Anti-Corruption and Antitrust Law

Management Approach Disclosures

ProSiebenSat.1 Group believes that sustained economic success in a competitive environment can only be achieved by ensuring that all action taken is in compliance with the applicable laws. Therefore, preventing corruption and violations of antitrust law is highly relevant to business and represents an important success factor for achieving our corporate goals. In addition to the prevention of corruption, the Group’s compliance management system organizationally encompasses the avoidance of antitrust violations as well as adherence to the data protection processes and media law requirements of the German Interstate Broadcasting Treaty (Rundfunkstaatsvertrag). The major aim is to anchor integrity and lawful conduct in the thoughts and actions of all employees on a lasting basis and hereby prevent violations of laws and regulations from the outset. Organization and Management

The Group has laid down basic guidelines and policies in its Code of Conduct. The stipulations therein define the general standards for conduct in business, legal and ethical matters. They serve as a binding reference and regulatory framework for all members of the Executive Board, the management, and the employees of the Group for dealing with each other and with external stakeholders. Another central compliance instrument for ProSiebenSat.1 Group is the whistleblower system, which comprises internal and external reporting channels. Anti-Discrimination

Anti-Corruption

14 companies underwent a compliance check in 2016. As well as issues such as antitrust and media law and data protection, this check also examined risks related to corruption. The companies assessed included central units such as ProSiebenSat.1 TV Deutschland and SevenOne Media, which generate a high proportion of the consolidated revenues. With regard to the main competition and corruption issues, one of our key focal points is the advertising sales model owing to how financially important it is to the ProSiebenSat.1 business model. This risk assessment remains valid.

In addition, ProSiebenSat.1 Group has implemented training in the fields of antitrust law, anti-corruption, data protection and media law, which includes both online and classroom training. The online training, which is offered in English and German on a two- to three-year cycle and is mandatory for all employees, is intended to provide a basic understanding of the main compliance risks. The classroom training is targeted at risk groups and is carried out by Legal Affairs, Group Compliance, HR Law, Corporate Information Security, the Data Protection Officer and the Youth Protection Officer for their individual areas. In addition, ProSiebenSat.1 Group offers all-day seminars for the managers of German affiliated companies at its P7S1 Academy in order to give them a comprehensive overview of their rights and obligations and the relevant legal bases. Product Governance

In 2019, as in the previous year, no investigations became known against the Group, its subsidiaries or employees of ProSiebenSat.1 Group with regard to corruption offenses. No fines or financial penalties were imposed.

Anti-Competitive Behavior

In 2019, as in the previous year, no investigations became known against the Group, its subsidiaries or employees of ProSiebenSat.1 Group with regard to antitrust violations. No fines or financial penalties were imposed.