Non-financial indicators

Societal indicators

Fair Business Practices

Definition of the policy’s priority axes

concerning the struggle against corruption

GRI

UNGC OECD Scope covered

G4-DMA SO

Corruption

aspect

II, VII

Canal+ Group

UMG (9 focus group countries)

GVT

The subsidiaries manage their own anti-corruption policies based on the

Compliance Program and on the United Nations Global Compact, of which

the group is a signatory.

Canal+ Group has formalized its commitments in an Ethics Charter and

devoted a training module to contractual risks. In June 2014, the Internal

Auditing department issued a memorandum for its employees on fraud

prevention.

All employees of the Canal+ Group Purchasing department, Legal

departments and Audit department are made aware of the fight against

corruption. The Canal+ Group Internal Audit department takes a three-

monthly inventory of fraud detected within the group, as well as the

associated plans of action. This information is fed back by operational

services following a group procedure to highlight fraud established by

the Canal+ Group Internal Audit department. This procedure is available

and published on Intranet with the option for employees to appeal to the

secretary-general of the group in the event of difficulty. An email address

is also available for reporting any breach of the Ethics Charter.

UMG is committed to adopting a “zero tolerance” approach to fraud

and corruption and to acting in a professional manner and with integrity

wherever the company operates, in accordance with local regulations

and with the 2010 UK Bribery Act. UMG has introduced an early warning

system available to its employees. All the group’s employees have been

instructed in the company’s Code of Conduct which includes its anti-

corruption policy and they must agree to abide by it.

Employees located in North and Central America take a yearly online

Code of Conduct training course. This session comprises sections relating

to fraud and corruption, which enables employees in these regions to

be continually tested in these issues. With regards to the UK Bribery

Act, UMG has a specific policy that is available to employees on the

UMG Human Resources website. UMG has also developed fraud and

corruption training programs. In 2014, all employees in China, Hong Kong

and Taiwan received training on the Foreign Corrupt Practices Act, the

UK Bribery Act and the UMG Code of Conduct. The meeting was held

in Chinese to ensure that all employees fully understood the subjects

covered.

With the support of outside counsel, UMG has undertaken an approach

to draft anti-corruption language which the group intends to include in

its commercial contracts on a global basis. The language will require

UMG vendors to comply with applicable local laws and will provide

UMG the ability to terminate contracts or enforce another penalty in the

event of non-compliance on the part of the supplier. China will be the

first jurisdiction in which the measure will be adopted, followed by North

America.

GVT, which signed the United Nations Global Compact in 2014, has held

training sessions to inform and enlist the support of its senior executives

in this fight against corruption. In addition, the Brazilian operator signed

the “Call to Action: Anti-Corruption and the Global Development Agenda”

issued by the United Nations Global Compact in December 2014 to

celebrate the tenth anniversary of the tenth principle of the Compact.

This Call to Action is an appeal by the private sector to governments

to promote practices combating corruption and to establish policies of

good governance, which are necessary conditions for promotion of a

sustainable and inclusive global economy.

Total number of incidents having resulted in

non-renewal of contract with commercial partners

due to violations related to corruption

GRI

UNGC

OECD

Scope covered

G4-S05

II, VII

Canal+ Group

UMG (9 focus group

countries)

GVT

During 2014, neither Canal+ Group nor UMG recorded any cases of

corruption in connection with their commercial partners.

■

4.5.2. Contribution to Public Policy/Responsible Lobbying

Formal commitment in favor of responsible

and transparent lobbying practices

GRI

UNGC

OECD

Scope covered

G4-DMA

S0 Public

policy

aspect

Canal+ Group

UMG (9 focus group

countries)

GVT

Canal+ Group is a member of professional associations such as AFRC

(French Association of Customer Relations) and FEVAD (Federation of

E-Commerce and Distance Sales), which are lobbying, among other

things, for changes in practices and in the regulations related to the

activities of their sectors.

Moreover, at the time the inter-professional agreement on media

chronology was being renegotiated, the group lobbied public authorities

to maintain the major balances in that system, which makes it possible

to maximize the funding of cinematographic works, in particular through

the exclusive window of pay-TV channels.

In Poland, nc+ engaged in extensive dialog with its stakeholders

involved in the fight against piracy.

Among the numerous initiatives conducted by nc+ in 2014, a

conference hosted by Signal (Polish association of TV broadcasters of

which nc+ is a founding member) is worthy of note; it was organized

in December 2014 on the subject of “Protecting intellectual property

on the Internet, Poland’s strength or weakness?”. A number of major

players from the media sector and representatives from the public

sector came together at round tables to discuss the challenges to

intellectual property in the digital age.

Non-Financial Indicators Handbook 2014