplenet”

Share of digital training hours

in percent

2021	2020
91	53

Basis: all training data entered on the digital HR platform “peoplenet”

The absolute number of training hours decreased in 2021 compared to 2020. During the coronavirus pandemic, the share of digital training hours soared from 53 to 91 percent, following an increase in the previous year.

Bertelsmann does not currently report training hours broken down by gender and other employee categories, since this information is not available centrally. Bertelsmann continues to develop its data collection in this respect and aims to report these figures in the medium term.

UN Global Compact principles: I, VI

A holistic approach to managing Diversity, Equity & Inclusion (DEI) not only serves to increase diversity in the workforce, but also promotes a culture of appreciating diversity and authenticity. In combination with a constant, ongoing review and adaptation of structures and processes, all employees shall be able to reach their full potential. This creates the framework conditions for diversity of perspectives – based on diverse competencies, backgrounds, and experiences – to have a positive impact on corporate decision-making processes.

Managing DEI is a prerequisite for diversity of perspectives and social representation. This provides the framework on which media, products, and services can be developed successfully and in line with target groups in the long term. In addition, the importance of DEI for the business success is reflected in the steadily increasing requirements from legislators and business partners. DEI contributes also to strengthening the attractiveness of the company as an employer.

For Bertelsmann, diversity and differences in the workforce are prerequisites for creativity, innovation, and the company’s long-term business success. This conviction is conveyed in the Bertelsmann Essentials and in the Executive Board’s DEI Policy  , which was adopted in 2021. In this policy, the Bertelsmann Executive Board reaffirms its intention to further increase the diversity of staff at all levels and in every respect and to create appropriate framework conditions that foster the appreciation and involvement of employees and ensure equal opportunities. A culture of respect and belonging, in which employees are valued for their diverse backgrounds, perspectives, and talents, makes Bertelsmann a more open-minded company. The Bertelsmann Code of Conduct also mandates a respectful and appreciative treatment of all employees (see GRI 102-16  ). The Executive Board Guideline on Principles of Hiring Policy also provides orientation in addressing diversity.

The Executive Board bears the strategic responsibility for DEI within the Group. The DEI strategy is implemented by the Corporate Responsibility (CR) department, which is responsible for DEI, with support from a Group-wide and other working groups in the corporate divisions. In addition, executives, human resources and communications managers in particular are responsible for visibly living and implementing DEI in practice through their role model function. The focus in 2021 was on the following dimensions: gender, disability, sexual orientation, and gender identity. In line with the Group’s decentralized structure, some of the corporate divisions also set – based on local conditions and business models – in part additional priorities. The Bertelsmann website provides an overview of the DEI measures at Bertelsmann and in the corporate divisions at www.bertelsmann.com/diversity  .

To further enhance diversity at the management levels, Bertelsmann had also set itself the target of raising the ratio of women in top management and senior management across all corporate divisions to one-third by the end of 2021. While the proportion of female executives in senior management was unchanged from the previous year, Bertelsmann did further increase the ratio in top management. That figure is now 30 percent in both target groups (see GRI 405-1  ). In addition, the targeted proportion of women in the talent pools was set at one-third for the top and senior management pools and 50 percent for the career development pool. These target figures were met in all three pool cohorts in 2021. The Bertelsmann Supervisory Board and the Executive Board are notified annually of progress in regard to these targets.

In 2021, the company defined strategic objectives relating to DEI as part of the Bertelsmann CR Program (2021–2023). These include the greater involvement of the Executive Board and top management into DEI engagement, the strategic further development of Diversity Management into Diversity, Equity & Inclusion Management, the professionalization of the governance structures for DEI in the corporate divisions, and awareness raising and competence development in relation to DEI. In this context, the Bertelsmann Executive Board’s DEI Policy was also communicated more intensively throughout the Group.

The Bertelsmann Action Plan for Inclusion (2019–2024)  aims to design processes and structures at German companies in such a way that employees with disabilities can work in a barrier-free environment and thus contribute to Bertelsmann’s business success to their full potential. It comprises 27 targets and 69 measures. The second evaluation of the implemented measures took place as scheduled after the second year; the results can be viewed on the Bertelsmann website: www.bertelsmann.com/disability-and-inclusion  . In addition, the first-ever Group Inclusion Agreement, covering all Bertelsmann SE & Co. KGaA operations and group companies in Germany, was concluded.

Bertelsmann’s LGBTIQ+ employee network “be.queer” continued its activities in 2021 and advanced international collaboration with the LGBITQ+ networks in the corporate divisions. In addition, a wide range of anti-racism measures were also implemented in the company, including Group-wide training offerings and measures to raise awareness.

Gender-neutral compensation

The equal treatment of women and men set out in the Code of Conduct explicitly applies to compensation as well. The compensation system is intended to ensure that remuneration is exclusively driven by the market, function, and performance – and is therefore gender-neutral. Insofar as explicit job, function, and position descriptions or position endowments exist, these are also defined in a gender-neutral manner. Women and men in comparable markets, in comparable positions, and delivering a comparable performance have equal earning opportunities.

UN Global Compact principles: I-II, VI

The Code of Conduct and the Supplier Code of Conduct (see GRI 102-16  ) contain a clear prohibition of discrimination and intimidation, which is also expressed in the Bertelsmann Diversity, Equity & Inclusion (DEI) Policy (see GRI 405  ). In addition to existing speak-up channels, AGG contact persons have been appointed at all German locations. Employees can contact them in the event of suspected violations of the German General Equal Treatment Act (“Allgemeines Gleichbehandlungsgesetz,” AGG). Employees are informed about their rights under the AGG by means of brochures, posters, and information provided on the company’s internal intranet. Throughout the Group, employees were sensitized to the issue of anti-discrimination in Code of Conduct trainings and made aware of their rights. These and other international activities are being continuously developed. In the United States, for example, the company has stepped up training to prevent sexual harassment and racism in the workplace.

UN Global Compact principles: I-III

The protection of human rights within the company and in the supply chains is a priority for Bertelsmann. Bertelsmann is committed to the Principles of the Universal Declaration of Human Rights, the Principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the UN “Free & Equal” Standards, the OECD Guidelines for Multinational Enterprises, and the ILO Core Labor Standards. Ensuring fair working conditions is an integral part of Bertelsmann’s corporate culture. Bertelsmann sets binding human rights standards in the company as well as in the global supply chains, which must be adhered to by all employees and business partners. Key corporate guidelines that address the issue of human rights and codify these standards are the Bertelsmann Code of Conduct, the Bertelsmann Supplier Code of Conduct, as well as the Executive Board Guideline on Anti-corruption & Integrity (see GRI 102-16  ).

The Code of Conduct and the Supplier Code of Conduct reaffirm the right to freedom of association and the right to engage in collective bargaining, in accordance with applicable laws and regulations, for all employees of Bertelsmann companies as well as those of business partners. At Bertelsmann, violations of this principle can be reported via the speak-up channels of Bertelsmann’s existing compliance management system, both by employees and by third parties (see GRI 102-17  ).

UN Global Compact principles: I-II, V

Bertelsmann does not tolerate child and forced labor and expects its business partners to share this position. The Code of Conduct and the Supplier Code of Conduct contain accordingly explicit prohibitions (see GRI 102-16  ). In addition, Bertelsmann and individual Group companies issued statements in accordance with the UK Modern Slavery Act  that condemn all forms of modern slavery, child and forced labor, exploitation, and discrimination, and present the measures taken to prevent these human rights violations.

UN Global Compact principles: I-II, IV

See GRI 408  .

UN Global Compact principles: I-II

Media report and entertain, clarify, show connections, and form the basis for freedom of information as well as formation and diversity of opinions in society. They are an integral and indispensable part of the democratic social order and thus systemically relevant. The company sees censorship and attempts of political influence in markets, in which Bertelsmann is internationally active, as a risk to its media businesses and resolute opposition to it as an opportunity. Bertelsmann is aware of the responsibility it has toward the public in its role as an opinion-shaper and handles this responsibility with care. With this in mind, the company sees the independence of its content a matter of course, including vis-à-vis its advertising business partners.

Creativity is one of Bertelsmann’s two core values. Free and critical thinking and the exchange of different opinions are essential to innovation and thus part of the company’s value system. With regard to its content businesses, Bertelsmann stands for editorial and journalistic independence as well as for freedom of the press and artistic license. The company publishes a wide variety of opinions and positions. These basic principles of the content businesses are also set forth in the Bertelsmann Code of Conduct (see GRI 102-16  ).

Bertelsmann aims to ensure this creative/journalistic independence in two directions. Inside the company, it means that the company management does not attempt to influence the decisions of artists, authors, editors, program managers, or any other content managers, or to restrict their freedom. To the outside, this means that both content managers and company management comply with existing laws regarding the separation of editorial content and commercial advertising and do not capitulate to political or economic influence in their coverage. In accordance with the Bertelsmann “Editor-in-Chief Principle,” editorial decisions are the sole responsibility of the content managers.

To discuss issues relating to press freedom and editorial and journalistic independence, share information, current challenges, and best practices, exchange takes place in a cross-divisional Bertelsmann working group of representatives of the corporate content divisions – RTL Group, Penguin Random House, Gruner + Jahr, and BMG. The editor-in-chief of RTL Group’s German news channel, ntv, chairs this working group.

In 2021, the company defined strategic objectives relating to creative/journalistic independence as part of the Bertelsmann CR Program (2021–2023). These include guaranteeing the safety and health of journalists, continuously developing high-quality news reporting output, and creating an environment that supports creative/journalistic independence and that reflects the diversity of perspectives and differences of people and their opinions, ideas, and stories.

Measures derived from this and already implemented in 2021 include a “Violence against Journalists” checklist, which was developed by RTL Deutschland. The list is intended to help minimize the risk of violence in the run-up to and during filming and to find the right contact person as needed. Under the title “JAhr zur Wahrheit. Weil’s stimmen muss” (roughly: “Y[ear of Y]es to truth. Because it has to be true”), the Bertelsmann Content Alliance companies in Germany advocated journalistic integrity, quality, and responsibility and campaigned against the manipulation of minds and conspiracy theories with a cross-divisional marketing campaign on the radio, on TV, and in print.

In addition, a variety of organizational measures were continued to safeguard editorial and artistic independence in the editorial and creative departments. The main focus here is compliance with the “Editor-in-Chief Principle,” duties of care, protection of personality rights, a clear separation of advertising and editorial content, and dealing with the representation of violence and the protection of minors. Such topics are also part of Bertelsmann’s in-house training for editors. Further examples of measures and projects in the corporate divisions can be found on the Bertelsmann Website  .

UN Global Compact principle: I

Bertelsmann sees itself as part of society. Responsibility is deeply rooted in its corporate culture and hence in the day-to-day action of the Group, its corporate divisions, and companies. The Bertelsmann Essentials, which focus on the values of creativity and entrepreneurship, form the basis for this. According to the Essentials, Bertelsmann is mindful of its impact on society and the environment and seeks to make a positive difference. This includes also contribution of the Group’s media, services, and education businesses and the expertise of its employees where help and support are needed outside the company.

As a media, services, and education company, Bertelsmann’s activities are interwoven with societal developments worldwide. Society and workforce expect the company to fulfill its responsibility as a corporate citizen beyond its own businesses. Bertelsmann’s social commitment, at the Group, divisional, and company level, encompass a wide range of measures and funding programs that involve and develop local communities. These efforts contribute to the business success by supporting the company’s license to operate; that is, enhancing Bertelsmann’s acceptance in the society.

Donations, sponsorship, funding for charitable projects, and memberships both at the Group and divisional level are an expression of responsible behavior and support Bertelsmann’s role as a good corporate citizen worldwide. Carefully planned and professionally executed measures boost the company’s reputation and anchor Bertelsmann as a responsible partner.

Bertelsmann seeks to contribute to the future-oriented development of its surroundings through donations, sponsorship, and funding for charitable projects, while at the same time safeguarding acceptance and a broad client base. The objective is to reach as many people as possible and to create a positive impact on society.

The Executive Board’s Guideline on Donations, Sponsorships, and Memberships ensures that funding measures in the form of donations, sponsorship, and memberships comply with legal and fiscal requirements and are consistent with the company’s strategy. In line with the principle of decentralization, the corporate divisions independently decide on their collaborations, funding for charitable projects, and donations, steered by the Executive Board Guideline and in coordination with Bertelsmann Corporate Communications. The Chairman and Chief Executive Officer decides on one-off donations and sponsorships exceeding €100,000 as well as regular commitments exceeding €50,000. All commitments must be reported annually to the Group Tax department, to ensure that the Executive Board can fulfill its related due diligence and compliance obligations. Group companies are also required to define and document their donation activities and sponsorship concepts and keep these documents for a period of five years. The general prerequisites of the Executive Board Guideline on Anti-corruption & Integrity are thus complied with. Any cases of doubt are to be coordinated and clarified with the Integrity & Compliance department.

Based on the Executive Board Guideline on Donations, Sponsorships, and Memberships, Bertelsmann’s focus areas for its corporate citizenship activities are as follows:

• Education: particularly for socially disadvantaged groups and media-related issues (e.g., reading promotion, media literacy);
• Culture: particularly the promotion of cultural heritage and young talent in fields closely associated with Bertelsmann (e.g., literature, TV, movies);
• Academic research: particularly on topics closely associated with Bertelsmann, such as economic and social sciences as well as media and communications science;
• Freedom of creativity and media: particularly freedom of expression and press freedom, protection of intellectual property, content responsibility, and editorial independence;
• Networking activities with relevant stakeholders.

Bertelsmann maintains an open dialog with stakeholders in politics, business, and civil society. Key objectives include respect for and protection of intellectual property, freedom and independence of the media, regulation of tech & data, and preservation of cultural and journalistic diversity.

Bertelsmann’s public affairs managers offer political decision-makers access to expert dialog partners within the Group, communicate the latest positions and facts, and provide helpful information. Joint positions are developed by in-house working groups and through association and other organizational memberships. In addition to functioning as a discussion forum and committee of experts, Bertelsmann’s liaison offices in Brussels and Berlin and the divisional public affairs managers introduce policymakers to the Group’s various business models in the fields of media, services, and education. Their activities include presenting Bertelsmann’s digital businesses and the international media group’s cultural activities. Bertelsmann SE & Co. KGaA is registered in the Transparency Register of the European Union and is a signatory to its Code of Conduct.

UN Global Compact principles: I,VIII

In their creation and distribution of products and services as well as in their advertising activities and marketing communications, all Bertelsmann companies comply with legal provisions and the highest quality standards as a matter of course. The Bertelsmann Code of Conduct (see GRI 102-16  ) codifies this as a binding principle. Responsibility for the protection of media users and customers as well as compliance with related requirements, standards, and commitments, rests with the management of the individual companies. Bertelsmann and its companies use a variety of principles and procedures for product labeling, reflecting the diversity of their own products and services. Relevant fields in which labeling is used in particular include the protection of minors (see MSD “Content creation and dissemination”  ) and environmental and climate protection (see GRI 300  ).

Product safety is a focus topic that plays a special role in the production of children’s books at Penguin Random House. The company adheres to the strictest safety standards in connection with the manufacturing of its books, toys, and related products to ensure that all Penguin Random House products are risk-assessed and safety-tested for things such as choking hazards or toxicity.

UN Global Compact principles: I-II

In the creation and distribution of its media, services, and education offerings, Bertelsmann uses customer data. In particular in the services business, many of the largest corporations worldwide entrust the company with parts of their value chain, e.g., the management of logistics processes or customer communications. Careful and confidential handling of personal data also plays a decisive role in contact with media users.

Protection of privacy is a fundamental human right. The objective of customer data protection is to protect people’s right to determine who has what knowledge about them, and when. This also means that personal information or information that could identify a person must be handled in accordance with legal requirements and adequately protected against unauthorized access and that data subjects are able to exercise their statutory data subject rights. There are various ways for data subjects to contact Bertelsmann, including via email inboxes set up specifically for this purpose. Bertelsmann attaches great importance to protecting customer data. This includes safeguarding the personal data of own company customers as well as personal data provided to Bertelsmann by its business partners regarding their customers. In addition to the legal requirements as well as the Bertelsmann Code of Conduct and Supplier Code of Conduct (see GRI 102-16  ), customer data protection within the company is governed by the Executive Board’s Information Technology and Information Security Policy, the Bertelsmann Cloud Policy, and for the German companies of the Bertelsmann Group by the Corporate Privacy Handbook as well.

Bertelsmann operates in a highly regulated environment as pertains to handling customer data. In all the core markets, in which Bertelsmann operates, the protection of customer data is required by law and compliance with it is also part of company’s self-commitment. European legislators in particular are enforcing further data protection regulations against the background of Economy 4.0 and stipulate heavy fines for serious violations within the EU General Data Protection Regulation (GDPR).

Responsibility for customer data protection is decentralized and rests with the management of the Group companies. To ensure compliance with data protection law governing customer data, subsidiaries use a Group-wide data protection management system that addresses in particular the implementation of the documentation and accountability obligations under GDPR. In addition, German subsidiaries have a data protection organization, consisting of central data protection officers and local data protection coordinators. The latter report to the local management as well as annually or upon request to the central data protection officers, who in turn report to the Executive Board annually or upon request. A similar organization exists at Group companies outside Germany. An Information Security Management System (ISMS) based on industry-standard ISO 27001 creates the technical and organizational framework for confidential data processing. The ISMS features a regular and structured survey of relevant processes and procedures to ensure compliance with statutory information security requirements, a systematic recording of risks, and the derivation and monitoring of related mitigation measures to minimize risk.

UN Global Compact principles: I-II

Media is an integral and indispensable part of the democratic social order – they are an economic and a cultural asset at the same time. Media report and entertain, clarify, show connections, and form the basis for freedom of information as well as formation and diversity of opinions in society. Bertelsmann takes the social responsibility that this implies seriously: for its business and journalistic activities as well as the creation and distribution of content and formats worldwide. In providing outsourcing, print, and education services, the company gives high priority to professionalism and customer focus, service quality, and the protection of personal information.

The Bertelsmann Essentials anchor creativity and entrepreneurship as important guiding principles in the creation and distribution of media and services. In addition, the Bertelsmann Code of Conduct (see GRI 102-16  ) specifies key principles for the responsible creation and distribution of media and services that are consistent and binding for all Bertelsmann companies. Compliance with legal requirements and the highest quality standards is a matter of course for Bertelsmann and is fundamental to the business success.

Content responsibility at Bertelsmann means reflecting on the repercussions of the content creation and distribution so as to protect the rights and interests of media users, customers, and third parties in the best possible way. Overriding principles and guidelines of media ethics are set by national and international laws governing the press, broadcasting, and multimedia. They are complemented by voluntary commitments to external guidelines, such as the ethics codes of national press councils, and within the company by the Bertelsmann Code of Conduct. Bertelsmann’s editorial and creative staff are committed to, among other things, “respecting privacy and to the responsible treatment of information, opinion, and images.” As a result, the company expects careful research, high-quality reporting, and transparency in case of errors – because thorough journalistic work is more important than ever in the face of online disinformation (“fake news”). Cross-divisional verification teams provide their expertise in discerning between authentic and manipulated photos and videos, or those taken out of context.

In addition, content responsibility is anchored in various ways in the corporate divisions, companies, and editorial departments. In accordance with the “Editor-in-Chief Principle” practiced at Bertelsmann, responsibility for the creation and distribution of media content lies solely with the content managers in the companies’ editorial teams and creative departments, who are free from influence from the Group’s owners or local management. The representation of social diversity as well as regulations to avoid discriminating or stereotyping content and “fake news” also play an important role.

In 2021, the company defined strategic objectives relating to content responsibility as part of the Bertelsmann CR Program (2021–2023). These include expanding coverage of socio-political topics, ensuring complete protection of minors in streaming services and digital offering, developing guidelines for publishing content, and a commitment to fairness and transparency in the music industry. In addition, cross-industry partnerships on social issues with artists were expanded.

On the level of measures, RTL launched its “Klima Update” (“Climate Update”) program, which examines the topic in all its various facets. In addition, the news channel “ntv” covered the UN Climate Change Conference with a series titled “Wie schaffen wir Klimawandel?” (“How can we manage climate change?”), with on-location reporting and an extensive schedule of special programs. The Gruner + Jahr magazine “Geo” is increasingly anchoring sustainability in its core business and is adapting operations and work processes accordingly. Among other topics, “Geo” covered all aspects of climate and species protection, as well as future technologies, in its “Nature and Sustainability” section and it also launched “Wer wird Visionär:in?” (“Who wants to be a visionary?”), a podcast casting show searching for Germany’s best sustainable ideas. Under the umbrella of the Bertelsmann Content Alliance and under the heading “Damit es auch morgen noch läuft” (“Making sure things will still work tomorrow”), RTL Deutschland, UFA, RTL Radio Deutschland, the Penguin Random House Verlagsgruppe, and Gruner + Jahr put the spotlight on water as a resource as part of the “Packen wir’s an” (“Let’s get to grips with it”) themed week launched in October 2021. Further examples of measures and projects in the corporate divisions can be found on the Bertelsmann Website  .

The company shoulders a special responsibility when creating and distributing content for children and adolescents, who experience their living environment as digital natives. The media policies and laws to protect minors from harmful media serve to examine media content to determine whether it could impair the development of children or adolescents. If such an effect is suspected, various restrictions come into force. The intent is to ensure that such media content is only accessible to age groups with the necessary maturity to put the possibly disturbing or unsettling content into context and process it appropriately. Bertelsmann gives high priority to the protection of children and adolescents in the creation and distribution of its creative content and complies with the relevant requirements. These include broadcast time restrictions as well as content and product labeling. The corporate divisions and companies go partly beyond existing regulations at the EU and national level, particularly in broadcasting (e.g., the Audio Visual Media Services Directive). In addition, Bertelsmann companies are continuously active in child and youth media protection organizations.