Combined Non-Financial Statement

The following information relates to Bertelsmann  SE & Co. KGaA  and the Bertelsmann Group (“Bertelsmann”) with its incorporated, fully consolidated subsidiaries (“subsidiaries”).

Bertelsmann operates in the core business fields of media, services and education in around 50 countries (cf. section “Company Profile”). Responsible conduct – in business, toward employees, in society and in dealing with the environment – is firmly anchored in Bertelsmann’s corporate culture. In its corporate responsibility management, Bertelsmann pursues the goal of reconciling its economic interests with social and environmental concerns within the Group and beyond.

To identify relevant topics and describe concepts, the GRI Standards 2016 specified by the Global Reporting Initiative (in particular standards 102 and 103) were used to produce the Group Non-Financial Statement. In addition, a voluntary CR report based on the GRI Standards (2016; Option “core”) will be published by the middle of the financial year.

Company Principles and Guidelines

The prerequisites for a corporate culture in which employees, management and shareholders work together successfully, respectfully and in a spirit of trust are common goals and shared values. These are enshrined in the corporate constitution and in the four Bertelsmann Essentials: partnership, entrepreneurship, creativity and corporate citizenship. Furthermore, the Bertelsmann Code of Conduct – as a binding guideline – defines standards for law-abiding and ethically responsible conduct within the company and toward business partners and the public. The sense of purpose embodied in the triad “To Empower. To Create. To Inspire.” also provides orientation for the company’s staff and partners.

Bertelsmann’s actions are also determined by external guidelines. The company largely follows the recommendations of the German Corporate Governance  Code for good and responsible corporate governance and the OECD Guidelines for Multinational Enterprises. Bertelsmann is committed to the principles of the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and the International Labor Organization core labor standards. Since 2008, Bertelsmann has also supported the 10 principles of the United Nations Global Compact as an active participant.

Corporate Responsibility Management


The advisory body for the strategic development of corporate responsibility at Bertelsmann is the CR Council. The CR Council is made up of the Chief Human Resources Officer (CHRO) and representatives from the corporate divisions and focuses on the Group-wide CR objectives in line with the corporate strategy and the cross-divisional coordination of CR activities within the Group.

At the Group level, the Corporate Responsibility & Diversity Management department coordinates and supports the work of the CR Council in close cooperation with the other Group functions. Within the decentralized Bertelsmann corporate structure, the local management teams are responsible for implementing corporate responsibility through specific CR measures and projects. The corporate divisions and companies have their own structures and processes in place for this, in accordance with local requirements.


To identify key CR topics, Bertelsmann carries out regular CR relevance analyses. In 2017, the company conducted a survey of internal and external stakeholders. The external stakeholders estimated the impact of Bertelsmann’s business activity on the topics, while the internal stakeholders assessed their business relevance. This made it possible to identify topics of relevance to Bertelsmann relating to environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters. The topics are analyzed within the company boundaries, unless otherwise stated.

Corporate responsibility topics, including non-financial performance indicators, are not part of Bertelsmann’s valueoriented management system. Due to limited measurability, no directly quantifiable statements can be made regarding relevant interdependencies and value increases for the Group. For this reason, the non-financial performance indicators are not used for the management of the Group (cf. section “Value-Oriented Management System”).


A number of risks associated with CR topics are relevant for Bertelsmann. These risks can arise from the company’s own business activities or from its business relationships, and can affect the company or its environment and stakeholders.

For the non-financial matters defined in the German “CSR Directive Implementation Act” – environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters – no significant risks were reported as part of the 2017 reporting.

For an analysis of the risks that are relevant for Bertelsmann, please see the “Risks and Opportunities” section.

Employee Matters

Motivated employees ensure long-term quality, innovation and growth. HR work at Bertelsmann is therefore based on the company’s cooperative identity as codified in the corporate constitution and the Bertelsmann Essentials. Supplementary regulations are specified in Executive Board guidelines on HR work. The CHRO is primarily responsible for dealing with employee matters within the company. He works closely with the HR managers from the corporate divisions who report directly to him via a dotted-line concept. This cooperation is supported by other bodies such as the HR Committee, consisting of the CHRO and representatives from the corporate divisions and the HR Country Coordination Meetings (with the HR managers of the largest subsidiaries – or the subsidiaries with the largest number of employees in the region in question). Divisional Nomination & Compensation Committees decide on the implementation of remuneration and staffing policies in the respective areas of responsibility. In 2017, measures were taken to address the following topics.


Bertelsmann sees continual dialogue between employees and company management as a fundamental prerequisite to the company’s success. As a media company, Bertelsmann is free to determine its political direction as defined in the German Works Constitutions Act (Tendenzschutz) and in this respect is not subject to statutory codetermination within the Supervisory Board. Nevertheless, the employees have five members serving on the Supervisory Board of Bertelsmann SE & Co. KGaA on a voluntary basis: four of these are works council members and one is a member of the 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. The Bertelsmann Group Dialogue Conference is an event where the CEO, CHRO and members of the Corporate Works Council can exchange ideas. Employees are also involved in the development and improvement of working conditions through standardized HR interview tools (Performance and Development Dialogue, Agreements on Objectives, Team Talk), as well as employee surveys. In 2017, measures were derived at corporate, divisional and Group level from the employee survey conducted in the previous year.


Highly trained employees are needed to overcome major challenges such as the Group’s increasingly international focus, the digital transformation of the media and service landscape, and demographic change. By providing opportunities for lifelong learning, Bertelsmann helps to secure the long-term employability of its employees. With four different campuses – Strategy, Leadership, Function and Individual – Bertelsmann University is the central learning organization within the company. The most important measures implemented in 2017 included the further development of international programs in the areas of leadership, strategy and creativity, and holding strategic summits for the Group-wide finance, HR and IT community. In addition, 2017 saw the launch of a global Data Science Initiative and the continued integration of digital learning content in the various training and degree courses that Bertelsmann offers in Germany.


For Bertelsmann, diversity of its workforce is a prerequisite for creativity, innovation and long-term business success. The diversity strategy focuses on the aspects of gender, generations and nationality. The proportion of women in Bertelsmann talent pools (top management, senior management, career development) shall be increased. This was already considered in the 2017 talent pool nominations. The diversity strategy is implemented by the Corporate Responsibility & Diversity Management department with support from a Group-wide Diversity Working Group. In 2017, the primary focus was on realizing the recommendations from the Bertelsmann Diversity Conference 2016. These included piloting diversity training, management qualifications from Bertelsmann University and taking into account diversity aspects in Corporate Talent Management.


With a view to designing a health-promoting work environment and preventing work-related risks of disease, Bertelsmann is expanding a systematic health management system at German locations. Bertelsmann Health Management has been put in charge of supervising and coordinating the Germany-wide health strategy and associated activities, in conjunction with a cross-functional strategy group. The cross-divisional “Health Community,” which is comprised of health experts, works council chairs, Supervisory Board members, HR managers and representatives for employees with disabilities, plays a key role here. Through targeted networking, it also helps to reinforce uniform standards that Bertelsmann Health Management is seeking to apply to all German locations. In the medium term, the internationalization of Bertelsmann Health Management shall continue.

Fair Working Conditions

At Bertelsmann, remuneration issues are an essential part of the topic of fair working conditions. The policy is to establish consistent and transparent remuneration structures in the Group. The design of the compensation system is intended to ensure that remuneration is driven by market, function and performance, taking into account business-specific characteristics. Employee profit sharing in Germany is based on the same criteria as those used to calculate variable remuneration components for Executive Board members and executives. This includes Bertelsmann and subsidiaries based in Germany, except RTL Group and Gruner + Jahr. These and many foreign subsidiaries have similar success and profitsharing models adapted to local requirements. In 2017, a total of €105 million of the 2016 profits was distributed as part of such schemes.

Social Matters

Corporate citizenship is one of the Bertelsmann Essentials and is thus firmly anchored in Bertelsmann’s corporate culture. As a good corporate citizen, Bertelsmann is committed to contributing to society and implemented measures in the following areas in 2017.

Press Freedom

Bertelsmann stands for the freedom of the press and therefore a wide variety of opinions and positions. The Bertelsmann Code of Conduct defines freedom of speech and opinion and creative independence as a basic principle of the Group’s business activities. Bertelsmann interprets this independence in two directions: Inside the company, it means that our management does not attempt to influence the decisions of artists, editors and program managers, or to restrict their artistic or editorial freedom. In accordance with the Bertelsmann “Editor-in-chief Principle,” editorial decisions are the sole responsibility of the program managers. To the outside, this means that the company does not capitulate to political or economic influence in its journalistic coverage, and complies with existing laws regarding the separation of editorial content and commercial advertising. In addition to the Bertelsmann Code of Conduct, many companies and editors in 2017 continued to implement separate statutes to safeguard journalistic independence in their day-to-day business and to develop these further where necessary. These statutes focus primarily on journalistic and editorial duties of care, respect for privacy, and dealing with the representation of violence and the protection of minors.

Content Responsibility

Bertelsmann reflects on the repercussions of the content it produces and distributes to protect the rights and interests of media users and customers as far as possible. Overriding principles and guidelines of media ethics are set by national and international laws governing the press, broadcasting and multimedia; 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 and editorial statutes. With it, Bertelsmann’s editorial staff are committed to, among other things, “respecting privacy and the responsible treatment of information, opinion and images.” In accordance with the “Editor-in-chief Principle,” the responsibility for media content lies solely with the program managers in the local editorial teams.

In the area of youth media protection, content is monitored at Bertelsmann in accordance with different circulations for each medium and region to see if it could adversely affect the development of children or young people. Various restrictions come into force, such as broadcasting time restrictions or labeling content and/or products. Through voluntary labeling systems, Bertelsmann sometimes goes beyond the existing European and national regulations, particularly in the broadcasting industry. Other specifications relating to content responsibility are agreed through supplementary statutes at the divisional, company and editorial level.

Customer Data Protection

Bertelsmann attaches great importance to protecting customer data. This includes safeguarding the personal data of individual customers, as well as information about customers that is provided to Bertelsmann by its business partners. The objective of customer data protection is to protect an individual’s right to determine who acquires 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. In addition to the Bertelsmann Code of Conduct, customer data protection within the company is regulated by Executive Board guidelines on the topics of information security and IT risk management..

The Executive Board Guideline on Data Protection addresses the data protection framework conditions at Bertelsmann Group based on the General Data Protection Regulation (GDPR), which will be applicable from May 25, 2018, and is designed to ensure consistent data protection management across the Bertelsmann Group. To support this, a data protection management system was rolled out across the Group in the third quarter of 2017. It addresses the documentation and accountability obligations under GDPR, as well as regulations concerning governance obligations.

Responsibility for customer data protection is decentralized and rests with the management of the individual subsidiaries. To ensure compliance with local laws governing customer data protection, the subsidiaries in Germany 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 on an event-driven basis to the central data protection officers, who in turn report to the Bertelsmann Executive Board. A similar organization exists in subsidiaries outside Germany. An information security management system (ISMS) based on industry standard ISO 27001 creates the technical framework for confidential data processing. The ISMS features a regular and structured survey to ensure compliance with statutory information security requirements, a systematic recording of risks and the derivation of related mitigation measures.

Protecting Intellectual Property

Bertelsmann’s businesses develop, produce, transfer, license, and sell products and services that are protected as intellectual property. For Bertelsmann, the protection of intellectual property rights is the foundation of its business success. For this reason, the company is committed to a high level of global copyright protection worldwide and in the digital world. The Group-wide Taskforce Copyright, with representatives from the relevant corporate divisions, supports current developments in copyright and summarizes its positions in the form of joint papers.

Respect for Human Rights

Through its corporate principles and its voluntary commitment to external guidelines, Bertelsmann is committed to respecting and protecting human rights within the company and in its business relationships. For this reason, the Bertelsmann Executive Board established an Integrity & Compliance program and appointed a Corporate Compliance Committee (CCC). The CCC submits an annual Compliance Report to the Bertelsmann Executive Board and the Audit and Finance Committee. The Integrity & Compliance (I&C) department was created to manage the ongoing day-to-day work and is subordinated to the CCC in the organization. I&C supports the CCC in fulfilling its tasks and makes suggestions for necessary improvements to the I&C program. I&C ensures that employees worldwide are made aware of the key legal provisions and internal company guidelines, including those concerning the respect for human rights, and it implemented the training and communication measures necessary for this in 2017.

Respect for human rights, particularly in respect to employees and within the supply chain, is expressly stipulated by the Bertelsmann Code of Conduct and the Supplier Code of Conduct. This includes the ban on child and coercive labor and the ban on discrimination and intimidation, and it reaffirms the right to freedom of association and the right to engage in collective bargaining. In addition, individual subsidiaries and Bertelsmann itself issued statements in 2017 in accordance with the “UK Modern Slavery Act” that condemn all forms of modern slavery, coercive and child labor, and exploitation and discrimination, and present measures to prevent these human rights violations. These statements are revised each year (as required). At Bertelsmann, violations of this principle may be reported by employees and by third parties via the reporting channels within the existing compliance management system. In terms of antidiscrimination, contact persons for Germany’s “General Equal Treatment Act” (AGG) have been appointed at all German locations. Employees can contact them in the event of suspected breaches of said act. The employees are informed of their rights under AGG and given corresponding training through a wide range of communication channels. The topic of antidiscrimination was addressed in a Group-wide e-learning program designed to build employee awareness of the issue and advise them of their rights.

Anti-corruption and Bribery Matters

Both the Bertelsmann Code of Conduct and the Bertelsmann guidelines expressly prohibit all forms of corruption and bribery. This prohibition also applies to all third parties that work for, with or on behalf of Bertelsmann, as stipulated in the Supplier Code of Conduct. Along with instructions for dealing with officials, and guidelines for the granting or accepting of gifts in the context of business relations, the anti-corruption and integrity guideline prescribes appropriate due diligence processes in dealing with third parties. An appropriate due diligence review is carried out for each individual risk profile through a corresponding risk classification. This Executive Board guideline also describes the channels for reporting suspected violations and seeking advice, as well as other prevention and control measures. The Executive Board guideline for dealing with alleged compliance violations anchors an obligation to report suspected violations of the prohibition of corruption to the Bertelsmann Corporate Center. The topic of corruption prevention is globally managed and further developed by the I&C department. One of the most important measures in 2017 was advising and training executives and employees on anticorruption and the design and initiation of the Group-wide rollout of a new e-learning program on this topic.

Fair Competition and Antitrust Law

Bertelsmann is committed to the principle of fair competition and condemns antitrust violations and anticompetitive behavior. The company acts against any contravention and consults internal or external experts on antitrust and competition issues. The Bertelsmann Executive Board has approved a “Group Guideline for Compliance with Antitrust Regulations.” There is an obligation to report any antitrust violations. The Corporate Legal Department offers antitrust training programs to corporate divisions and the management and employees of these divisions. A comprehensive compulsory training program for employees working in antitrust-related areas, which was also implemented in 2017, is intended to identify antitrust risks at an early stage and to prevent antitrust violations.

Environmental Matters

The Bertelsmann Environmental Policy and the Bertelsmann Paper Policy provide the framework for the responsible use of natural resources throughout the Group, as well as environmentally friendly energy and material procurement. The environmental commitment extends beyond the individual locations to the supply chain, in particular by influencing paper suppliers and energy firms. Operational responsibility for energy and environmental management and for implementing the measures adopted in 2017 is decentralized and rests with the management of the individual companies. An international “Be Green” Working Group with representatives from the Bertelsmann corporate divisions again provided a platform for cross-divisional exchange on environmental topics in 2017. In the medium term, the cooperation will focus on increasing the use of paper from certified or recycled sources and reducing greenhouse gas emissions from the consumption of energy, heat and fuels. Experts from the “Be Green” Working Group also coordinate the annual collection of environmental key figures, which not only create transparency about impacts on the environment and climate as well as about Bertelsmann’s environmental performance, but also enable the management to derive measures for improvement. The Group-wide environmental key figures are published on the Bertelsmann website.