✓ It is hard to imagine society, politics, and business today without mentioning “sustainability,” which can be defined in simple terms as ensuring that the needs of both current and future generations can be met. It therefore comes as no surprise that ESG topics also influence our Company. We aim to take changed expectations within society (such as those voiced by the Fridays for Future movement), consumer and client requirements, employees’ wishes, and increasing investor awareness of ESG aspects into account in our decisions and actions. The associated transformation processes are being discussed widely across different sectors, e.g., in connection with questions relating to data privacy, how to deal with (fake) internet news, the changing world of work, or the transition to a low-carbon economy.
Our sustainability management activities aim to address the challenges and opportunities offered by our material sustainability topics. ✓
✓ The United Internet Group’s group-wide sustainability management activities in 2022 were coordinated by a team from the Compliance & Sustainability department. Their tasks include strategic development, reporting, and answering ESG rating agency queries. Group Sustainability provides advice to and coordinates with the segments by liaising with the sustainability managers there, and with the core functions and relevant specialist departments. The Sustainability team helps them assess nonfinancial topics in their individual business activities, provide information, and ensure that the entire Group complies with its business responsibilities. The segment sustainability managers report periodically – in some cases weekly – to the Management Board member responsible for them and several times a year to the full Management Board and other bodies within the individual segments.
Group Sustainability reports to United Internet AG’s CFO, who is also responsible for preparing the sustainability report for the entire Group. Core principles such as using green electricity or the Diversity Statement are resolved by the Group Management Board. Overarching decisions – including the development of a Group-wide sustainability strategy (starting in the reporting period) – are also made by Group-level management bodies. However, the majority of concrete decisions relating to implementation affect the segment management boards. For example, it is they who resolve to roll out management systems and what the green electricity strategy should look like in practice. They also set most sustainability goals and targets, since the individual segments’ starting positions and the impact they have may vary. United Internet’s Supervisory Board discharges its duty of oversight by examining the consolidated nonfinancial report (“nonfinancial report”), and are assisted in this by an independent external review. ✓
✓ Our ability to do business depends on cooperating successfully with a wide range of stakeholders. Our dialog with different stakeholder groups also helps us assess our impact on society and the environment, identify material sustainability aspects during our materiality analysis, develop our sustainability strategy, set goals and targets, and determine whether they have been reached. We use a variety of different platforms and formats to liaise with our stakeholders, so as to deepen communication and cooperation with them and take their interests into account:
(1) Verband der Anbieter von Telekommunikations- und Mehrwertdiensten e.V.
(2) Bundesverband Informationswirtschaft, Telekommunikation und neue Medien e.V.
(3) Bundesverband Breitbandkommunikation e.V.
(4) Bundesverband Digitale Wirtschaft (BVDW) e.V.
(5) Verband der Internetwirtschaft e.V.
✓ We performed a new materiality analysis that is aligned with the future requirements of the CSRD in the 2022 reporting period. We were supported in our work by an external consulting firm that specializes in performing materiality analyses and developing sustainability strategies, among other things. Both external and internal perspectives were taken into account when examining potential material topics. ✓
✓ The materiality analysis was based on known topics derived from our sustainability management activities to date and from earlier materiality analyses. The list of relevant sustainability topics was updated in the reporting period in the course of stakeholder and benchmark analyses covering political, economic, social, technological, statutory, and environmental aspects. Additional input came from our dialog (interviews) with the stakeholder groups mentioned earlier. The relevant sustainability aspects were also discussed with our internal specialist departments (e.g., Human Resources, Compliance, and Information Security). In many cases this took place at both Group and segment level, while the Management Board members also took part. The topics on the updated list were then defined in more detail together with experts from the departments that are primarily responsible for them, and a uniform understanding of them was developed. Finally, a scoring model was used to assess the materiality of the various topics along the core value chain.
The materiality analysis was performed in line with the requirements of the HGB. The principle of double materiality under the Corporate Sustainability Reporting Directive (CSRD), which will apply throughout the EU in future, was incorporated already by examining both the relevance of topics for United Internet’s business and the potential and actual impact of our activities on the environment and society. No risk management measures were taken into account when examining potential effects (gross risk assessment). The final assessment of the topics was performed in a joint workshop with all specialist departments involved.
Employees’ views on the relevance of the sustainability topics were polled in a survey. In addition, virtual one-on-one interviews were held with internal and external stakeholders so as to examine the materiality of the topics from the stakeholder perspective as well.
Employees’ views on the relevance of the sustainability topics were polled in a survey. In addition, virtual one-on-one interviews were held with internal and external stakeholders so as to examine the materiality of the topics from the stakeholder perspective as well. ✓
✓ The materiality matrix presents the results of the analyses and provides a consolidated overview of the double materiality assessment. The topics indicated in red in the matrix have been defined as material.
The topics of responsible corporate management, working conditions, and diversity, inclusion, equality, and accessibility were defined as material because of their high business relevance scores. In addition, two environmental matters – decarbonization and material efficiency and circularity – have a significant impact on society and the environment. Data privacy, information security (“cybersecurity” in the materiality matrix), and digital participation were assessed from the perspective of double materiality. In addition, we consider supply chain responsibility to be a material topic.
The material topics cover environmental matters, employee-related matters, social matters, respect for human rights, and anti-corruption and bribery matters (see “Information about CSR-RUG requirements” in the Annex).
All topics in the materiality matrix for earlier reporting periods can be assigned to topics from the current matrix. They have merely been structured, named, and assessed differently in some cases on the basis of the new, more refined methodology used. Two new material topics – material efficiency and circularity, and inclusion and accessibility – were added as a result of the materiality analysis performed in the reporting period. In addition, the current matrix contains a number of new topics that were not assessed as being material – transparency and communication, biodiversity, training and education, and social commitment. ✓
✓ At present, we are revising our sustainability strategy based on the insights gained from the current materiality analysis.
We will develop a clear vision and objectives in the course of fiscal year 2023 that will communicate our commitment to material ESG topics. We will combine our activities to date and our future ambitions into concrete action areas that will then form the strategic framework for our sustainability management activities.
One key next step towards implementing our new sustainability strategy – which we shall also take in good time before the first CSRD reporting period in 2024 – is to adapt our sustainability management governance structure with the involvement of our management bodies. We aim to ensure that our sustainability activities are binding and effectively managed by defining responsibilities for topics and action areas, both in the form of central functions and locally in our segments.
We shall build on our strategy to formulate goals for the entire Group, which will then be specified in greater detail and implemented by our segments in the form of milestones and measures. In this way, we aim to make our commitment to sustainability and our level of ambition both measurable and monitorable. ✓
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