This Sustainability Report is addressed to all United Internet stakeholders. These comprise in particular investors, analysts, customers, employees, business partners, NGOs, political representatives, and the general public.
This Sustainability Report contains United Internet’s consolidated non-financial statement as required by 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)). The consolidated non-financial statement and the non-financial statement for the parent company, United Internet AG, have been combined in this separate non-financial report.
This report contains the statutory and supplementary disclosures for the material aspects for United Internet: environmental matters, employee-related matters, social matters, respect for human rights, and anti-corruption and bribery matters. This list of the minimum aspects required by the CSR-RUG has been supplemented by “customer-related matters.” These are material for United Internet and must therefore be reported. In addition to customer satisfaction, customer-related matters include information security, data protection, and digital transformation in general – all of which are particularly relevant to the sector. This is why these topics are presented in a separate chapter entitled “Corporate Digital Responsibility.”
The disclosures on diversity required by the CSR-RUG are to be found in the United Internet Group's Management Report (part of the Annual Report).
In addition to the CSR-RUG, our reporting is based on the internationally recognized Sustainability Reporting Standards published by the Global Reporting Initiative (GRI). This report has been prepared in accordance with the GRI Standards: Core option. 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. The CSR-RUG uses the term “policy” (“Konzept”) in this context, whereas the GRI talks about the “management approach.” The latter term is used in this report, as our objective is to prepare a sustainability report that complies with the GRI Standards and that contains the non-financial statement. Consequently, the “management approaches” in this report include the CSR-RUG’s “policies.” In addition, we have applied the European Commission’s Guidelines on non-financial reporting, which build on Directive 2014/95/EU as regards disclosure of non-financial and diversity information by certain large undertakings and groups – the European Directive underlying the CSR-RUG.
We applied the principle of materiality when defining the report content and considered the expectations of our stakeholders. The main requirements used to define the material topics were those set out in the GRI Standards, the CSR-RUG, and the abovementioned EU Guidelines. We observed the GRI Reporting Principles of Stakeholder Inclusiveness, Sustainability Context, Materiality, and Completeness during the definition process.
Since these frameworks are based on different definitions of “materiality,” the analysis takes a variety of viewpoints into account (see also the figure next page).
Sustainability reports prepared in accordance with the GRI Standards must define material topics using the following two dimensions:
The CSR-RUG and the EU Guidelines require at a minimum disclosures to be made on the non-financial aspects of environmental, social and employee matters, anti-corruption and bribery matters, and respect for human rights that are necessary to understand
The term “double materiality” is used to describe this combination of financial materiality on the one hand and environmental and social materiality on the other.
In order to do justice to both definitions, we evaluated the following criteria to define the material topics at the United Internet Group.
Our 2016 stakeholder survey consisted of two phases. In a first step, more than 40 managers from different areas of the United Internet Group pooled their expertise to assess which sustainability topics are material for United Internet. The analysis used the topics suggested by the GRI, which also include the non-financial aspects from the CSR-RUG.
In a second step, this internal, employee-oriented viewpoint was then supplemented by an online survey of external stakeholders. Stakeholder identification was based on the AA1000 Stakeholder Engagement Standard (SES). The survey polled representatives of our relevant stakeholder groups: investors/analysts, business partners/customers (including wholesale partners and outsourcing providers), other suppliers, and industry associations.
The results allowed us to identify the topics that our internal and external partners consider to be material.
In 2019, we also analyzed what sustainability expectations United Internet currently has to meet to satisfy investors, ESG ratings, and analysts, along with recent frameworks, standards, and initiatives. Firstly, this ensures that we can meet the requirements of the capital markets, which are becoming increasingly interested in ESG topics and which are a key target group for the Sustainability Report. Secondly, it helps ensure that our materiality analysis remains up to date, since innovations are often rapidly reflected in capital market decisions and in initiatives.
The following new key reference items have been included in this Sustainability Report: a number of ESG ratings (including MSCI, Sustainalytics, and CDP), assessments, and investor queries; the United Nations’ Sustainable Development Goals (UN SDGs, also referred to as the “Global Goals”); the European Commission’s revised Guidelines on non-financial reporting, which form part of the EU’s Sustainable Finance Action Plan (including the Supplement on reporting climate-related information that was published in 2019); and the 2017 recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) on linking climate-related reporting with financial information.
As a result, we were able to expand the list of topics derived from our direct stakeholder survey and identify those topics that are particularly relevant at present.
We also addressed additional future regulatory requirements during the reporting period. These include the framework for the EU’s Taxonomy Regulation, the TCFD recommendations mentioned earlier, and potential changes resulting from the revision of the CSR Directive and the implementation of the SPG.
The GRI Standards, the CSR-RUG, and the EU Guidelines all define “impacts” as the economic, social, and/or environmental effects that an organization’s activity has on the goal of sustainable development. This represents “environmental and social materiality,” which can be of interest to consumers, employees, business partners, municipalities, civil society organizations, and society as a whole.
We adopted as broad a social perspective as possible on our organization and our sector when defining United Internet’s potential impacts on society and the environment. To do this, we analyzed frameworks, standards, initiatives, agreements, studies, and research results, among other things – including materials with a sector-specific focus, where applicable. Examples include the UN SDGs (which we also examined from a sector-specific perspective), the UN Global Compact, the Paris Agreement, and studies and discussion papers produced by civil society organizations and research institutions. We comply with the CSR-RUG in the process and examine the potential impacts of our own business activity, products and services, and business relationships.
The main criterion that we used to assess business relevance was whether a particular topic is included in the United Internet Group’s financial reporting. We focused primarily on the Report on Risks and Opportunities in this context, although we also looked at other areas of the annual reporting. The sustainability topics identified in this way are considered to be directly relevant to the business.
We then widened this analysis by consulting the expanded definition of risk used in the EU Guidelines. Our objective is to ensure a broader time frame along the entire value chain. The risk types included in the TCFD recommendations – which cover political, legal, technological, market, and reputational risk in addition to physical risk – can be used for this.
See the TCFD Status Report.
Next, we started the process of identifying such risks by taking a look at regulatory developments. Among other things, these include the EU Sustainable Finance Action Plan, along with Germany’s decision to introduce carbon pricing and its National Action Plan to implement the UN Guiding Principles on Business and Human Rights.
We also examined overarching data and research results on risks. For example, the top five global risks in terms of likelihood listed in the World Economic Forum’s Global Risks Report 2020 are now all environmental and climate-related. For the fourth year in a row, the top five risks in terms of severity of impact include four from the environment and society categories (with the number one risk being “failure of climate change mitigation and adaption”). By contrast, economic risks have declined in importance over recent years.
Finally, the expectations of investors, ESG ratings, and analysts as to the transparency and management of ESG topics are used as an indicator of business relevance. According to the GRI Standards and EU Guidelines, financial materiality is particularly interesting to these stakeholders.(1)
(1) The EU Guidelines, among other things, draw attention to the fact that the various (risk) perspectives may overlap, and that the probability of their doing so is likely to increase even further in future.
The materiality matrix shows the results of the analysis. The horizontal axis shows the impacts of United Internet’s business activity on the environment and society; this dimension is common to both the GRI Standards and the CSR-RUG. The vertical axis shows the relevance of topics for stakeholders in line with the GRI Standards. The top right quadrant shows (in descending order) topics that not only represent relevant impacts by United Internet but are also important to our stakeholders. The renewed analysis of capital market players’ wishes has led to a particular emphasis on these stakeholders.
The square boxes show the business relevance of the topics as defined by the CSR-RUG: Topics that have been assigned red boxes are directly relevant to the business, as can be seen from the fact that they are included in financial reporting, e.g., as part of the Risk Report. Grey boxes are used to denote topics that are currently indirectly relevant to the business if an expanded definition of risk is used (i.e., if regulatory, social, and capital market expectations are used as indicators).
Materiality Matrix: United Internet's Sustainability Topics
An overview of how the topics identified are linked to the non-financial aspects under the CSR-RUG and of the action areas they are addressed in is given in the section entitled “Materiality Analysis: Topics and Action Areas.”
In addition, the table entitled “GRI Content Index and CSR-RUG Disclosures” links the statutory requirements with the GRI requirements.
The CSR-RUG also requires the principle risks to be reported that are linked to the Group’s operations or to its business relationships, products, and services that are highly likely to cause material adverse impacts on the abovementioned aspects, to the extent that these risks are necessary for an understanding of the organization’s development, performance, and position, and of the impacts on the abovementioned aspects. Please see the Risk Report in the Group’s Annual Report, which presents the centrally managed risk management system.
See the United Internet Group’s Annual Report.
United Internet’s Sustainability Report is published annually. This report covers the fiscal year from January 1, 2020, to December 31, 2020. Where appropriate, prior-period figures for fiscal years 2018 and 2019 are presented or outlooks are given, as required under the GRI Standards. Such places are specifically indicated.
Since this is the Sustainability Report for the United Internet Group, the statements it contains apply in principle to all divisions and locations, and to all subsidiaries in which United Internet holds a majority interest. Where individual disclosures do not yet apply to all companies, locations, and areas covered by this report, this is indicated. We intend to continuously expand the data pool on which the reporting is based. The previous report was published in April 2020.
Preparation, Publication, and Examination of the Sustainability Report
The non-financial statement taking the form of this Sustainability Report is prepared and published by United Internet AG’s Chief Financial Officer on behalf of the Company’s Management Board. In the course of its subsequent independent examination, the Supervisory Board addressed the Non-financial Report as a whole in depth and examined it for compliance with the law, propriety, and appropriateness. The Supervisory Board critically reviewed the context of the non-financial statement and discussed it with the Management Board, which was available to answer supplementary questions and provide additional information. Following its own examination, the Supervisory Board came to the conclusion that there were no grounds for any objections to the non-financial statement.
This report will be publicly available in German and English in early April 2021 as a PDF download on United Internet AG’s website.
See the “Reports” on United Internet’s website.