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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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).
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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:
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



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
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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.
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