SPEAK UP

Bauer Media’s People Code of Conduct (“Code”) sets out the clear principles and behaviours that inform the way we operate as individuals and as a business, every day. The Code tells our leaders, employees, freelancers, customers, partners and suppliers how we at Bauer conduct business, the behaviours we encourage and the standards we set for ourselves and the people we work with.

Our global reporting service, Speak Up, is not only available to all our people, but to any third party too, including but not limited to all external partners, suppliers and stakeholders. This service is dedicated to reporting, investigating and remedying breaches of the law, or potential instances of non-compliance with our Code, as well as human rights and environmental risks at or on behalf of Bauer or our suppliers.

We encourage you to report any honestly-held concerns or suspicions about potential violations of our People Code of Conduct, our Supplier Code of Conduct, our internal policies, or any misconduct related to – or by – Bauer.

You will not suffer any adverse consequences when you report a possible violation in good faith. All information on how to raise a concern can be found in the following overview.

Bauer Media’s Speak Up Reporting Service is operated by an independent service provider – People Intouch BV – and is available 24 hours a day, seven days a week. You can access it whenever you need to and can communicate through the system in your native language. The service is governed by the terms of our Speak Up Policy. Please also be aware of our privacy notice.

You can access the Speak Up Reporting Service via: https://bauermediagroup.speakup.report/bauerspeakup.

We hope that you will feel able to voice your concerns openly, but if you feel it is necessary, you can choose to report your concerns anonymously.

Please note: while every effort will be made to robustly review and investigate all reports, those received from anonymous sources may be more difficult to follow up. If you opt to report anonymously, we strongly encourage you to include as much information as possible to enable Bauer to respond effectively to your concerns. It may not always be possible to fully investigate allegations and reach a conclusion in such limited circumstances.

Your report will be initially assessed by Bauer Media’s Group Compliance Team, who may involve internal and external experts if necessary. The timeframes for investigating reports raised via the Speak Up Reporting Service are likely to vary depending on the nature and complexity of the case. We need to keep our investigation approach flexible to maintain the integrity of the service, however, we aim to operate within the following guidelines:

• acknowledge receipt within seven days;
• ensure that the individual raising concerns is provided with regular updates throughout the investigation (at least one, more where possible)
• aim to conclude investigations, where practicable, within three months.

If we need more information from you, we will ask follow-up questions through Speak Up and you may be invited to a meeting to discuss your concerns. Please keep a note of your case number and password so you can keep receiving information about your report, particularly where you have chosen to report anonymously.

Bauer Media’s Executive Board is committed to the principles of our Speak Up Policy and we will take all necessary steps to ensure that you will not suffer unfair treatment, retaliation or victimisation as a result of reporting your honestly-held concerns.

Should you choose to use our Speak Up Reporting Service, we will take all practical measures to protect your identity. We will not disclose your identity without consent, unless legally required to, and will prohibit attempts to identify you.

If you notice or experience any form of retaliation, such as unfair treatment or victimisation, please report this via the Speak Up Reporting Service or by contacting a member of the Group Compliance Team: groupcompliance@bauermedia.com.

By law, in some circumstances you can report reasonable suspicions of unlawful conduct to an external body. Please follow this link to learn more about the competent authorities in each Bauer Media Group territory.