CSR Report 2015
Transcription
CSR Report 2015
CSR Report 2015 –the Charity Lotteries 0. Table of Contents 1. Introduction 2. Organisational profile 3. CSR agenda 4. Value chain 5. Stakeholder engagement 6. Materiality assessment 7. Our performance 8. Reporting principles 9. GRI table 10. Assurance report 11. Glossary of terms 1. Introduction We have taken steps this year to further integrate our CSR reporting into our annual reporting. Additionally, this is also the first year that we report according to the G4 reporting guidelines of the Global Reporting Initiative (GRI). Together these two developments help us to further focus our CSR reporting and align this with the requirements, wishes and expectations of our stakeholders. 2. Organisational Profile Novamedia and the Charity Lotteries in the Netherlands, Sweden and Great Britain are innovative organisations with a social purpose, working to bring together business and ideals. We want to make the world a better place. We understand how important long-term funding is, and that promoting the good work of charitable organisations is crucial in helping them achieve a better world. That is why we raise funds and awareness for good causes in the fields of International Cooperation, Human Rights, Nature and Environment, Health, Social cohesion & Wellbeing and Culture. Together with the players of our Charity Lotteries, we raise funds to help these charitable organisations contribute to a better world. In 2015 we donated a total of EUR 613 million. In December 2015 City A.M. rated Novamedia/Charity Lotteries as the third largest private charity donor in the world over 2014. As we believe that CSR is integral to our business, we are moving towards integrated reporting and away from a stand-alone CSR report. We will continue to explore the possibilities as this will enable us to provide a full picture of our business in one single report. At this stage however, we still complement our statutory accounts and our public annual report with this concise and factual CSR report. The main audience of this report are CSR experts and other interested stakeholders. This CSR report complements the following reports: public Annual Report 2015 of Novamedia/Charity Lotteries, the public Annual Reports 2015 of the Nationale Postcode Loterij, the BankGiro Loterij, the VriendenLoterij and People’s Postcode Lottery, the consolidated financial statements of Holding Nationale Goede Doelen Loterijen N.V. and the consolidated financial statements of Novamedia Holding B.V. figure 1: Organisation chart Page | 1 Novamedia was set up in 1983 as an innovative Dutch marketing and media agency raising funds for charity organisations that create a fairer and greener world. To this end, Novamedia founded the Nationale Postcode Loterij (Dutch Postcode Lottery) in 1989. In 1998, the Sponsor Bingo Loterij (now VriendenLoterij) and in 2002 the BankGiro Loterij joined. Together the three lotteries are part of Holding Nationale Goede Doelen Loterijen N.V. The success of the Nationale Postcode Loterij inspired Novamedia to launch the Svenska PostkodLotteriet (Swedish Postcode Lottery) in 2005, followed by the People’s Postcode Lottery in Great Britain in 2008. Novamedia Sverige AB operates the Swedish Postcode Lottery on the basis of a contract concluded with Svenska Postkodförenigen. The lottery permits are held by Svenska Postkodföreningen, which have their own independent Board.” 3. CSR agenda Based on our vision, mission, core values and the stakeholder analysis we developed a CSR agenda specifying our ambitions. Our CSR agenda consists of three pillars: Planet, People and Openness and will be further developed in 2016. All entities work according to the three pillars and corresponding topics on the CSR agenda. Goals and KPI’s are set centrally, but each entity implements its own measures in order to reach those goals. As the world around us is changing continuously, a proactive approach is key to the viability of our CSR agenda. As a result, we performed an extensive survey of our stakeholders’ expectations in 2015, reassessing the pillars and topics on our CSR agenda. One of the outcomes is that our stakeholders would like to know more about our allocation process and work made possible with our funding. This touches upon the essence of our organisation and mission. CSR Governance Not only are we currently reassessing our CSR, we are also advancing the way it is rooted in our organisation. Our CSR agenda is overseen by our highest governance bodies – the Supervisory Boards of Novamedia Holding B.V. and of Holding Nationale Goede Doelen Loterijen N.V. This will ensure that our CSR agenda, activities and progress is adapted at the highest level in our organisation. The CSR team is responsible for the day to day execution of the CSR agenda and provides the Management Team and Executive Board with results and insights. The Executive Board and Managing Directors discuss the targets, the achievements and the progress made on the objectives. They, together with the CSR team, aim to actively involve every employee by regularly informing them about the CSR agenda and our ambitions. The Managing Directors formally approve the data from their respective lotteries. As part of our CSR agenda we have set ourselves ambitious goals in the areas that matter most to our stakeholders and our own business. In order to track our progress against our goals we have formulated key performance indicators (KPI’s) on each relevant CSR theme. At this stage we report on the KPIs at least yearly for our annual reporting. The guidelines for the process, the indicators and data quality are laid down in a reporting manual. This facilitates and guarantees internal monitoring and planning of activities that drive performance on CSR themes for all the Charity Lotteries and Novamedia. In figure 2 we have depicted our CSR agenda and ambitions. In chapter 7 we report on the progress of each of these as well as the objectives we have set ourselves. Our CSR Agenda 1. Achievements of beneficiaries made possible by charitable contributions Our lotteries fund charities for several years with unrestricted funding. We are convinced the charities know best where the funding is most needed. This helps them to become and/or stay strong organisations that make communities and the environment a better place. The Charity Lotteries raised over EUR 1,424 million in revenues last year. To establish mutual understanding and trust with our stakeholders: We communicate transparently how we allocate the funds in our annual reports and on our websites. 2. Fair and real cost pricing In the interest of our future, we call for a reordering of priorities, putting our planet first closely followed by a decent living standard for people. Creating a positive impact is an important requirement for our own operations. This Page | 2 means paying fair and real cost prices for products we purchase. With this we aim to treat planet and people responsible throughout the entire value chain. The lotteries work continuously to further implement sustainability in its offer of prizes in kind. Also environmental friendly packaging and the required transportation are taken into consideration. This is why we aim to work together with: Suppliers with a sustainable operation offering sustainable products. Local suppliers (when possible). Our significant suppliers and ask them to commit themselves to our supplier Code of Conduct. In the long term being carbon positive is our ambition, without the help of compensation projects or buying credits. Energy independence is essential to achieve this goal. In striving towards this, we aim: To purchase ‘green’ electricity produced locally. To produce our own renewable energy. 4. Responsible Operations Our mission commits us to organising our Charity Lotteries in a responsible way. We communicate in an open and balanced manner, providing stakeholders with an unbiased picture of our performance and societal impact. The basic principles for organising our lotteries are transparency, responsible participation, integrity and compliance. We have a large responsibility towards our players participating in our lotteries. Ensuring that every draw is fair and that the prizes are awarded correctly is crucial for our lotteries. That is why we have a zero tolerance policy regarding errors. We want to act fair and in line with legislation. That’s why we: Maintain the integrity of the Charity Lotteries by acting with ‘zero tolerance’ in guaranteeing the absence of errors in our draws and payment of prizes. Monitor all technological innovations and developments regarding customer data to minimize the risks regarding customer privacy and protection of personal data. Train our employees in relevant laws & regulations. Communicate openly in case of incidents. figure 2: CSR Agenda 3. Aim to have a positive impact on the planet with our own operations We expect that in the long term, energy independence will form the basis of a completely renewable energy supply. In striving towards this, we are focusing on purchasing green energy that is produced locally. The final aim is to produce our own renewable energy. 5. Responsible Campaigning We protect consumers by preventing irresponsible or underage participation, including a commitment to responsible marketing activities and compliance with advertising codes. We want to be fair in what we do, also in marketing and advertising. Our players have the opportunity to share possible complaints with the Charity Lotteries and we act upon each complaint. That’s why we: Aim for zero upheld complaints related to commercial communication. Communicate openly in case of incidents. Page | 3 6. Good employment We aim to be a great place to work and to reflect society in The Netherlands, Sweden and Great Britain in terms of diversity of employees and management. Where possible we actively stimulate diversity in ethnicity and gender. We believe that only with an engaged, well-developed and diverse group of employees, we are able to work towards our mission. That’s why we: Have a ‘30% difference at the top’ charter in place to increase and foster diversity in higher management. Want equal treatment and opportunities for each of our employees regardless of age, ethnicity, gender, sexual orientation and/or disability. We measure how our employees perceive our organisation in our employee satisfaction survey and evaluate the outcomes. Page | 4 4. Value chain We want to create value for all our relevant stakeholders. The value chain as depicted provides insight in our role and impact in a wider context. It shows the areas in which we can create the most value – both by creating a positive impact directly and indirectly, as well as eliminating any negative impact. This visualisation also provides insight in our inputs and operations in order to achieve the desired outputs and impacts. We have a unique model: our main impact is achieved indirectly through our beneficiaries which we support with our contributions. We do not have production facilities ourselves but we purchase substantial numbers of prizes in kind and premiums for our players. We use significant amounts of paper for our marketing activities. In our value chain we therefore have impact via our players, suppliers, beneficiaries and winners. It is of a high importance that we make conscious decisions including social, environmental and economic aspects, for example in our procurement processes. We have created the visualisation (refer to figure 3: value chain) of our value chain in accordance with the reporting framework of the International Integrated Reporting Council (IIRC), which includes different types of capital. The visualisation, for instance, shows the relationship capital that we need as input (‘Relationships with beneficiaries), as well as our relations with our players in order to make our model work so that we can distribute different forms of financial capital such as prize money and money for our beneficiaries. In the value chain we show the unique characteristics of our organization that make us a unique lottery. Furthermore, we show our overall purpose to raise funds for social organizations worldwide and increase awareness of their work. We follow developments in our value chain very closely as these might impact our agenda significantly. We further elaborate on our strategic approach in our CSR agenda in chapter 3 of this report. Our performance on this CSR agenda and on different capitals as depicted can be found in chapter 7 of this report. Challenge: what to focus on to create the highest impact? We strive to allocate our time and resources to have the highest possible impact. Our biggest impact lies in securing long-term funding for charity and offering sustainable prizes. Moreover, we want to be a sustainable organisation figure 3: Value chain – our perspective - limiting our energy use and greenhouse gas emissions. However, as an organisation that does not have production facilities and supports environmental organisations, we should also consider the potential negative and positive impact of our suppliers and beneficiaries, and how this can support our mission. Our materiality analysis allows us to identify how to maximize these opportunities. 5. Stakeholder engagement The Charity Lotteries are in regular contact with all relevant stakeholder groups to increase involvement and enhance transparency about the activities of the lotteries. During our stakeholder engagement process, several CSR related themes are on the agenda and key topics and concerns of stakeholders are discussed. These form input for our CSR agenda. Please refer to the table below for an overview of the most important stakeholder groups, the topics discussed and the outcomes thereof in 2015. The Executive Board and Managing Directors are actively engaged in our dialogues with stakeholders and are ultimately responsible for translating the outcomes of these dialogues into our CSR agenda. Page | 5 Players Beneficiaries Authorities, government & regulators Employees Suppliers Type of dialogue Frequency Key topics discussed in 2015 Surveys are used to find out what the players of our lotteries think about Service Our players are a major stakeholder. They expect us to be certain issues, such as prizes (in kind) or mailings. We also maintain desk: daily transparent and open about the terms and conditions of contact with our players through the Members Service Departments in participation, as well as their chances of winning. We want to be the local countries and, increasingly, through social media. Via press reliable and responsible lotteries. Therefore, we need to releases we announce the allocations to our beneficiaries. continuously monitor our players’ views and expectations of us, and adjust our approach if necessary. Our players expect us to run our operations in a sustainable way. On a daily basis we have contact with our beneficiaries. In the Netherlands, twice a year, the directors of the lotteries and the directors of a number of beneficiaries meet and discuss plans for the coming year. In Sweden we have yearly meetings with all our beneficiaries. Additionally, we have forums and seminars in place to communicate with beneficiaries. In Great Britain we are also in regular contact with our beneficiaries during events and bilateral meetings. Biannually / annually / daily We have regular contact with politicians, civil servants, policy makers Daily and directors in various sectors. We also facilitate dialogues with these monthly stakeholders, and investigate the role of the lotteries in society and how rules and legislation can best be shaped. In Sweden and Great Britain we became member of the reference group in the commission on new gaming legislation. We also issue monthly reporting and follow up meetings in Sweden with authorities regarding issues such as responsible operations, licence and compliance with regulations. Every other year our employees participate in the employee satisfaction Twice a survey, to check whether we, as an employer, meet our targets on being year a great place to work. Furthermore we let our employees experience personal growth and development through training and by letting our employees volunteer with our beneficiaries. In that way we connect them with the organisations we allocate money to. Additionally we have Work Councils in place in Great Britain and the Netherlands, which have an important say in our daily business practices. They are regularly consulted. In Sweden and in the Netherlands we also communicate two or three times a year through company conferences. We have regular contact with our suppliers as part of the procurement Yearly process. Additionally, at the moment of delivery (of goods) and/or execution (of services) we communicate with our suppliers. We expect our significant suppliers to uphold the ethical standards set out in our Supplier Code of Conduct, which mentions anti-corruption, anti-bribery and freedom of association. We reach out to suppliers that do not sign our Supplier Code of Conduct. Most of these suppliers do have their own Code of Conduct in place. In those cases we analyse these Codes to make sure that they meet and uphold our own ethical standards. The meetings with beneficiaries serve as a platform for sharing and discussing ideas for improving co-operation. We also use these meetings to discuss how beneficiaries have spent their charitable contributions and the impact this created. A main topic discussed in Sweden is the impact of the new model used for allocating our charitable contributions. The Dutch government is reforming the Act on Games of Chance. In 2016 the parliament will discuss an act to legalize online gambling. If this happens the government indicated they wish to reform the lottery sector. In Great Britain the lottery provided evidence at a Parliament hearing to support changes to remove constraints for charities to raise funds through lotteries. In Sweden possible new legislation on gaming has been discussed impacting issues such as responsible operations, license, marketing, beneficiaries and taxes. Also, an ongoing investigation on potential abuse of dominant position and/or use of anti-competitive agreements is in place. The meetings with the Work Councils and the employee satisfaction survey serve as a platform for actively addressing the possible issues that are important to our employees. In 2015 the main topics discussed were the absence of leave arrangements, lease car conditions and intermission arrangements of our part-time employees. The topics discussed with our significant suppliers mostly cover the ethical standards as set out in our Supplier Code of Conduct and the materials used in the products we buy in. Where needed, we intensify the dialogue to make sure that suppliers uphold our ethical standards. Most important outcomes All our players are unique and we need to be able to respond adequately to their increasingly diverse expectations. They expect us to be reliable, transparent and responsible lotteries. Where needed we will further tailor our approach to remain reliable, transparent and responsible. In 2015 we did not significantly update our approach. In essence, our beneficiaries form the reason for our existence. Hence it is of the utmost importance to be a reliable partner to them, as well as to work together based on mutually shared values to contribute to a better world. In 2015 we did not receive feedback that led to substantial changes in our approach towards our beneficiaries. It is of great importance that we follow the changes on laws and regulations in all countries where we operate our lotteries. The increased demand on society lotteries has resulted in the government reviewing lottery legislation and potentially remove lottery limits in the United Kingdom. We need to follow the developments on the possible new legislation in the Netherlands and Sweden. Based on the outcomes of the employee satisfaction survey and the dialogue with the Work Councils every department develops action plans in order to maintain and improve our satisfaction score and the working conditions. We are planning to design a more strict monitoring of the return process of signed codes. Suppliers that do not comply require a change process. After all, we aim for long-term, mutually beneficial relationships. The Swedish Postcode Lottery and its growing experience with supplier audits provides a best practice to our other entities in this respect. Page | 6 6. Materiality assessment Our materiality assessment is the basis for determining the report content and was performed in the course of 2015. In our assessment we have built on the outcomes of our internal assessment carried out in 2014. The outcomes of the materiality assessment are approved by the Executive Board. The 2015 process consists of three steps: Step 1: Identification of relevant aspects and other topics The goal of the first step is to create a gross overview of relevant CSR topics. In this process, the Charity Lotteries build a comprehensive list of topics based on GRI guidelines. Where relevant, missing topics are added, including topics identified during media scans and stakeholder dialogues. Relevant topics are those on which the Charity Lotteries have or can have an impact (inside the organization and in the value chain or society). The outcome is an overview of all relevant topics. Step 2: Determining reporting priority The second step aims to assess the reporting priority of all relevant topics, which is presented graphically and used not only to determine the contents of the annual reporting but also as input to determine our (CSR) agenda, policies and approach. The Charity Lotteries determine the reporting priority by reviewing all relevant topics on: (1) significance of the topic for the Charity Lotteries and (2) significance of the topic for key stakeholders. This review is performed by an extensive survey to our internal and external stakeholders requesting them to rank the relevant aspects. The combination of the horizontal axis (importance to the Charity Lotteries) and the vertical axis (importance to stakeholders) determines the degree of influence that the topic has on our business and therefore the reporting priority. The Charity Lotteries divide the results into three categories: High material topics: We aim to fulfil a leading role on these topics. We report on these topics in our annual reporting following the GRI G4 Guidelines. Medium material topics: Topics we report on in our annual reporting. Low material topics: Topics we monitor, but do not report on. figure 4: materiality matrix Step 3: Implementation Based on the priority outcomes of the materiality determination, we determine the topics to be addressed in the report, including the scope and aspect boundaries of all material topics. Our businesses are informed on new and altered topics to be acted and reported on, to prepare reporting systems, enhance internal mechanisms, develop reporting definitions and, where relevant, targets. Timelines are developed and new/altered topics are included in the relevant reporting process mechanisms. Where possible we aim to report quantitatively on our material topics. In some cases this is not (yet) possible. We will continue to explore options on how to further expand our reporting in these areas. Page | 7 Highly material (included in reporting) Low material (not included in reporting) 1. Achievements of beneficiaries made possible by charitable contributions (p.9) 15. Employee training & talent development 2. Regulatory compliance (p.10) 16. Employee well-being and safety 3. Responsible campaigning (p.10) 17. Audits on suppliers 4. Community involvement* 18. Use of paper 5. Transparency in allocation of contribution to beneficiaries (p.16) 19. Economic performance 6. Good employment (p.10) 20. External (sustainability) reporting 7. Corporate governance (p. 4, 14, 16-17) 21. Transportation and distribution 8. Responsible operations (p.9) 22. Non-monetary prizes and premiums 9. Privacy and consumer data protection (p.11) 23. Code of Conduct for suppliers 10. Fair and real cost pricing (p.9) 24. Consumer service, support, Medium material (included in reporting) 25. Customer satisfaction 11. Emissions and energy management (p.9) 26. Stakeholder engagement 12. Integration of CSR into organization (p.11) 27. Grievance mechanisms 13. Incidents in the drawing process (p.10) 28. Employee compensation & benefits 14. Company competitiveness (p.11) *We cover this topic via our beneficiaries (nr 1) and fair and real cost pricing (nr. 10). Also refer to the GRI table for details. Page | 8 7. Our performance Eco-labelled paper Unit In this chapter we report on our performance in line with our CSR agenda and objectives on the quantitative topics that matter most to our stakeholders and our own business. We report on the most material topics following our materiality analysis (see chapter 6). We also report on the targets we have set for ourselves for 2015. Dutch Charity Lotteries 1. Achievements by beneficiaries made possible by charitable contributions Our lotteries fund charities for multiple years with unrestricted funding. In 2015 we donated for a total of EUR 613 million to beneficiaries. Dutch Charity Lotteries Swedish Postcode Lottery People’s Postcode Lottery Contribution to beneficiaries active in: Unit International cooperation % 27% 8% 11% Human rights % 9% 17% 0% Nature and environment % 23% 10% 44% Health % 6% 34% 17% Social cohesion & wellbeing % 21% 14% 22% Culture % 14% 17% 6% 2. Fair and real cost pricing We observed an overall rise of 7% in the number of significant suppliers which signed our Code of Conduct. Across our operations we have not yet achieved our target of 100%. Significant suppliers’ adherence to our Code of Conduct Unit Dutch Charity Lotteries Target 2015 2014 % 60% 33% 27% Swedish Postcode Lottery % 100% 72% 73% People’s Postcode Lottery % 100% 21% 12% Novamedia % 100% 63% 35% 1 1 = 2014 figure restated due to recalculation Almost all our paper consumption is either FSC certified or recycled. We observe an overall small decrease in eco-labelled paper compared to 2014. Target 2015 2014 % 100% 93% 96% Swedish Postcode Lottery % 100% 97% 98% People’s Postcode Lottery % 100% 100% 100% 3. Aim to have a positive impact on the planet with our own operations Our green energy usage (electricity, natural gas, district heating) has increased significantly to 73% of the energy we use in our buildings. The carbon emissions of our own operations (direct, indirect, business air travel, paper) shows a decrease of 9%. In 2015 we compensated 16,906 ton CO2 equivalents through investments in climate compensation projects such as clean cooking stoves, waste water treatment and wind power in developing countries. The carbon emission associated with our direct energy consumption (natural gas) show a significant decrease as we are now using green gas for all our Dutch operations. Also, this is the first year that we have calculated the carbon emissions along our value chain for the prizes and premiums we purchase for our Charity Lotteries. Based on an externally assured approach which was followed by our Swedish Lottery for several years, we have now approximated the carbon emissions associated with the production, consumer and end of life phase for the prizes and premiums we purchase. Energy and emissions Unit Green energy usage % Climate compensation Ton CO2e Scope 1: direct energy 2015 2014 73% 45% 16,906 no data Ton CO2 3 13 Scope 2: indirect energy Ton CO2 174 169 Scope 3: business air travel Ton CO2e 683 724 Scope 3: paper consumption Ton CO2e 15,099 14,230 Scope 3: prizes & premiums Ton CO2e 49,252 No data Page | 9 4. Responsible operations In 2015 we had no incidents in the drawing process. Incidents Unit Incidents in the drawing process Number Unit Complaints related to customer privacy from regulatory bodies Number Unit 2015 2014 Dutch Charity Lotteries % No data No data Target 2015 2014 Swedish Postcode Lottery % 99% No data 0 0 0 People’s Postcode Lottery % 100% No data We monitor technological innovations and developments regarding customer data to minimize the risks regarding customer privacy and data protection. Additionally, we are transparent on the complaints we received related to customer privacy. This is the first year that we are reporting on this indicator. We received one complaint for the Swedish Postcode Lottery. Customer privacy Employees trained inresponsible operations Target 2015 2014 0 1 No data Compliance with laws and legislation is of the utmost importance to the Charity Lotteries. In 2015, we received one non-monetary sanction in the Netherlands. No monetary fines were issued. Regulatory compliance Unit Target 2015 2014 Monetary value of fines EUR 0 0 0 Non-monetary sanctions Number 0 1 1 5. Responsible campaigning In the Netherlands seven complaints related to commercial communication were upheld by the Advertising Code Committee. Additionally, one complaint was upheld by the Dutch Gambling Commission (Kansspelautoriteit). Similar to 2014, the Swedish Postcode Lottery and People’s Postcode Lottery received no complaints that resulted in either a warning, fine or penalty. Incidents of non-compliance with regulations concerning marketing communications resulting in a warning, fine or penalty Unit Dutch Charity Lotteries1 Target 2015 2014 Number 0 7 9 Swedish Postcode Lottery Number 0 0 0 People’s Postcode Lottery Number 0 0 0 Last year’s report showed seven upheld complaints for the Dutch Charity Lotteries. However, due to an appeal procedure during 2015 two additional complaints from 2014 were upheld. The Swedish Competition Authority started an investigation on Swedish Lotteries’ compliance with competitions laws in 2013. To this date, no charges have been brought to court. Fair competition Unit Legal actions pending or completed Number Target 2015 2014 0 1 No data Almost all our employees are currently trained in responsible operations in the United Kingdom and Sweden. As this is a new indicator, we will take the necessary steps to start measuring this indicator for our operations in the Netherlands in 2016. Page | 10 6. Good employment We aim to have at least 30% females in our higher management to foster diversity. In 2015 we had 49% female employees in our higher management (2014: 43%). Management positions Headcount Starting next year, we will start disclosing how our employees perceive equal treatment regardless of age, ethnicity, gender, sexual orientation and/or disability. Full integration of CSR in our organisation is for example mirrored in being transparent in our external communication towards stakeholders. Our annual reporting and the recognition of it in the Dutch Transparency Benchmark is an important parameter. In the most recent version of this benchmark we scored 167 out of 200 points. FTE (NM, NL, UK, SE) 215 312 49 % Men 51 % Women 106 24 10 NM 264 111 102 112 68 NL UK SE Male Female 21 10 196 NM NL Male 105 102 64 UK SE Female figure 5: diversity & equal opportunity We consider good employer practices of crucial importance. Both for a good operating result and for the people who work with us. Do our colleagues appreciate our efforts in this area? To keep ourselves properly informed, we organize an anonymous employee satisfaction survey at least every 3 years. This survey asks the employees to assess the lottery organization on five values: credibility, respect, honesty, pride and camaraderie. Challenge: How can we mitigate the ambiguity between commercial targets and CSR targets in daily practice? We want our employees to be committed to the organisation and its CSR agenda. However, in daily practice our employees also have to deal with the ambiguity between commercial targets and CSR targets. For instance, we are dedicated to lowering our carbon footprint, but when looking for attractive prizes to offer to our players, we sometimes choose items that appeal to our players, but happen to have a relatively large environmental footprint. An important continuous ambition is to make CSR top of mind and to provide better opportunities for our employees to combine CSR targets with their daily work, for instance through the selection of prizes. In Sweden, we have compensated 100% of our CO2-emissions by investing in projects that reduce CO2-emission in less developed countries. All projects are certified according to Gold Standard. Page | 11 8. Reporting principles Reporting scope The purpose of the CSR information in our CSR reporting (including the statutory financial statements and our popular annual accounts and on our website), covering the calendar year 2015, is to inform our stakeholders about our role in society, in connection with our main strategic objectives and targets. We regard as stakeholders all people and organizations affected by our operations or with whom we maintain a relationship, such as players, regulators, employees, suppliers, beneficiaries, etc. The scope of the CSR information in this report, covers the following entities: Charity Lotteries: Holding Nationale Goede Doelen Loterijen N.V. Nationale Postcode Loterij N.V. (The Dutch Postcode Lottery) BankGiro Loterij N.V. (BankGiro Lottery) VriendenLoterij N.V. (Friends Lottery) People’s Postcode Lottery (represented by 16 trusts) Entities of operator Novamedia Holding B.V.: Novamedia B.V. (excluding the media entities) Novamedia Sverige AB (before 20 February 2015 known as Novamedia Svenska PostkodLotteriet AB) operates the Swedish Postcode Lottery on the basis of a contract concluded with Svenska Postkodförenigen. The lottery permits are held by Svenska Postkodföreningen, which have their own independent Board. Refer to GRI table section governance for details. Postcode Lottery Ltd. Unless stated otherwise, references to the charity lotteries should be read as referring to the above entities. For our CSR reporting, we include new acquisitions in relation to our Charity Lottery activities in our report as of the first full year of ownership. CSR information for divestments that occurred during the reporting year is excluded for the full year. The data in this report refers to the Charity lotteries performance and not to that of our subcontractors or beneficiaries, unless stated otherwise. Our reporting specifically reviews developments and performance in 2015 and is based on topics identified as material for the Charity Lotteries. Reporting process CSR information For this report, we have applied the guidelines from the Global Reporting Initiative (GRI). The CSR information in this report is presented in accordance with the core option of GRI G4. The process for defining the material topics and report content, as well as the list of material topics, is described in the materiality determination (see chapter 5). Where available and relevant, the report includes data of previous years. Quantitative data concerning the workforce and financial results set out in this report have been collected using our financial data management system. The remaining data set out in this report have been collected using a standardized questionnaire that is yearly completed by the responsible entities. The data for this report have been measured. Where no data was available, they were estimated. The CSR departments used consistency and availability of supporting evidence as the basis for their assessment of the data reported at consolidated level. Validation criteria set out in advance were also used to assess the data. In order to provide our stakeholders assurance over the reliability of our reporting, we engaged PricewaterhouseCoopers Accountants N.V. (PwC) to provide reasonable assurance on our performance indicators (refer to chapter 7) with the exception of our scope 3 carbon emissions. Limited assurance is provided on all other metrics in the scope of PwC. Reasonable assurance is obtained through audit work, while other elements of the report have been reviewed. Review work provides only limited assurance because exhaustive gathering of evidence is not required. The assurance work is performed in accordance with the Assurance Standard 3810N ‘Assurance Engagements Relating to Sustainability Reports’ as drawn up by the professional body of Dutch Accountants (NBA). We will continue to explore options to further integrate our CSR information in our regular and public annual reporting. This will enable us to communicate our message in one single place and reach a large audience. At the same time we want to provide external stakeholders assurance over the reliability of our data. Page | 12 9. GRI Table GRI-table The Charity Lotteries - G4 Core Nr. Indicator General standard disclosures Strategy & analysis G4-1 Statement from the most senior decision-maker Organizational profile G4-3 Name of the organisation. G4-4 Primary brands, products, and services. G4-5 G4-6 G4-7 G4-8 G4-9 G4-10 Location of the organisation's headquarters. Countries where the organisation operates Nature of ownership and legal form. Markets served Scale of the organisation Profile of the workforce G4-11 Employees covered by collective bargaining agreements. G4-12 Describe the organization's supply chain. G4-13 Significant changes during the reporting period G4-14 Precautionary approach or principle G4-15 Externally developed charters or principles endorsed G4-16 Memberships of associations Identified material aspects and boundaries G4-17 Entities included in the organisations consolidated financial statements and whether these are covered by the report. G4-18 The process for defining report content & aspect boundaries. G4-19 List all material Aspects identified G4-20 Aspect boundary within the organisation G4-21 Aspect boundary outside of the organisation Reference/description Foreword in the Popular Annual report 2015 1. Introduction 2. Profile Our postcode formula and focus on beneficiaries gives us a competitive edge over other lotteries. Van Eeghenstraat 70, Amsterdam, The Netherlands 2. Profile Annual accounts 2. Profile 2. Profile, 4. Value Chain and 7. Our performance 7. Our performance The health and wellbeing of our employees is important for us. We actively monitor absence rates as this is an important indicator for the well-being of our employees. The average percentage of absenteeism in 2014 for our Dutch operations was: 4.0% 18% of our employees are covered by collective bargaining agreements 4. Value chain Not applicable Annual Accounts Among others: SPER, CDM, Workplace Pride, Great Place to Work, FSC Among others: De Groene Zaak, INSID and Het Nieuwe Werken Doe Je Zelf. 8. Reporting principles 6. Materiality assessment 6. Materiality assessment All information regarding our policy, strategy, agenda and associated indicators, procedures and systems relate to our own organisation, unless otherwise specified in the report. However, it should be noted that the Charity Lotteries and its activities are not isolated from its surroundings. Therefore, most material issues have an impact both inside and outside our organisation. However, the material topics regulatory compliance, responsible campaigning/communications and ethical advertising, Transparency in allocation of contribution to beneficiaries, Good employment, Corporate governance, Responsible operations and Customer privacy and consumer data protection have a primary focus within our organisation. The material topics Achievements by beneficiaries made possible by charitable contributions, Community involvement and Fair and real cost pricing on the other hand focus primarily outside the organisation. For additional clarification refer to: 4. Value chain 6. Materiality assessment See G4-20 Page | 13 GRI-table The Charity Lotteries - G4 Core Nr. Indicator G4-22 Restatements of information provided in previous reports G4-23 Report significant changes in Scope and aspect boundaries. Stakeholder Engagement G4-24 List of stakeholder groups engaged by the organisation. G4-25 Basis for identification and selection of stakeholders G4-26 Organisations approach to stakeholder engagement G4-27 Key topics raised through stakeholder engagement Report Profile G4-28 Reporting period (such as fiscal or calendar year) G4-29 Date of most recent previous report (if any). G4-30 Reporting cycle (such as annual, biennial). G4-31 Contact point for questions regarding the report G4-32 a) Report the 'in accordance' option, b) Report the GRI Content Index, c) Report the reference to the External Assurance Report. G4-33 a) The organisation's policy and practice regarding assurance b) The scope and basis of any external assurance provided c) relationship between organisation and assurance provider d) Involvement Board in seeking assurance Governance G4-34 Governance structure of the organisation Reference/description We restated the 2014-figure on significant suppliers for Novamedia. See also 7. Our performance Based on the outcomes of our materiality analysis we updated our set of indicators and reporting definitions in 2015. This formed the basis for our first GRI G4 report.. We also discussed our CSR agenda and the goals we have set with our stakeholders 5.Stakeholder engagement Stakeholders are selected on the basis of an informal estimate of the reciprocal interest which the stakeholder and the Charity Lotteries have in each other. 5.Stakeholder engagement 5.Stakeholder engagement 5.Stakeholder engagement 1 January 2015 - 31 December 2015 March 2015 Annually Feedback and suggestion are most welcome, please contact us at: Communicatie@postcodeloterij.nl a) Core; b) CSR report 2015; c) 10. Assurance report 8. Reporting principles 10. Assurance report The Board is involved in seeking assurance on our 2015 CSR report and is ultimately responsible for our policy and practice regarding assurance. No significant inherent limitations are associated with definitions and/or associated with the methodologies of measuring, estimating and calculating CSR data. Novamedia Holding B.V. is the parent company of Novamedia B.V. Novamedia B.V. is the owner of the Postcode Lottery format worldwide. People’s Postcode Lottery and the Swedish Postcode Lottery have been granted a sublicense on the format, via local subsidiaries of Novamedia. The Members of the Executive Board of Novamedia Holding B.V. are Boudewijn Poelmann, Sigrid van Aken and Ruud Esser. The Supervisory Board of Novamedia Holding B.V. supervises the board. The board of Novamedia is supported by a team of Company Directors and a team of Functional Directors. Holding Nationale Goede Doelen Loterijen N.V. has three subsidiaries: Nationale Postcode Loterij N.V. (Dutch Postcode Lottery), VriendenLoterij N.V. (FriendsLottery) and BankGiro Loterij NV (BankGiro Lottery). The Supervisory Board of Holding Nationale Goede Doelen Loterijen N.V. supervises the Board. The Members of the executive Board of Holding Nationale Goede Doelen Loterijen N.V. are Boudewijn Poelmann, Ruud Esser and Sigrid van Aken. A team of three managing directors is responsible for the day-to-day management of the three lotteries and heads the Management Team. Novamedia Sverige AB operates the lottery on behalf of Postkodföreningen in accordance with an agreement of full operation. Svenska Postkodföreningen has its own independent Board. As from October 2015 a team of two Managing Directors is responsible for the daily management of Novamedia Sverige AB and heads the Management Team. In Great Britain, the daily operations are the responsibility of the Country Director and two Managing Directors and they also head the Management team. 16 charitable Postcode Trusts hold individual licences to operate their own respective lotteries and engage People’s Postcode Lottery to manage the marketing and operation under contract as a licenced External Lottery Manager (ELM). Page | 14 GRI-table The Charity Lotteries - G4 Core Nr. Indicator Ethics and integrity G4-56 Describe the organisation’s values, principles, standards and norms of behaviour such as codes of conduct and codes of ethics. Reference/description Novamedia as the Executive Board of the Dutch Charity Lotteries receives fixed contractual remuneration that is indexed yearly. This contract has been concluded by the Supervisory Board of Holding Nationale Goede Doelen Loterij N.V. for a period of 5 years. The Executive Board is evaluated annually by the Supervisory Board. The remuneration of the Executive Board of Novamedia Holding B.V. is determined by the remuneration committee and presented on the general shareholders meeting. The performance of the Executive Board is evaluated annually by this Supervisory Board. The top managers within the organisations involved are the Managing Directors in each country, who are evaluated by the Executive Board and have a bonus scheme based on rise in turnover. The same applies to members of the Management Teams. As standard, the evaluation of all employees also involves Planet First! performance. The achievements on Planet First! are part of the criteria for the bonus. Our passion is encapsulated in our four core values: ‘Courageous’, ‘Sustainable’, ‘Sharing’ and ‘Fun’. These core values are also a promise. It shows how we treat the earth, nature and other people. Our values are central to the way we work, who we are and what we stand for. All significant suppliers should commit to our Code of Conduct. Suppliers must satisfy the procurement criteria on human rights and labour, health and safety, environmental impact and ethics. We have a monitoring system in place. The code is based on internationally accepted guidelines such as the Ethical Trading Initiative, the UN Global Compact, the Universal Declaration of Human Rights and the ILO-guidelines. In our social vision the opportunities for development are distributed unevenly throughout the world. Many people are threatened by hunger and disease and nature and the environment are hit hard by human activity. Fortunately, there are many non-profit organisations and people throughout the world who work to change this. We want to support non-profit organisations in their work. Specific disclosures 1. Achievements by beneficiaries made possible by charitable contributions (no direct link with G4) DMA a) Report why the Aspect is material. Report the impacts As part of their mission, the Charity Lotteries provide players with information about the charities they support. Players find that make this Aspect material, b) Report how the information on all supported charities on the lotteries’ and grant giving trusts’ websites. Their work features in magazines and organization manages the material Aspect or its impacts, newsletters sent to the players. TV game shows and special documentaries feature the work of the charities too. Moreover, c) Report the evaluation of the management approach players are encouraged to use the charities’ services or can win prizes provided by them, such as tickets for museums, flower shows, nature reserves or zoos. Where possible, the lotteries also work closely with the charity press teams to generate publicity for their causes. On a daily basis we have contact with our beneficiaries. In the Netherlands, twice a year, the directors of the lotteries and the directors of a number of beneficiaries meet and discuss plans for the coming year. In Sweden we have yearly meetings with all our beneficiaries. Additionally, we have forums and seminars in place to communicate with beneficiaries. In Great Britain we are also in regular contact with our beneficiaries during events and bilateral meetings. The meetings with beneficiaries serve as a platform for sharing and discussing ideas for improving co-operation. We also use these meetings to discuss how beneficiaries have spent their charitable contributions and the impact this created. - Annual Report 2015 of Novamedia/Charity Lotteries, 3. Lotteries for a better world - Annual Report 2015 of Novamedia/Charity Postcode Lotteries, 10. Where the millions go No quantitative indicator available at this stage Annual Report 2015 of Novamedia/Charity Lotteries, 3. Lotteries for a better world Annual Report 2015 of Novamedia/Charity Lotteries, 10. Where the millions go 2. Regulatory compliance (G4 aspect Compliance) DMA a) Report why the Aspect is material. Report the impacts Compliance with laws and legislation is of utmost importance to the Charity Lotteries. In 2015, we focused on monitoring and that make this Aspect material, b) Report how the reporting on internal measures against non-compliance. We reported quarterly to our Executive Board on the most important organization manages the material Aspect or its impacts, risks, internal control mechanisms and results relating to compliance. On a yearly basis this is on the agenda of the Audit c) Report the evaluation of the management approach Committee and Supervisory Board meeting. Marketing employees attended a presentation on compliance and promotional gaming. Page | 15 GRI-table The Charity Lotteries - G4 Core Nr. Indicator G4-SO8 Monetary value of significant fines and total number of sanctions for non-compliance with laws & regulations 3. Responsible campaigning (G4 aspect Marketing Communications) DMA a) Report why the Aspect is material. Report the impacts that make this Aspect material, b) Report how the organization manages the material Aspect or its impacts, c) Report the evaluation of the management approach G4-PR7 Reference/description 7. Our performance 3. CSR Agenda Responsible campaigning means that we protect consumers by preventing irresponsible or underage participation, including a commitment to responsible marketing activities and compliance with advertising codes. We want to be fair in what we do, also in marketing and advertising. That’s why we aim for zero upheld complaints related to commercial communication. The Swedish Postcode Lottery is a member of SPER (Swedish Regulated Gambling Market’s Ethical Council) and have set all sales and marketing activities in accordance with their guidelines. SPER is a soft-regulatory ethical council, which aims to enhance the knowledge about ethics in the gaming industry and to ensure that its members follow their guidelines for marketing and sales of gaming products. By being a member of SPER, the Swedish Postcode Lottery can continue its work towards implementing responsible operations and ethics into everyday work. For example, our sales and marketing employees in Sweden received training on the implementation of the SPER guidelines and the implications during 2015. In the Netherlands the Dutch Postcode Lottery is the coordinator on behalf of all gaming license holders in implementing selfregulation rules concerning responsible advertising and marketing in the Dutch Advertising Code. These rules set a high standard, and are usually stricter than and go beyond the legal standard. Incidents in relation to non-compliance with regulations concerning marketing communication are received from the Dutch advertising code committee. In Great Britain, the criteria of the Advertising Standards Authority are strict and robust, leaving no current need for a self-regulatory council that goes beyond this legislation. The People’s Postcode Lottery is regulated as a Society Lottery under the Gambling Act 2005. 16 charitable Postcode Trusts hold individual licences to operate their own respective lotteries and engage People’s Postcode Lottery to manage the marketing and operation under contract as a licenced External Lottery Manager (ELM). We monitor and evaluate our performance on responsible campaigning by measuring the number of upheld complaints that we receive. 7. Our performance Incidents of non-compliance with regulations concerning marketing communications resulting in a fine, penalty or warning 4. Community involvement (refer to material topics fair and real cost pricing and achievements by beneficiaries made possible by charitable contributions) DMA a) Report why the Aspect is material. Report the impacts Community involvement centres for us on performing activities and setting up programs aimed at creating higher standards of that make this Aspect material, b) Report how the living and quality of life in the communities in which we operate. This incorporates the inclusion of sustainability (environmental organization manages the material Aspect or its impacts, and social) requirements in the procurement processes. This fully overlaps with the material topics fair and real cost pricing and c) Report the evaluation of the management approach achievements by beneficiaries made possible by charitable contributions. Refer to these for a description of our DMA. Qualitative description Refer to above. 5. Transparency in allocation of contribution to beneficiaries (no direct link with G4) DMA a) Report why the Aspect is material. Report the impacts Being transparent about the criteria and selection process used when allocations of the surplus is made between the that make this Aspect material, b) Report how the beneficiaries is key for us. In Great Britain, the independent Boards of each Postcode Trust are responsible for deciding how organization manages the material Aspect or its impacts, funds are allocated to charities. All Trusts are audited by an independent auditor. c) Report the evaluation of the management approach In Sweden, it’s the Board of the PostkodFöreningen that decides on new beneficiaries and how the proceeds are to be distributed between the beneficiaries. As operator, the Managing Directors of Novamedia Sverige presents their proposition for allocations to the Board of Postkodföreningen. In order to increase transparency and predictability of the distribution of the lottery-surplus a new allocation model has been developed during 2014 and 2015. The new allocation model will be used for the distribution of the 2015 lottery-surplus and onwards. Dutch Postcode Lotteries: In the case of the Dutch Postcode Lottery, recruitment and distribution go hand in hand. This is also one of the reasons behind the success of the Dutch Postcode Lottery in the Netherlands. It is efficient. Finally, the organisation Page | 16 GRI-table The Charity Lotteries - G4 Core Nr. Indicator - No quantitative indicator available at this stage 6. Good employment (G4 aspect Diversity and Equal Opportunity) DMA a) Report why the Aspect is material. Report the impacts that make this Aspect material, b) Report how the organization manages the material Aspect or its impacts, c) Report the evaluation of the management approach G4-LA12 Composition of governance bodies and breakdown of employees per employee category according to gender 7. Corporate governance (no direct link with G4, other than G4-34) DMA a) Report why the Aspect is material. Report the impacts that make this Aspect material, b) Report how the organization manages the material Aspect or its impacts, c) Report the evaluation of the management approach Reference/description acts very decisively. The Supervisory Board decides how funds will be distributed every year. Long-term contracts are concluded with most beneficiaries, guaranteeing our support for a longer period. We have regular meetings with our beneficiaries which serve as a platform for evaluation, sharing and discussing ideas for improving co-operation. We also use these meetings to discuss how beneficiaries have spent their charitable contributions and the impact this created. No quantitative indicator available at this stage. We will continue to explore options on how to further expand our reporting in this area. We have a large diversity among our players and we want our team to be a reflection of societies in every country where we operate. Different backgrounds and viewpoints increase creativity, new ideas and synergy, and help further improve our organisation. Where possible, we try to recruit people who are far-removed from the job market. To achieve this, we have an active policy to attract employees from every stratum of society. However, this remains challenging. We are trying to improve ourselves in this respect and are actively searching for ways we can do more for people who try to find their way back to the job market. We periodically evaluate our performance by measuring diversity levels within our organization. Additionally, we aim to monitor the perceived equal remuneration between male and female employees via the results of the employee satisfaction survey. In each of our countries of operations we have HR departments which monitor progress and which are responsible for the execution of our policies in this area. In the Netherlands we also have a HR director who overlooks the activities of all our Charity Lotteries. 7. Our performance Refer to G4-34. Holding Nationale Goede Doelen Loterijen N.V. has three subsidiaries: Nationale Postcode Loterij N.V. (Dutch Postcode Lottery), VriendenLoterij N.V. (FriendsLottery) and BankGiro Loterij NV (BankGiro Lottery). The Supervisory Board of the Holding Nationale Goede Doelen Loterijen N.V. supervises the Board. The Supervisory Board manages the policy implemented by the Executive Board and the general running of the Novamedia holding company and its affiliated companies. Guided by the interests of Novamedia Holding BV, the Supervisory Board advises the Executive Board and approves the annual budget and major investments. The lottery licences required in order to legally hold a lottery in the Netherlands are issued by the Dutch Gambling Authority. The Ministry of Justice and Security and the Dutch Gambling Authority supervise compliance with the Act on Games of Chance and the lottery licences. The financial figures are audited by auditors from PwC. Computer experts from PwC and NMi Certin audit the mechanical, electrical and electronic processes. Also refer to: http://www.postcodeloterij.nl/organisatie/regelgevingen-toezicht-1/corporate-governance.htm In Great Britain, Novamedia B.V. established Postcode Lottery Ltd. People’s Postcode Lottery, operates a number of society lotteries, on behalf of charitable trusts. It is regulated by the Gambling Commission under licences 829-N-102511-009 and 829R-102513-008, dated 4 September 2014. People’s Postcode Lottery holds an External Lottery Manager (ELM) licence that enables the lottery to operate the draws on behalf of the trusts. Personal lottery management licences have been awarded to the Directors, the Head of Finance, the IT Director, the Country Director and the (Deputy) Managing Directors. The draws are supervised by an independent solicitor from Thorntons Solicitors, in accordance with the Gambling Act 2005. The draw engine is NMi certified. PwC performs the annual IT audit. Financial auditing of Postcode Lottery Ltd is carried out by PwC. The CSR report is audited by PwC. Svenska Postkodföreningen has been licensed to hold a lottery in Sweden. Beneficiaries of the lottery are members of this association. Novamedia Sverige AB operates the Swedish Postcode Lottery on the basis of a contract concluded with Svenska Postkodförenigen. This contract is approved by the Swedish Gambling Authority. The Board of the Association is composed of leading representatives from society and consists of six members and the Lottery Manager as an adjunct member. Novamedia Page | 17 GRI-table The Charity Lotteries - G4 Core Nr. Indicator - No quantitative indicator available at this stage Reference/description Sverige AB has run the Swedish Postcode Lottery since 2005. The managing director is also the Lottery Manager appointed by the Swedish Gambling Authority. These two roles combine the commercial concept of the business with the idea of generating money for charity organisations through the lottery. The Swedish Gambling Authority, which grants the lottery licence, collaborates closely with the Lottery Manager and supervises the lottery. PwC audits Novamedia Sverige AB (the operator); KPMG does this for the Swedish Postcode Association (and the licence holder). Refer to G4-34 and 3. CSR Agenda No quantitative indicator available at this stage. We will continue to explore options on how to further expand our reporting in this area. 8. Responsible operations (no direct link with G4) DMA a) Report why the Aspect is material. Report the impacts that make this Aspect material, b) Report how the organization manages the material Aspect or its impacts, c) Report the evaluation of the management approach Refer to material topics 7 (Corporate Governance). With a ticketbase of more than 8,598 million players and a total revenue of more than EUR 1,424 million, we have a big responsibility towards our customers participating in our lotteries. Responsible operations entails organising a fair and honest draw ensuring that players are well informed, voluntarily take part and are happy with the way we raise funds for charities. We do so by focusing on training our employees on the applicable regulation and internal codes in relation to responsible operations. Employees trained in responsible operations 7. Our performance Incidents in the drawing process 7. Our performance 9. Customer privacy and consumer data protection (G4 aspect Customer Privacy) DMA a) Report why the Aspect is material. Report the impacts Refer to 7.Corporate Governance. Ensuring that every draw is fair and that the prizes are awarded correctly is crucial for our that make this Aspect material, b) Report how the lotteries. That is why we have a zero tolerance policy regarding errors. We are transparent about how our lotteries are organization manages the material Aspect or its impacts, organised and focus on integrity, such as taking care of the privacy of our players. We actively monitor and evaluate our c) Report the evaluation of the management approach performance on customer privacy by measuring the number of complaints. G4-PR8 Substantiated complaints regarding breaches of customer 7. Our performance privacy and losses of customer data 10. Fair and real cost pricing (no direct link with G4) DMA a) Report why the Aspect is material. Report the impacts We have a significant impact on society and the environment via our procurement of products and services. We purchase that make this Aspect material, b) Report how the significant amounts of paper for our marketing activities and also prizes and premiums for our players. Social and environmental organization manages the material Aspect or its impacts, costs are often not included in the price of products. Therefore, we aim to purchase products for which the costs of treating the c) Report the evaluation of the management approach planet and people responsibly are included. In order to do so we have for many years now, requested all significant suppliers to commit to our Code of Conduct. We define significant suppliers as suppliers from whom we purchase more than 300,000 Swedish Crowns, GBP 23,000 or 31,800 Euro worth of goods and services, such as office supplies, coffee, tea but also prizes in kind. Suppliers must satisfy the procurement criteria on human rights and labour, h&s, environmental impact and ethics. Our purchase departments in our countries of operation are responsible to monitor and evaluate performance amongst others by identifying individual suppliers with an increased risk profile. We have an active monitoring system in place to measure progress in this area. Contracts will be terminated if suppliers are in breach of the criteria set out in the Code of Conduct. % of significant suppliers that signed the Code of Conduct 7. Our performance Page | 18 10. Assurance report Independent assurance report To: the Executive Boards of Holding Nationale Goede Doelen Loterijen N.V. and Novamedia Holding B.V. The Executive Boards of Holding Nationale Goede Doelen Loterijen N.V. and Novamedia Holding B.V. (‘the organisations’), Amsterdam, engaged us to provide assurance on the CSR Report 2015 (‘the Report’), which is a combined report of Holding Nationale Goede Doelen Loterijen N.V. - Nationale Postcode Loterij, BankGiro Loterij and VriendenLoterij –, Novamedia (with the exception of its media activities), Novamedia Sverige AB (before 20 February 2015 known as Novamedia Svenska PostkodLotteriet AB) and the People’s Postcode Lottery (Postcode Lottery Ltd) (together referred to as ‘Novamedia and the Charity Lotteries’). We believe our engagement fulfils a rational objective as disclosed by the organisations in Chapter 8 - Reporting principles. Our engagement consisted of a combination of reasonable assurance (leading to an ‘opinion’ and limited assurance (leading to a ‘conclusion’) procedures. We performed reasonable assurance procedures on the performance indicators presented in the tables of Chapter 7 - Our performance, with the exception of ‘Scope 3: prizes & premiums’ included in the table ‘Energy and emissions’ (together referred to as ‘the Performance Indicators’), leading to an opinion. We performed limited assurance procedures on all other elements the Report, leading to a conclusion. Our opinion Based on the procedures we have performed and the evidence we have obtained, in our opinion, the Performance Indicators presented in the tables of Chapter 7 - Our performance, with the exception of ‘Scope 3: prizes & premiums’ included in the table ‘Energy and emissions’ for the year ended 31 December 2015 are, in all material respects, presented reliably and adequately, in accordance with the organisations’ reporting criteria. Our conclusion Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the other elements in the Report for the year ended 31 December 2015 do not provide a reliable and appropriate presentation of the organisations’ policy for sustainable development, or of the activities, events and performance of the organisations relating to sustainable development during the reporting year, in accordance with the organisations’ reporting criteria. This opinion and conclusion are to be read in the context of the remainder of our report. What we are assuring We performed procedures and obtained evidence on the data and tables in this report. The CSR information includes the reporting scope as defined by management (Chapter 8 - Reporting principles), the organisations’ policy for sustainable development, the activities and events during the year and the organisations’ 2015 performance relating to sustainable development. We have audited the performance indicators included in the tables of Chapter 7 - Our performance, with the exception of ‘Scope 3: prizes & premiums’ included in the table ‘Energy and emissions’. We have reviewed the other elements of the Report of Novamedia and the Charity Lotteries. Limited assurance, leading to the above-mentioned conclusion, is substantially less in scope than reasonable assurance in relation to both the risk assessment procedures, including an understanding of internal control, and the procedures performed in response to the assessed risks. The basis for our opinion and conclusion Professional and ethical standards applied We conducted our engagement in accordance with Dutch law, including Standard 3810N ‘Assurance engagements relating to sustainability reports’ (hereafter ‘Standard 3810N’). Our responsibilities under this standard are further described in the “Our responsibilities” section of this independent assurance report. We are independent of the organisations in accordance with the “Verordening inzake de onafhankelijkheid van accountants bij assurance-opdrachten” (ViO) and other relevant independence requirements in the Netherlands. Furthermore, we have complied with the “Verordening gedrags- en beroepsregels accountants” (VGBA). Page | 19 Limitations in our scope The CSR Report 2015 contains prospective information, such as ambitions, strategy, targets, expectations and projections. Inherent to this information is that actual future results may be different from the prospective information and therefore it may be uncertain. We do not provide any assurance on the assumptions and feasibility of this prospective information. The auditor is not expected to, and cannot, reduce audit risk to zero and cannot therefore obtain absolute assurance that the Report is free from material misstatement due to fraud or error. This is because there are inherent limitations of an assurance engagement, which result in most of the audit evidence on which the auditor bases the auditor’s opinion being persuasive rather than conclusive. Reporting criteria Novamedia and the Charity Lotteries developed their sustainability reporting criteria on the basis of the G4 Guidelines of the Global Reporting Initiative (GRI), which are disclosed together with detailed information on the reporting scope in Chapter 8 - Reporting principles. We consider the sustainability reporting criteria to be relevant and appropriate for our examination. Understanding reporting and measurement methodologies The information in the scope of this engagement needs to be read and understood together with the reporting criteria, which Novamedia and the Charity Lotteries are solely responsible for selecting and applying. The absence of a significant body of established practice on which to draw, to evaluate and measure non-financial information allows for different, but acceptable, measurement techniques and can affect comparability between entities and over time. Our assurance approach Materiality We set thresholds for materiality at the planning stage and reassessed them during the engagement. These helped us to determine the nature, timing and extent of our procedures and to evaluate the effect of identified misstatements on the information presented, both individually and in aggregate. Based on our professional judgment, we determined specific materiality levels for each element of the Report. When determining our materiality thresholds, we considered the relevance of information for both the stakeholders and the organisations based on the materiality assessment of the organisations. Work done We are required to plan and perform our work in order to consider the risk of material misstatement of the information in the Report and Performance Indicators. Our work was carried out by an independent and multi-disciplinary team with experience in sustainability reporting and assurance and was performed at the head office in Amsterdam and at the Svenska PostkodLotteriet office in Sweden. Our most main procedures related to the Report were amongst others: performing an external environment analysis and obtaining an understanding of the relevant social issues, relevant laws and regulations and the characteristics of the organisations; evaluating the acceptability of the reporting policies and consistent application of this, such as assessment of the outcomes of the stakeholder dialogue and the process for determining the material subjects, the reasonableness of estimates made by management, as well as evaluating the overall presentation of the Report; understanding the systems and processes for data gathering, internal controls and processing of other information, such as the aggregation process of data to the information as presented in the Report; interviewing management and relevant staff at corporate and local level responsible for the sustainability strategy and policies; interviewing relevant staff responsible for providing the information in the Report, carrying out internal control procedures on the data and the consolidation of the data in the Report; analytical review of the data and trend explanations submitted for consolidation at group level; reviewing internal and external documentation to determine whether the information in the Report, including the disclosure, presentation and assertions made in the Report, is substantiated adequately; assessing whether the Report has been prepared ‘in accordance’ with the Sustainability Reporting Guidelines version G4 of GRI. In addition to the procedures mentioned above, for the Performance Indicators as included in the tables of Chapter 7 - Our performance, with the exception of ‘Scope 3: prizes & premiums’ included in the table ‘Energy and emissions’ we performed the following: Page | 20 assessing the systems and processes for data gathering, including testing the design, existence and the effectiveness of the relevant internal controls during the reporting year; conducting analytical procedures and substantive testing procedures on the relevant data; assessing the processing of other information, such as the aggregation process of data to the information as presented in the Performance Indicators; corroborating internal and external documentation to determine whether the Performance Indicators are substantiated adequately. Responsibilities The Executive Boards’ responsibilities The Executive Boards of the organisations are responsible for the preparation of the Report in accordance with the organisations’ Reporting Criteria, including the identification of the stakeholders and the determination of material subjects. Furthermore, the Executive Boards are responsible for such internal control as the Executive Boards determine is necessary to enable the preparation of the Report that is free from material misstatement, whether due to fraud or error. of ‘Scope 3: prizes & premiums’ included in the table ‘Energy and emissions’; and express a conclusion on all other information in the Report. This requires that we comply with ethical requirements and that we plan and perform our work to obtain reasonable and limited assurance about whether the Report is free from material misstatement. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the Report, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant for the preparation of the Report in order to design procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the organisations’ internal control. An assurance engagement aimed on providing limited and reasonable assurance also includes evaluating the appropriateness of the reporting framework used and the reasonableness of estimates made by management as well as evaluating the overall presentation of the Report. Amsterdam, 14 april 2016 PricewaterhouseCoopers Accountants N.V. Our responsibilities Based on our assurance engagement in accordance with Standard 3810N, our responsibility is to: express an opinion on the Performance Indicators included in the tables of Chapter 7 - Our performance, with the exception J.E.M. Brinkman RA Page | 21 11. Glossary of terms Achievements by beneficiaries made possible by charitable contributions: Providing insight in the accomplishments made possible by charitable contributions through beneficiaries. We split our total contribution in the following areas where our beneficiaries are active: international cooperation, human rights, nature and environment, health, social cohesion & wellbeing and culture. Fair and real cost pricing: The processes in place to accommodate paying the right price with external costs included. We ask our suppliers to commit to our supplier code of conduct and measure the percentage of significant suppliers that have signed the code. Good employment: Providing insight in the diversity of our workforce and emphasizing the principle that all human beings should be treated in the same way on a specific task and that no distinction is made regarding gender, race, age, religion, sexual orientation, transgender identity and/or disability. We focus our policy on equality between men and women and measure the diversity of our total workforce and management team. Responsible operations: The process by which we offer products/services that consumers can use in a responsible way. Also, the measures and methodologies in place to ensure customer privacy and consumer data protection. To track our progress we measure the percentage of relevant employees that have received training in the area of responsible operations. We also measure the incidents in relation to responsible operations. We also measure the number of complaints related to customer data protection and the number of identified leaks. Responsible operations include regulatory compliance which covers complying with applicable external and internal laws and regulations as well as voluntary standards. We measure the significant fines and non-monetary sanctions for non-compliance with laws and regulations. Responsible campaigning: The process by which we communicate factual and unbiased information and operate with fair contractual practices. By doing so we aim to minimize any misinterpretation by our (potential) players. We measure the number of incidents, warnings and fines of non-compliance with regulations and voluntary codes concerning marketing communications. Aim to have a positive impact on the planet with our own operations: We are focusing on purchasing green energy usage that is produced locally. The final aim is to produce our own renewable energy. We measure the consumption of district heating, electricity and natural gas in our offices. Additionally, we calculate the CO2e emissions of our printed communication, business air travel and prizes and premiums we purchase. Page | 22