Effective Anti-corruption and Anti-bribery Management
Susan Gustafsson, Group General Counsel
How does MTG work to prevent corruption and bribery?
MTG does not tolerate any form of bribery and corruption, and we work diligently to prevent any kind of corruption, bribery and unlawful misbehavior in our company. Every new employee is required to sign our anti-bribery and anti-corruption policy, and to complete an e-learning anti-corruption course that was initially created by UNOCD and the UN Global Compact. We also work systematically with scenario-based training. During 2016, all MTG management teams, including those in our digital ventures, were trained in our anti-bribery and corruption policy and guidelines. In total, six workshops were held and 356 senior managers were trained. We plan to continue these training sessions targeting senior management, selected employees and any new company that becomes part of the group.
What can employees do both to prevent and detect potential corruption?
MTG is committed to achieving an open and transparent working environment, and it is for these reasons that we have established our whistleblower policy. This means that all MTG employees can be confident that they can raise any matter of genuine concern and that this will be investigated appropriately (and, if so required, on a confidential basis). Since 2015, we have provided an internal anonymous whistleblower system called Speak Up. This system is run by an independent company that specializes in the provision of these services, and it allows employees to report (anonymously if they wish) via an online portal or a free phone number. The system is available in 15 different languages and is promoted in the employee induction process and through our intranet. During 2016, we had two whistleblowing complaints in relation to alleged fraud, bribery and corruption. Both cases were fully investigated and were closed.
How will you continue to improve MTG’s anti-corruption work?
In 2017, we will review our policies and procedures for employee engagement and training for the group, as well as our e-learning offering, to make sure they stay relevant, effective and educational. We need to ensure that we have robust policies in place at all times, as well as effective training and procedures for preventing, reporting and dealing with potential bribery and corruption incidents.
Esports Ethics Partnerships
In 2016, we helped found the World Esports Association (WESA). WESA’s vision is to create a framework that supports sustainable growth for esports, based on shared values of fairness, transparency and integrity.
Modeled on similar traditional sports associations, WESA is an open and inclusive organization that works to further professionalize esports by promoting dialogue between industry stakeholders and facilitating industry-wide standards and frameworks.
We are one of the organizations behind the Esports Integrity Coalition (ESIC). ESIC is a not for profit members’ association established by industry stakeholders to address integrity challenges in esports. These include, but are not limited to, cheating to win using software cheats, online attacks to slow or disable an opponent, match-fixing and doping.
ESIC is an open coalition of organizations who recognize that corruption has the potential to undermine the industry. ESIC has already published policies and codes in order to create a common regulatory framework based on joint definitions, as well as a unified disciplinary procedure. ESIC also provides a comprehensive education programme for association members and esports participants.
Data Protection and Privacy
Ulrika Wester, Group Compliance Officer
Tell us about the new European Union General Data Protection Regulation (GDPR) and what MTG is doing to meet its requirements.
We believe that the GDPR, which will come into force in May 2018, is a great step forward. It strengthens personal data protection for everyone in the EU and harmonizes relevant laws across Member States. At the same time, the new regulation introduces significant new requirements and challenges for all legal and compliance functions.
During 2016, we continued to strengthen MTG’s data protection processes. We have carried out data protection training, which has been a mixture of voluntary training for all staff and mandatory training for senior managers. Over 90% of our senior managers received face-to-face training on data protection issues. We have also asked Deloitte to assess MTG’s readiness for GDPR compliance, and to compile a report with initial gaps and improvement areas. This content will be used to develop a compliance roadmap that will be part of the group’s data protection program in the future.
How do we mitigate data protection risks such as data breaches?
Our main focus in 2016 was on developing data protection breach guidelines and carrying out training for relevant staff. This training focused on how to respond effectively to a breach, and was carried out in Riga and London as part of a wider crisis management exercise. We have also put in place Data Loss Prevention (DLP) software, which will help reduce the risk of potential data losses or thefts by monitoring data transfers in and out of the company.
The plan for 2017 is to train more management teams in responding to these types of situations. We have developed a clear data breach procedure, which sets out the contacts and procedures to follow in the event of a breach. This includes training for relevant senior management on how to respond, and a mock data breach where we test our procedures.
What is the plan to strengthen our data protection work further?
We will focus on completing the review of MTG’s data protection processes, with the assistance of Deloitte. Once achieved, we will then establish a roadmap for GDPR compliance and appoint data protection champions who will act as points of contact within the group’s different businesses. They will also be responsible for setting the groundwork for implementation.
We have recently appointed a Chief Information Security Officer and we also intend to hire a Data Protection Officer who will be responsible for the daily management of the group’s data protection program.
In the long term, our aim is to achieve GDPR compliance, as well as ensuring that effective data protection procedures are in place – first of all, to secure personal data, but also to ensure the right response to any breaches while minimizing the possibility of any happening in the first place. We want MTG to be seen as a leader in this field, and as a company that can be trusted and respected for our stance on data protection.
How We Govern
Modern Times Group MTG AB is a Swedish public limited liability company. The company’s governance is based on the Articles of Association, the Swedish Companies Act, the listing rules of Nasdaq OMX Stockholm, the Swedish Code of Corporate Governance, and other relevant Swedish and international laws and regulations.
Our valuable investors who can make propositions on issues affecting the company and its operations at the AGM.
The Nomination Committee evaluates the Board of Directors’ work and composition, submits proposals to the AGM regarding the election of the Board, Chairman of the Board and Auditors, and prepares fee proposals to the Board and Auditors and proposals for the Chairman of the AGM.
Board of Directors
The Board of Directors consists of six non-Executive Directors, of which all six are independent of the Company Management and five are independent of the major shareholders. The Chairman of the Board is independent of both the Company and the major shareholders. The Board also governs MTG’s corporate responsibility. The Remuneration Committee is responsible for issues related to salaries, pension plans, Long Term Incentive Plans, and the employment terms of the CEO and Executive Management of MTG.
The Audit Committee focuses on financial reporting accuracy, accounting policy changes, internal controls, risk assessment, auditor qualification and independence, adherence to regulations and transactions with related parties. The Internal Auditors are responsible for the evaluation of risk management and internal control activities, and report the result of these reviews to the Audit Committee.
The Corporate Responsibility Advisory Group (CRAG) was established in 2013 to support the Board of Directors on corporate responsibility topics. The Group meets three times a year and consists of two members of the Board of Directors. MTG’s President and CEO, one member of the Executive Management team, the Group General Counsel and the Head of Corporate Responsibility report and are part of the CRAG meetings. The CRAG has overall responsibility for the Group’s corporate responsibility strategy, agenda and practices, including issues relating to human and labour rights, anti-corruption and environmental performance. The group reports their findings to the Board of Directors.
The Executive Management team is in charge of day-to-day implementation of the business strategy and corporate responsibility.
Global Corporate Responsibility Team
The Global Corporate Responsibility Team drives MTG’s corporate responsibility strategy. The team implements a cross-functional corporate responsibility agenda and processes, monitors and reports on progress, and communicates various activities. The team reports to the CRAG.
Local CEOs ensure that MTG’s corporate responsibility strategy is implemented and forms an integral part of our various businesses. Each country has an appointed corporate responsibility representative and a green ambassador who works as a link between the Global Corporate Responsibility Team and the local operations.
Our Stakeholder Engagement
MTG’s stakeholders consist of all the people and organizations that may be affected by our business – and those that in turn affect us as a company. It goes without saying that their input guides us in the right direction, and that our stakeholders are therefore key to our success.
We engage with stakeholders as part of our everyday business, and continuously involve them in our corporate responsibility activities and goal-setting processes as part of our materiality assessment. This engagement aims to achieve shared goals of common interest. In 2016, our structured materiality dialogue involved over 400 internal and external participants.
Our corporate responsibility strategy and focus areas are consequently based on stakeholders’ input. We use our social media channels, intranet, web and in-person meetings to broaden the conversation around our ongoing corporate responsibility work and to strengthen our feedback processes even further.
Day-to-day engagement methods: Free-TV: focus groups, attitude research, social media, viewing figures and audience appreciation index. Pay-TV: customer support channels and social media. Radio: listener hotlines, competitions, websites, blogs and social media. B2B: direct dialogue.
Key issues: Health, safety and security, transparent and credible dialogue, content quality.
Day-to-day engagement methods: Annual General Meeting, Annual Report, Corporate Responsibility Report, quarterly reports, press releases, Environmental Social Governance (ESG) roadshows and conferences.
Key issues: Responsible advertising, content quality and accessibility.
MTG’s Board of Directors.
Day-to-day engagement methods: Board of Directors meetings.
Key issues: Data protection and privacy, equality and diversity, effective anti-corruption management.
Our team members.
Day-to-day engagement methods: Annual employee survey, intranet, newsletters, policies and guidelines, meetings and daily dialogues.
Key issues: Content quality and accessibility, transparent and credible dialogue, data protection and privacy, valuing creativity, work-life balance, skills management, diversity and equality.
The companies whose products and services we buy.
Day-to-day engagement methods: Continuous dialogue, supplier principles and self-check document.
Key issues: Compliance with our requirements.
The non-governmental organizations with which we work.
Day-to-day engagement methods: Continuous dialogue (locally and centrally).
Key issues: Equality and diversity, health, safety and security, community engagement.
Ofcom and other authorities that set the rules for what we do.
Day-to-day engagement methods: Continuous dialogue with the compliance and legal teams.
Key issues: Product safety and compliance (regulatory and legal), child and minor protection, responsible advertising, content accessibility and impact awareness.
Our peers and colleagues.
Day-to-day engagement methods: Quarterly industry forums, the Responsible Media Forum and continuous dialogue with colleagues and other professionals.
Key issues: Data protection and privacy, human rights and environmental impacts, United Nations Sustainable Development Goals (SDGs).
As a global digital entertainer, we offer a wide range of products and services for multiple markets across a broad range of distribution channels. But even though we are many brands, we are one organization. That means we follow the same processes and work towards the same goal: to create value for our customers, partners, employees and shareholders, as well as for society as a whole.
We work with many types of suppliers to ensure we have what we need to run our business. Core suppliers include Hollywood film studios and major sports rights providers, as well as local studios and channels. Set-top-box hardware producers are also included in this category. Non-core suppliers, meanwhile, include office equipment and IT vendors.
Before content can be distributed, many departments and teams need to be involved. Some play a direct role, while others facilitate. This process covers everything from production, acquisition and scheduling to compliance, marketing and broadcasting.
Selling and supplying
We make our content available to customers on our free-TV and pay-TV platforms, on our streaming services as well as on radio stations. We supply advertising space to media buyers, other businesses and charities. We also produce programmes for other broadcasters.
Broadcasting and streaming
We make our content available via multiple broadcast and streaming platforms. MTG operates free-TV and pay-TV platforms in the Nordic region and in markets in Central and Eastern Europe. Our streaming services Viaplay (subscription) and Viafree (free) offer content on-demand through smart TVs, mobile apps and additional access points.
We have an ongoing dialogue with all our stakeholders to improve our products and services. This dialogue includes focus groups, surveys and interviews, and ensures we give our audiences exactly what they want, while offering our business customers opportunities to strengthen their brands. This input is channeled back to our content creation and purchasing teams to ensure we continue to offer inclusive, accessible and responsible content that delivers a positive impact.
MTG’s digital ventures
As part of our transformation from a traditional broadcaster into a leading digital video entertainer, we are investing in relevant, complementary and scalable content and communities. Today, our portfolio includes digital video networks, esports and online gaming businesses, each with distinct value chains. Our digital video networks Splay Networks and Zoomin.TV connect audiences with the most popular Scandinavian and international online talents and influencers, and deliver original high quality content. Our esports businesses DreamHack and ESL operate live events, pro gaming leagues and international tournaments. And our most recent investment, InnoGames, is a leading developer and publisher of online games.