Scope 1 Emissions
2022 Communication on Progress
Vivendi
Published date
July 6, 2022
No. of questions
61
Supplemental files
Avis EY Comp modifs EY à VA Transmis Havas 03172022.pdfAnti-corruption Code - VA - Septembre 2018.pdfCEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
2. Does the company have a publicly stated commitment regarding the following sustainability topics?
3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentThe Chief Compliance Officer is a member of the Management Board.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Prevention
6. Does the company have a process or processes to assess risk?
Optional commentDuty of Care : A group-wide risk map was also drawn up by consolidating the maps created for each entity. This initiative was based on fifteen risks related to the specific nature of each business and structured Vivendi’s approach to analyzing the group’s businesses and supply chain. The process involved conducting interviews with representatives of operations departments at headquarters, and in the entities, to better describe the risks to human rights, fundamental freedoms, health and safety and the environment that may result from the group’s activities. It also included an inventory of existing policies and action plans aimed at assessing the degree of control over these risks. This assessment was guided by the severity and frequency of each risk and by whether effective Risk Management systems are in place for governance, processes and controls. It also took the size of the various entities into account by applying a weighting factor to the results of the assessments carried out by each business line, thereby producing a more accurate assessment of group risks. The weighting factor reflects the revenues and headcount of group businesses and is adjusted for the impact of their activity. Corruption: Regarding corruption risks, the risk assessment prepared by Compliance Officers and operational officers at the entities and headquarters over the last four years, provides a detailed analysis of the potential corruption risks within all Vivendi group businesses. The controls needed to protect against these risks are also based on the action plans for each risk map, which are designed to strengthen the Risk Management systems already in place within each business. In 2021, the Vivendi group improved its ability to analyze the corruption risks related to its businesses by creating seven more corruption risk maps, bringing the total number of such maps to 23.7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Optional commentThe definition of third-party assessment policies is based on the specific nature of each business. These policies set out the categories of at-risk third parties, the roles and responsibilities of those involved in performing due diligence, and the appropriate process within the business for deciding whether to establish or continue the business relationship. In 2022, this work will continue to focus on rolling out third-party assessment policies and performing due diligence on identified at-risk third parties.Concerns and grievance mechanisms
8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Optional commentDesigned for reporting potential internal misconduct, the whistleblowing system features a platform that is available to all group entities. This system was updated in 2021 in alignment with regulatory changes. Originally designed for violations under France’s Sapin II Act, it now encompasses the requirements imposed by the French duty of vigilance law. Its procedures are in line with the recommendations of France’s data protection authority (CNIL) for whistleblowing systems and with the recommendations of the French National Cybersecurity Agency (ANSSI) for information system security. Reports are received and handled in accordance with detailed procedures for whistleblowers and those authorized to investigate reports. These procedures guide investigators in determining the seriousness and severity of a report and provide a framework for any further investigation.8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?
Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentAccording to French governance rules, the detailed board calculation for Women/Men and Independent members ratios exclude the 2 board members representing the employees13. Do you produce sustainability reporting according to:
Optional commentVivendi's Non-financial reporting protocol is based on national and international references including the guidelines of the Global Reporting Initiative (GRI) and its Media Sector Supplement of May 4, 2012, even if we do not report our activities following the GRI framework preciselyData Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
2.1. For each human rights policy, is it:
Prevention
3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?
4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?
5. Who receives training for the following human rights issues?
Optional commentTraining can take different forms (intended for all employees or only for selected employees), depending on the themes it covers and/or on the target population.6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
Gender equality Gender equality is one of Vivendi’s top commitments, advocated by its Supervisory Board and all group entities. Vivendi firmly upholds the importance of gender parity and diversity within management. It is determined to raise the percentage of women in top roles in all group entities by implementing specific initiatives promoting women and gender parity. The proportion of women in the group’s management bodies was 35% in 2021(…) Pursuant to Article 7 of the AFEP-MEDEF Code as amended in January 2020, at its meeting on November 18, 2021, Vivendi’s Management Board, upon the recommendation of the Supervisory Board, increased the target for the proportion of women in the management bodies of the group, whose businesses have varying gender parity levels, to 38% for 2022 and 40% for 2023. (…) As part of the United Nations’ HeforShe movement, in 2021 Havas Group pledged to use every effort to try to increase the representation of women in creative senior management positions from 27% to 45% or higher by 2025, to measure the gender pay gap and to close any gaps identified. Specific initiatives promoting women’s career development and gender equality Vivendi has implemented a general policy to break the glass ceiling and increase gender diversity in management positions. This policy is centered around the Andiamo women’s network created in March 2012, at the request of the Supervisory Board, for women holding positions of responsibility to promote them to managerial positions, by offering them group and individual coaching sessions. In addition to developing individual leadership, Andiamo is also a community of shared resources where its members can exchange information, experience and management practices. Made up of about 60 women, the network also acts as a space for testing new leadership approaches. Andiamo has built on the Learning Expedition program (see Section 4.3.1.3.) to become another support network that furthers group projects. Other programs and actions to develop women’s leadership and behavioral change are implemented at the entity level. Since its creation in 2018, more than 150 women from 57 agencies in 23 countries have taken Havas Group’s Femmes Forward program, to promote women in management positions. With the digital career advancement platform Femmes Forward ON AIR introduced in 2021, Havas Group continues to offer women worldwide the chance to enhance their leadership skills and consider what they want from their career. By year-end 2021, Femmes Forward ON AIR had launched in the United Kingdom, Latin America, France, Belgium and Asia-Pacific, with nearly 100 participants. Other initiatives, such as Fight Club, launched by Havas Health and You, reflect Havas Group’s will to actively promote leadership among women. Canal+ Group started a women’s leadership program, known as Boost’Her, which about a hundred women have joined since its creation. It leads an active policy to improve the promotion of women and change mindsets, especially through Sister’s Day. This event is open to all women in the group who want to work on their professional goals and lift unconscious biases holding them back. In 2021, Gameloft launched the She Plays program, a community of women leaders that aims to raise the profile of women in an industry where they are underrepresented, shifting mindsets and attracting female talent to the industry. Vivendi aims to achieve equality at every level of the organization and at each step in the career path of its employees – recruitment, promotion and development. This objective is shared by all business lines and has been identified and developed into multiple forms of action, according to the specific needs of their businesses and culture. Vivendi’s commitment to this issue has led to the implementation of action plans and social progress measures going beyond the existing provisions. These action plans work toward several goals: promoting gender parity in recruitment and respecting equality in terms of access to employment; ensuring equal opportunities in career development; guaranteeing equal pay between men and women performing the same jobs at the same skill level and with the same level of accountability and results; guaranteeing equality in terms of professional development and pay increases in the event of a career interruption for parental, maternity, paternity or adoption leave; and striving for a better work-life balance. Most of the group’s French entities have accordingly signed agreements on gender equality, including: ► agreements or action plans on gender equality at work, pursuant to the French Law of March 23, 2006 on the implementation of comprehensive measures (recruitment, promotion, compensation and maternity leave) and metrics to monitor the mechanisms put in place; ► parenting agreements or charters advocating equal treatment of both parents; and ► agreements on working hours to facilitate a work-life balance and measures to promote parental leave, including for men. In France, Vivendi is taking further steps to promote gender equality by offering to maintain 100% of the salary of employees on second-parent leave for the entire duration of the leave. This measure may exceed the basic legal entitlement at certain entities such as Canal+ Group and Dailymotion. (…) Among the business line initiatives, Canal+ Group, Prisma Media and Dailymotion have decided to systematically take into consideration for any vacant job position at least one woman and one man and have eliminated periods of maternity leave from the annual assessment, identified gaps in equal pay for equal work and taken remedial action. Havas Group is also committed to an active policy on equal pay for women and men. Its three-step action plan starts with an assessment before making the necessary adjustments and implementing a follow-up.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
1.1. For each labour rights policy, is it:
Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?
3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?
Optional commentFreedom of association and the effective recognition of the right to collective bargaining Since this matter is not a risk at the Vivendi group, we do not collect the actions nor initiatives associated with this matter. Nevertheless, “as part of its labor policy and in compliance with the ILO fundamental conventions, Vivendi prioritizes ongoing, constructive dialog with employees and their representatives by promoting exchange and consultation at all levels.” (AR-URD 2021 page 94) All the business lines of the Vivendi group have these same priorities and “within the entities, dialog and social discussion are organized in line with the employment laws and regulations for each country, and in accordance with human resources policy guidelines adopted by each business line.” (AR-URD 2021 page 95) Forced labour + Child labour Not material for Vivendi: we do not collect actions on this matter; all the business lines of the Vivendi group must abide by legal and regulatory obligations in force on these matters.4. Who receives training for the following labour rights issues?
Optional commentForced Labour and Child Labour are not material for Vivendi : we do not collect actions on this matter; all the business lines of the Vivendi group must abide by legal and regulatory obligations in force on these matters.5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentSince “freedom of association and the effective recognition of the right to collective bargaining” is not a risk identified for the Vivendi group this data is not audited by our Independent Third Party (EY) nor disclosed in our AR – URD 20217. What is the percentage of employees in a trade union or other workers' organization?
Optional commentWe do not collect the number of employees in a trade union or on a worker committee. Nevertheless, we know that 52% of staff have the possibility to benefit from Staff representation and/or from Union representation in 2021 in the Vivendi group. Since “freedom of association and the effective recognition of the right to collective bargaining” is not a risk identified for the Vivendi group this data is not audited by our Independent Third Party (EY) nor disclosed in our AR – URD 20218. In the course of the reporting period, what was the percentage of women in:
Optional commentAccording to French governance rules, the detailed board calculation for Women/Men excludes the 2 board members representing the employees9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Optional commentWe are in the process of constructing the indicator at the Vivendi Group level10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentThe Frequency rate of workplace accidents is calculated as follows: Number of workplace accidents resulting in lost work time x 1,000,000 Average annual headcount x annual hours actually worked (please refer to our AR – URD 2021 page 108, section “Health and safety”)11. In the course of the reporting period, what was the company’s incident rate?
Optional commentThe Severity rate of workplace accidents is calculated as follows: Number of days lost due to workplace accidents x 1,000 Average annual headcount x annual hours actually worked (please refer to our AR – URD 2021 page 108, section “Health and safety”)Response and Reporting
12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?
13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
Freedom of association and the effective recognition of the right to collective bargaining Since this matter is not a risk at the Vivendi group, we do not collect the actions nor initiatives associated with this matter. Nevertheless, “as part of its labor policy and in compliance with the ILO fundamental conventions, Vivendi prioritizes ongoing, constructive dialog with employees and their representatives by promoting exchange and consultation at all levels.” (AR-URD 2021 page 94) All the business lines of the Vivendi group have these same priorities and “within the entities, dialog and social discussion are organized in line with the employment laws and regulations for each country, and in accordance with human resources policy guidelines adopted by each business line.” (AR-URD 2021 page 95) Non-discrimination in respect of employment and occupation From a Vigilance perspective, the group-level mitigation measures were (please refer to the table on page 74 of our AR - URD 2021): “► Measures in place: – a system for tracking harassment and discrimination reports – training modules for employees in certain entities – presence of harassment and discrimination representatives in the businesses ► Measures to be implemented: – draw up an inventory of all existing measures within the group and support training initiatives in the entities (e.g., carrying out initiatives to raise employee awareness and adding a course on harassment and discrimination to the training plan for managers)” From a HR perspective, the actions within our group were (please refer to the “Respect for human rights and fundamental freedoms” section of our AR - URD 2021 page 99): “Havas Group has integrated harassment prevention into its social policy by defining three priority areas of action: training, counseling and whistleblowing systems, and engagement from its executive management. An awareness session on these issues aimed at all managers was organized in 2019, which included simulation exercises featuring real-life situations. The initiative was tremendously effective and will be repeated in 2022. The mandatory training module has been included in the induction process to ensure that all employees are trained on these matters. Other related modules are available on the Havas University training platform to expand the offering. Canal+ Group introduced a whistleblowing system in line with its collective agreement on quality of life at work and informed all employees about the procedure. In 2021, all managers received training on preventing harassment, and an e-learning module is available for all employees on Campus Canal. Canal+ Group has also signed the #StOpE charter on everyday sexism in the workplace and is committed to reducing it by deploying information, training (including the #StOpE e-learning program available on Campus Canal), prevention and support initiatives among its employees, and a zero-tolerance approach. In 2019, Canal+ Group teamed up with Havas Worldwide to address this topic by signing the charter to combat sexual harassment and sexist behavior with the organization Pour les femmes dans les médias (PFDM). They have since been joined by three other group entities: Vivendi SE, Dailymotion and Prisma Media. Their commitments in this regard include informing employees, providing a support/whistleblowing system for victims and sharing their best practices. Editis has introduced a Code of Conduct and a whistleblowing system. It has also designated and trained HR correspondents in each of its three divisions – Literature, Education and Reference, and Broadcasting and Distribution – to prevent harassment and discrimination. Gameloft has drawn up a Corporate Charter, to be issued to all new employees, that sets out the principles and values to be respected. As of 2018, Prisma Media implemented mandatory training for managers and HR staff on preventing harassment, and regular awareness talks are available for employees. In 2021, a mini-series of seven videos featuring situations of sexual harassment and sexist behavior were put online to raise employee awareness. Prisma Media reissued its communication to its employees about the new whistleblowing system when it joined Vivendi group. In France, a number of entities included provisions on sexual harassment and bullying and/or the principle of non-discrimination in their internal rules. In addition, at a number of entities, particularly those located in English-speaking countries, employees have access to a whistleblowing hotline, in accordance with applicable rules and regulations, for reporting any instances of discrimination or harassment.” Occupational Health & Safety + Working conditions From a Vigilance perspective, the group-level mitigation measures were (please refer to the table on page 75 of our AR - URD 2021): “► Measures in place: – a plan for preventing stressful situations arising from organizational constraints, workload or other issues – conferences and webinars on health and wellness, surveys and polls on various themes (such as managing remote work) – establishment of a mental health counseling hotline or a medical teleconsultation service – preventive measures related to the public health crisis (e.g., employee information, prevention of psychosocial risks and counseling unit) ► Measures to be implemented: – assess occupational health and safety measures throughout the group (e.g., processes and responsibilities) and define appropriate action plans” From a HR perspective, the actions within our group were (please refer to our AR - URD 2021: the “Quality of life at work, well-being, and health and safety in the workplace” on page 94, and the “Compensation, profit-sharing and employee shareholding” section on page 95): “Quality of life at work, well-being, and health and safety in the workplace Vivendi has spent several years implementing a strategy for improving quality of life at work and guiding its employees toward new work organization methods that facilitate collaboration, agility and cross-functionality. Work environments are becoming more flexible and, in contributing to improving people’s quality of life, they also contribute to improving the performance of employees and of the group. (…) Health and safety in the workplace are key concerns for all business lines, and they all implement action plans and preventive measures, adapted to their activities, in compliance with local laws and regulations and the vigilance plan (see Section 3.2.2.). These action plans are processed and monitored by committees or task forces in charge of handling workplace health and safety issues. (…) Preventive measures taken to manage the various stages of the current health crisis are still in place: employee information; prevention of psychosocial risks, counseling units and internal surveys; prevention of musculoskeletal disorders, especially with more people working from home; and implementation of specific health measures. In this complex work environment due to the ongoing pandemic, Vivendi continues to stress the importance of taking care of its employees and protecting their mental health by implementing initiatives and actions such as: ► regular communication with senior management, managers, HR, etc., as well as, when possible, times for discussion or relaxation; ► meetings and webinars on health and wellness that cover topics like time management, emotions, relationships with others, rest time, exercise, etc.; ► questionnaires and surveys that collect information on employee needs and emotions regarding a range of themes, such as managing remote work; ► establishment of an anonymous mental health counseling/assistance hotline for employees or a telephone medical consultation service; and ► training for managers on how to recognize signs of anxiety and depression and to combat employee loneliness. In October 2021, Havas Group launched Be Kind to Your Mind, a global initiative to support its employees’ mental well-being. The program is built around four pillars: a commitment from executive management, training sessions on these topics, Wellness Wednesdays and a network of volunteers dedicated to protecting the well-being of employees. Havas Group has also implemented the Take Five initiative, a rule under which employees are given five minutes between each meeting to help them better manage stress and fatigue. Vivendi has taken action to promote the well-being of its employees whose work-life balance has been disrupted by health measures taken to cope with the pandemic. For example, it offers all employees based in France the opportunity to use the Campus Parentalité educational support program, already rolled out within Editis in 2019, and thus participate in online conferences such as “Combining family life with professional development” or “Managing my children’s relationship with screens”. Compensation, profit-sharing and employee shareholding Vivendi takes steps to offer its employees attractive and motivating compensation based on their skills and their personal contributions to the company’s performance. The compensation policy is based on principles of fairness and non-discrimination and is designed to reward individual, as well as collective, performances. The HR teams take part in positioning surveys and regularly analyze its employees’ compensation to ensure its relevance to the company and to compare it to market rates so that entities have the means to retain talent and attract new promising profiles. Vivendi also places particular importance on the equitable distribution of the value created by its employees’ efforts. The group has therefore established a profit-sharing policy that encourages the development of employee savings plans, especially through employee shareholdings. In 2021, the total net amount received by employees of the group’s French entities under optional and statutory profit-sharing plans and the employer’s contribution was €29.9 million, which represents a total expense of approximately €40 million for group entities, 77% of which was invested. (…)"Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
1.1. For each environmental policy, is it:
Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?
3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?
Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentScope 1 Emissions = 14 764 Scope 2 Emissions = 23 430 Scope 3 Emissions = 111 6226.1. Which Scope 3 categories are included in the organization’s scope 3 emissions calculation?
7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Overall Environment
21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.
The Creation for the Planet pillar of Vivendi’s CSR program focuses on fighting climate change, in line with the Paris Agreement, and protecting the environment. After signing on to the Science-Based Targets initiative (SBTi) in 2020, the group redoubled its commitment by joining the Business Ambition for 1.5 °C campaign in February 2021. It also submitted its carbon reduction plan to SBTi in December 2021 for review and approval before year-end 2022. The group will release the details of its decarbonization action plan once SBTi validates its targets. First of all, Vivendi aims to reduce its GHG emissions across its value chain, including Scope 3 activities related to its suppliers’ operations and customers’ use of the products and services of the group’s entities. The four main sources of Vivendi’s GHG emissions are, in order of importance: ► 1: purchases of goods and services (Scope 3); In 2020, the group strengthened supplier commitment to its environmental initiative by implementing a responsible purchasing Charter. Under the group’s carbon reduction plan, and as part of the process of having SBTi validate its carbon reduction targets (see Section 4.1.1.), the group will work more closely with its suppliers on environmental concerns in 2022. In keeping with its commitment to produce audiovisual content more responsibly, Canal+ Group introduced a charter of environmentally responsible production principles. The charter includes recommendations on limiting transport, waste production, energy consumption of equipment, etc., and is included in all its prepurchase and co-production contracts in France. Similarly, Editis encouraged printing companies to commit to an improvement strategy, particularly for the makeready process. ► 2: the use of products and services sold (Scope 3); The protection and renewal of natural resources are essential for their conservation. Natural resource consumption is a key challenge for Vivendi and some of its business lines, whose operations and products consume a significant amount of paper and plastic. Paper, the group’s most widely used resource Paper is the main resource consumed by the group (over 43,000 tons were used in 2021), especially for printing Editis books and Prisma Media magazines. The group’s purchasing policy recommends paper certified by the Forest Stewardship Council (FSC®) or the program for the Endorsement of Forest Certification (PEFC), which guarantee responsible and sustainable forest management and help fight deforestation. In 2021, 98% of the paper used by the group was FSC®- or PEFC-certified. To limit its paper consumption, Editis is also implementing an improvement strategy aimed at reducing the number of unsold copies by fine-tuning book placements and adjusting print runs. Editis also negotiated agreements with printing companies to improve the makeready process and reduce paper waste throughout the entire manufacturing process. Finally, in keeping with its preference for buying local, more than 99% of Editis’s paper suppliers are in Europe (with 20% produced in France). Plastic Plastic is the second most widely used resource in the group and is primarily used for Canal+ Group’s set-top boxes. Canal+ Group’s technical and marketing teams are integrating eco-design principles into the design and production process to reduce its equipment’s environmental impact. For example, the casing for the latest generation of set-top boxes, designed in 2021, is made with more than 90% recycled plastic, while the box itself is now smaller. The boxes have also been made lighter, which reduces the GHG emissions produced by shipping them. As for packaging, all protective bags and films, plastic ties and rarely used cables will be eliminated in 2022. The development of Over-the-Top (OTT) services such as myCanal, which allow customers to view Canal+ Group content without a set-top box, also helps reduce plastic consumption. Digital In 2018, the digital industry accounted for approximately 3.7% of the world’s total GHG emissions. In France, it is estimated that by 2040 these emissions could increase by 60% to reach 6.7% of the country’s total emissions. Given the above, the group’s technical and digital teams are developing ambitious solutions to limit bandwidth consumption and increase the energy efficiency of network infrastructure and equipment. According to a study conducted in December 2020 by Canal+ Group, in partnership with Greenspector (a company that focuses on the environmental impact of digital services) and Evea (a company that analyzes the environmental impact of products), streaming one hour of video on the myCanal platform generates 28 grams of CO2 equivalent. Based on this benchmark, Canal+ Group set itself the goal of reducing the carbon footprint of video consumption in mainland France by at least 30% by year-end 2023. The technical and digital teams launched ambitious projects to integrate the latest content encoding and broadcasting technologies and minimize streaming’s carbon footprint while maintaining the user experience. Dailymotion worked to make its software more efficient and less energy intensive by refining its source code, which means fewer servers are needed to run it. Gameloft’s data center in Montreal, which is 99% powered by renewable energy, is another example of Gameloft’s commitment to reducing its environmental impact. Other resources and circular economy initiatives In general, Vivendi entities systematically ensure that waste is treated in compliance with the local environmental standards in force. Some entities go further and take a circular economy approach to ensure optimum use of natural resources and prevent their depletion in the medium-term. Consequently, Canal+ Group’s policy aims to extend the life of its equipment through re-use and by optimizing end-of-life processing. In France, logistics teams have been collecting and recycling set-top boxes since the channel was launched more than 35 years ago. If the equipment returned by subscribers meets the group’s technical requirements, it is tested and reconditioned to be put back into service. In Togo, Benin and Mali, initiatives to recycle old set-top boxes were set up in 2018, in partnership with a company that recycles waste electronics. In total, these initiatives have collected nearly 25 tons of equipment since they were launched. Dailymotion is working to relieve the pressure on rare metal supply by extending the life of its data servers beyond their warranties. While the industry standard is to replace servers an average of every 4 to 5 years, Dailymotion uses them for up to 7 to 11 years at the cost of higher maintenance. ► 3: energy consumption by its sites (Scopes 1 and 2); For several years now, the Vivendi group has been committed to controlling its energy consumption and getting its buildings environmentally certified. In 2021, the group brought all of its initiatives together under a common Sustainable Buildings program aimed at improving the environmental and energy efficiency of the group’s buildings, thereby reducing the carbon footprint of its sites. This program is based on implementing internationally recognized environmental management standards (ISO 14001, ISO 50001) or sustainable building certifications (e.g., HQE®, BREEAM® and LEED®). In 2021, more than 20% of the group’s workforce was covered by ISO 14001 or ISO 50001 environmental certification, and a number of the group’s sites also held sustainable building or other forms of certification (e.g., generalist, sector-based and local) with an environmental component. The HKX building in London, which houses around 20 Havas agencies, and the Editis head office in Paris have Building Research Establishment Environmental Assessment Method (BREEAM) certification. Gameloft in Montreal has offices in LEED (Leadership in Energy and Environmental Design) certified buildings and has received the Environmental Award from GamesIndustry.Biz for its efforts to promote a more environmentally friendly workplace. In addition to certifications and labels, various solutions are being implemented to reduce building energy consumption and the carbon impact of the energy mix. Energy consumption by the buildings that the group owns or rents to accommodate employees and customers (including office space, warehouses, stores and performance venues) is the third largest source of the group’s GHG emissions. The use of renewable energies is one of the solutions implemented by the group and its entities to reduce its carbon emissions. Consequently, many group entities draw their electricity from renewable sources, including Canal+ Group for its stores in Africa, Studiocanal in Germany and M7 for its head office in the Netherlands, Gameloft for its studio in Canada, Dailymotion for its two data centers in the Île-de-France region, and Havas Village in France, Spain and the United Kingdom, where it shares its offices with Studiocanal. In 2021, over 18% of the electricity used by the group was generated using renewable energy sources In addition, several entities use motion detection systems to limit their use of artificial lighting, air conditioning and water, or they have renovated to improve their thermal insulation or upgraded their lighting systems by installing more energy-efficient LED lighting (l’Olympia, See Tickets). ► 4: business travel (Scope 3). Business travel is essential for establishing and maintaining effective and productive relationships with the group’s various stakeholders (including artists, producers, customers and business partners) and is therefore common in Vivendi’s businesses. Although business travel is still impacted by the Covid-19 pandemic, the group’s various employees traveled nearly 47 million kilometers for work purposes in 2021. Initiatives are being developed both globally and locally to reduce the GHG emissions resulting from these trips. For local travel, employees are encouraged to use more environmentally friendly modes of transportation, such as public transit or bicycles. Certain contracts with taxi or vehicle-for-hire companies were negotiated to include clauses offering an electric or hybrid vehicle at no extra cost when possible. The Purchasing Department continued to work with the business divisions to reduce the carbon footprint of the group’s company cars. This initiative began several years ago by gradually replacing vehicles in use with lower-pollution, electric or hybrid models. Remote work agreements were also put in place within various entities in 2021. Aside from improving work-life balance, remote working significantly reduces the transport-related carbon footprint. The group therefore expanded its rollout of Microsoft Teams, video conferencing equipment and remote collaboration tools. Initiatives were also launched to reduce GHG emissions from commuting: Havas Sports & Entertainment provided its employees with company bicycles; Editis rolled out a carpooling application for its headquarters in Paris and installed charging stations for electric vehicles. Lastly, Canal+ Group partnered with the SoliCycle organization to hold two bicycle repair workshops at its locations in the Île-de-France region. In 2022, the group will continue its efforts to reduce GHG emissions from business travel.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentYes, Vivendi has an anti-corruption program based on an anti-corruption code and various policies implemented in order to reduce the corruption risk. Corruption Risk Management is based on an anti-corruption policy implemented within the group. It uses tailored measures and procedures that focus on four objectives: risk identification, risk prevention, risk detection and the implementation of control measures. See page 72 URD 2021 Section 3 “Business ethics and compliance”.2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
Optional commentAs the foundation of the group’s anti-corruption policy, the Anti-Corruption Code sets out the group’s commitments to ethics in its business conduct. These rules apply to all employees in every country where the group operates. The Anti-Corruption Code has been translated into 24 languages so that each individual can understand the prevention measures it contains. The group’s businesses have adopted the Code as part of their Internal Regulations, which means employees are bound by it. It can also be found on the group’s intranet and website. Vivendi’s Anti-Corruption Code addresses situations identified during the risk mapping process and sets out a Code of Conduct. It takes into account applicable local rules and Regulations in countries where the group is present, particularly the Foreign Corrupt Practices Act (FCPA) in the United States and the UK Bribery Act. To help group employees better understand situations that could present a risk, several procedures have been defined to round out the implementation of the Anti-Corruption Code. For example, it establishes rules of conduct in cases such as conflicts of interest. If individual employees have any questions regarding a specific situation, they are asked to refer to their direct superiors or notify the Compliance Officer. A stand alone policy exists for gifts and invitations and the same procedure will soon be implemented for conflict of interest. This anti-corruption code has been set-up in 2018 but the anti-corruption program has evolved over the years (latest version in 2021).Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentAn online training module dedicated to anti-corruption issues helps employees gain a better understanding of at-risk behavior and of anticorruption policy rules. New employees must take this training, which can be found in the onboarding handbook provided to them when they join the group. At year-end 2021, 83% of employees had completed the module. Special classroom training is also provided to General Management of businesses and to employees who are more exposed to corruption risk due to the nature of their duties. The content of these training courses and the identification of their beneficiaries is based on the work carried out upstream during the preparation of corruption risk maps and action plans. In 2021, Canal+ France and Studiocanal focused on the functions of the purchasing, sales, finance and strategy, public relations and production departments. In 2022, the group’s businesses will continue their efforts to provide classroom training for the employees most exposed to corruption risk. To highlight the commitment of group Management to raise employee awareness about corruption and corruption risks, training is one of the criteria used to determine the variable compensation of Vivendi’s Management Board members and managers at Vivendi SE.3.1. How often is such training provided?
4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Optional commentDesigned for reporting potential internal misconduct, the whistleblowing system features a platform that is available to all group entities. This system was updated in 2021 in alignment with regulatory changes. Originally designed for violations under France’s Sapin II Act, it now encompasses the requirements imposed by the French duty of vigilance law. Its procedures are in line with the recommendations of France’s data protection authority (CNIL) for whistleblowing systems and with the recommendations of the French National Cybersecurity Agency (ANSSI) for information system security. Reports are received and handled in accordance with detailed procedures for whistleblowers and those authorized to investigate reports. These procedures guide investigators in determining the seriousness and severity of a report and provide a framework for any further investigation.7. Does your company engage in Collective Action against corruption?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
The anti-corruption policy implemented within the group uses tailored measures and procedures that focus on four objectives: risk identification, risk prevention, risk detection and the implementation of control measures. Anti-corruption action plans are implemented for Vivendi SE and its subsidiaries based on corruption risk mappings. Risk identification : The risk assessment, prepared by Compliance Officers and operational officers at the entities and headquarters over the last four years, provides a detailed analysis of the potential corruption risks within all Vivendi group businesses. The controls needed to protect against these risks are also based on the action plans for each risk map, which are designed to strengthen the Risk Management systems already in place within each business. Risk prevention : The Anti-Corruption Code sets out the group’s commitments to ethics in its business conduct. These rules apply to all employees in every country where the group operates. It addresses situations identified during the risk mapping process and sets out a Code of Conduct. It takes into account applicable local rules and Regulations in countries where the group is present, particularly the Foreign Corrupt Practices Act (FCPA) in the United States and the UK Bribery Act. Several procedures have been defined to round out the implementation of the Anti-Corruption Code. For example, procedures for handling gifts and invitations were adapted for all group entities. An online training module dedicated to anti-corruption issues helps employees gain a better understanding of at-risk behavior and of anticorruption policy rules. New employees must take this training, which can be found in the onboarding handbook provided to them when they join the group. Special classroom training is also provided to General Management of businesses and to employees who are more exposed to corruption risk due to the nature of their duties. In 2021, the process for assessing the integrity of third parties, which covers suppliers, subcontractors, customers and intermediaries, consisted of assessing the specific risk involved in maintaining the established or potential relationship with a business partner. The group’s businesses each analyzed its risks in detail. Third-party risks were mapped based on specific risk criteria (e.g., third party category, revenue generated and location) to identify the different third-party categories involved in each business line’s activities and to align the assessment with the chosen risk level. These analyses led to the definition of third-party assessment policies based on the specific nature of each business. In 2022, this work will continue to focus on rolling out third-party assessment policies and performing due diligence on identified at-risk third parties. Business relationships cannot be established unless the business partner is informed of the group’s anti-corruption commitments and receives documents on its Compliance Policy (e.g., Anti-Corruption Code and Responsible Purchasing Charter). Each business also ensures that the draft partnership agreement includes an anti-corruption clause setting out each party’s commitments regarding anti-corruption issues. Risk detection : Designed for reporting potential internal misconduct, the whistleblowing system features a platform that is available to all group entities. Originally designed for violations under France’s Sapin II Act, it now encompasses the requirements imposed by the French duty of vigilance law. Control measures : In 2021 control procedures continued to be rolled out for financial processes. The Audit Compliance team, which reports to the group Audit Department, performed both cross-functional and vertical controls to ensure that the businesses have properly applied the components of the anti-corruption policy and that its recommendations have been implemented.