United Internet provides an overview of the internal policies and guidelines that aim to prevent, reduce, or remedy actual and potential impacts for those sustainability matters that have been identified as material. At the same time, the goal is to address and mitigate risks and leverage opportunities. The people responsible for implementing the policies and guidelines constantly monitor their effectiveness.
Compliance Guidelines
Description of the compliance management system (CMS)
Determination of roles and responsibilities in the CMS
Compliance monitoring
Group-wide
Corporate Compliance
Intranet
Data Privacy Policy
Ensuring a uniform level of data privacy at United Internet
Compliance with the GDPR
Personal data is processed on the basis of the objective of data minimization
Personal data is processed on the basis of previously defined purposes
Personal data is stored for as short a period as possible and for as long as necessary, etc.
Segment-specific
Law Enforcement Affairs & Privacy
General Data Protection Regulation (GDPR)
Company Cars Policy
Rules for electrifying the vehicle fleet
Commercial Services
Management Guidelines
Strengthening of responsible behavior by management and focus on role models and team culture
German Corporate Governance Code
Code of Conduct for Business Partners
Requirements to be met by business partners: compliance, integrity, fair competition, information security and data privacy, and intellectual property
Social and environmental due diligence requirementsiEnvironmental protection and climate change mitigation
Group-wide and segment-specific
Corporate Compliance and Corporate Procurement
UN Guiding Principles on Business and Human Rights
Company website
Policy Statement
Principles for respecting human rights and environmental due diligence obligations
Risk assessment for own area of business
Risk assessment for supply chain
Preventive measures, remedies, and controls
Universal Declaration of Human Rights, German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – LkSG), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
Whistleblower Protection Policy
Information on how to submit whistleblower reports
Description of reporting channels
Protection for whistleblowers
The German Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG) is the implementation into German law of the EU Whistleblowing Directive (EU Directive 2019/1937), German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – LkSG)
Information Security Management System (ISMS)
Safeguarding the product environment against unauthorized access and misuse
Group Information Security Officer (GISO) and Segment Information Security Officers (SISOs)
ISO 27001, BSI IT-Grundschutz, BSI C5
Group Policy on the Deployment of Contract Workers
Ensuring an efficient decision-making and procurement process
Determination of responsibilities
Ensuring compliance with the law when deploying contract workers
Corporate Procurement
German Employee Leasing Act (Arbeitnehmerüberlassungsgesetz – AÜG)
Group Policy on Device Use
Enabling long-term use, refurbishment, and recycling of internal hardware
Corporate IT Services
Group Anti-corruption Policy
Rules for accepting and giving gifts and contributions, descriptions of type of gifts and contributions, impacts of breaches
German Anti-corruption Act (Gesetz zur Bekämpfung der Korruption)
ArtificiaI Intelligence Guideline
Introduction of AI requirements analysis during procurement and development processes
Ensuring release procedure for AI systems
Establishment of training offerings to ensure adequate AI skills
Corporate Compliance, Corporate Privacy & Corporate Legal
Regulation (EU) 2024/1689 on artificial intelligence (AI Act)
Guidelines for Implementing Supply Chain Due Diligence (SCDD)
Organizational structures and workflows for implementing the LkSG
Clarity about governance structures
Appropriate and effective implementation of due diligence obligations
German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – LkSG)
Editing Guidelines
Rules for editorial staff; these are made transparent for the public and published
Guidelines on Dealing with Reports of Compliance Violations and Conducting Internal Investigations
Legal basis for internal investigations
Workflow for investigations
Roles and responsibilities
Rules of conduct for internal investigations
Source to Contract Policy – S2C
Guidelines and principles for operational and strategic purchasing
Tendering process
Rules governing demand management, product group management, supplier management, and contract management
Head of Source to Contract
Code of Conduct for employees
Interacting with staff, interacting with customers, information handling, competition law and anti-corruption, conflicts of interest, protection of company property, communication, interacting with public authorities, and compliance at United Internet
ILO labor and social standards
UN Guiding Principles on Business and Human Rights German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz – LkSG) German General Act on Equal Treatment (Allgemeines Gleichbehandlungsgesetz – AGG)
Compensation Policy
Ensures comparable, legally compliant, and fair compensation
Corporate Compensation & Benefit
Policy/guidelines
Description
Scope of application
Responsibility for implementation
National and international standards and legislation
Availability
Links
Downloads
