At MTG we promote a culture of openness, responsibility and accountability. We want to conduct business in full compliance with laws, regulations, international initiatives and standards.

Our Code of Conduct is built on our values; striving to inspire and ignite, exploring opportunities, enhancing lives and shaping the future. More importantly, the code is a guide for all our employees on how we do (and don’t do) business. It helps us navigate the ethical and legal situations we face daily. Our code describes our responsibilities towards customers, business partners, shareholders and each other. It also sets out our position on topics such as fair working conditions, asset protection, anti-corruption practices, conflicts of interest, competition, data privacy and much more.

As a responsible global business, we are committed to international initiatives and standards such as the OECD Guidelines for Multinational Enterprises, the UN Global Compact, the Fundamental Conventions of the International Labour Organisation, the UN Universal Declaration of Human Rights, and the UN Guiding Principles on Business and Human Rights. We review our policy framework annually and if significant changes are made we need approval from the Board.

To ensure that all our employees understand and adhere to our values and commitment, we ask them to sign our Code of Conduct when starting their employment with MTG. During 2018, 82% of new employees signed. In 2018, we launched and rolled out four e-learning courses for all fixed employees covering our Code of Conduct, Data & Asset Protection, Competition and Anti-Bribery & Corruption. Our overall completion rate for all four courses by the end of 2018 was 89%. The aim of the courses is to familiarise our employees with the content of our steering document framework by providing practical examples and questions. Both the e-learning courses and the steering documents clearly state whom to reach out to with questions and concerns.

During autumn 2018, the Legal and Compliance team initiated face-to-face compliance training with our local management teams, deep diving into topics such as anti-bribery and corruption, conflicts of interest, competition and data protection amongst others. The next step in 2019 is to provide the same training to middle management and do more targeted and tailored face-to-face training.

As we promote a culture of openness, responsibility and accountability, we want everyone to feel comfortable about raising concerns, including possible violations of our Code of Conduct, policies, applicable laws and regulations. It is important for all our employees to know that their concerns will be taken seriously and investigated properly without fear of retaliation and that their confidentiality will be respected. Therefore, we have established a Whistleblower process and encourage our employees to raise their concerns directly. Should an employee not feel comfortable to raise a concern with their line manager or manager’s manager, they can contact our Whistleblower officers or use our anonymous external option via Speak-Up Line.

At MTG we take anti-bribery and corruption seriously, which is why we have the Anti-Bribery and Corruption Policy as well as the e-learning course. 88% of our employees completed this course. During 2018 we had no confirmed incidents of corruption and no incidents that lead to employee dismissal or disciplinary action. No contracts with business partners had to be terminated or not renewed due to violations related to corruption, and no legal cases were brought against us or our employees.

We also want to develop and maintain strong business relationships with suppliers who are committed to ethical standards equivalent to our own. Our new Supplier Code of Conduct sets out the standards with which all companies providing products or services to MTG are expected to comply. It is important to note that failure to comply with the standards and provisions in the Supplier Code may result in MTG reviewing and potentially ending a co-operation with a supplier.

On the 25 May 2018, the General Data Protection Regulation (GDPR) came into force across the European Union. We were prepared and ready after having started the GDPR project in early 2017 to ensure compliance with the regulation. A core central team consisting of the Group Compliance Officer, Central Data Protection Officer, the Chief Security Information Officer (later replaced by the head of IT) and two GDPR Project Managers have worked closely with our appointed local Data Protection Managers and Human Resources to make sure data protection matters are handled correctly.

We have continued to follow our roadmap which includes activities such as updating privacy notices and data processing agreements, reviewing retention periods, handling data subject requests, establish data breach procedures, as well as producing policies/guidelines and different types of training and awareness activities. A data protection awareness video was launched for all employees as well as the Data & Asset Protection e-learning which has a 89% completion rate. During 2018 we have continued to use OneTrust to map personal data processed within the organisation and identify data flows and where data is stored.

We have established a clear framework that manages data incidents and breaches which will ensure that we report possible personal data breaches within 72 hours. All personal data breaches are documented centrally. Complying and working with GDPR has become part of our daily work as we have moved into a governance phase and processes are starting to fall into place. In 2019 we will continue to define our strategy to include GDPR into daily work, to keep GDPR relevant and prioritised.