2.5 Corporate Responsibility

United Internet AG’s Management Board and Supervisory Board consider it their responsibility to ensure the Company’s continued existence and create sustainable value through responsible corporate management that takes a long-term perspective. For United Internet, running a business involves more than pursuing economic goals – it also has an obligation to society, the environment, employees, and other stakeholders.

United Internet AG fulfills its disclosure obligations pursuant to the German CSR Directive Implementation Act (CSR-Richtlinie-Umsetzungsgesetz – CSR-RUG) (sections 315b and 315c in conjunction with section 289c of the German Commercial Code (“Handelsgesetzbuch” – HGB)) and publishes a separate non-financial Group report as part of a separate sustainability report. In this Sustainability Report, the Company also complies with its reporting obligation under the EU Taxonomy Regulation 2020/852 of the European Parliament and discloses its proportion of environmentally sustainable business activities accordingly.

The Company’s Sustainability Report 2023 will be published in late March 2024 (at https://www.united-internet.de/en/investor-relations/publications/reports.html) and thus fulfills the disclosure requirements of the CSR-RUG and the transparency requirements of stakeholders.

The separate non-financial Group report contains the statutory disclosures for the aspects “environmental matters” (chapter: Environmental Responsibility), “employee-related matters” and “social matters” (chapter: Social Responsibility), and “respect for human rights” and “anti-corruption and bribery matters” (chapter: Corporate Responsibility). This list of the minimum aspects required by the CSR-RUG has been supplemented by the chapter “Digital Responsibility”, which is a material aspect for United Internet and also particularly relevant for the sector.

In addition to the CSR-RUG, reporting is based on the internationally recognized Sustainability Reporting Standards published by the Global Reporting Initiative (GRI) with the option: “With reference to the GRI Standards”. Both the CSR-RUG and the GRI Standards expect information to be presented on how the material topics and their impacts are managed, and in particular the associated goals and measures, and the procedures used for risk identification and mitigation. In addition, the European Commission’s Guidelines on non-financial reporting are applied, which build on Directive 2014/95/EU on disclosure of non-financial and diversity information by certain large undertakings and groups – the European Directive underlying the CSR-RUG.

When defining the content, the materiality principle was applied. In 2022, a double materiality analysis was carried out to determine the material topics. Both the business relevance for United Internet and the potential and specific impact of the Company’s activities on the environment and society were taken into account.

In the reporting period, the main focus was on preparing for the first CSRD reporting for the fiscal year 2024. A Group-wide project was driven forward in order to meet the reporting requirements of the new EU reporting obligation. The materiality matrix from the fiscal year 2023 formed the basis for the development of the future reporting strategy. A reconciliation to the CSRD requirements and a comprehensive gap analysis of the future quantitative and qualitative reporting obligations were conducted. The necessary transformation of the reporting system was initiated. As part of an evaluation project, the necessary processes, IT concepts and software solutions were reviewed in order to facilitate future data collection for all parties involved.

The Company’s Supervisory Board is responsible for examining the content of sustainability reporting. The Supervisory Board is supported in this by a “limited assurance” review of the separate non-financial Group report by PricewaterhouseCoopers GmbH Wirtschaftsprüfungsgesellschaft.