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Societal Indicators

Fair Business Practices

Canal+ Group has formalized its commitments in its Ethics Charter and set

up a structured governance procedure for all expenditures and contracts

signed within the group. In addition, the Internal Audit department of

Canal+ Group has defined a quarterly census procedure to highlight any

fraud within the group, as well as defining the associated action plans.

In accordance with the group’s procedure for notifying fraud, established

by the Internal Audit department, this information is transmitted by the

operational departments.

All the employees of the Canal+ Group’s Purchasing department, Legal

departments and Audit department are made aware of the fight against

corruption. Moreover, in 2015, the governance procedures were presented

to the employees based in Paris during sessions held in April and June.

In addition, in the Polish subsidiary of Canal+ Group, the topic of fighting

corruption has appeared since November on the agenda of the training

modules given to new employees. An e-mail restating the guidelines

of this anti-corruption policy is also sent every year to operational

executives and to the members of the executive committee of nc+.

UMG is committed to adopting a “zero tolerance” approach to fraud

and corruption and to acting in a professional manner and with integrity

wherever the company operates, in accordance with local regulations

and with the 2010 UK Bribery Act. UMG has introduced a warning alert

system available to its employees: the group maintains a compliance

and ethics helpline number that can be called to anonymously report

any suspected violations of the UMG Code of Conduct. The helpline is

available twenty-four hours a day, seven days a week.

All the group’s employees have been made aware of the company’s Code

of Conduct which includes its anticorruption policy and must agree to

abide by it. UMG has also developed courses on the fight against fraud

and corruption. After a 2014 session in Asia, colleagues in Mexico,

Brazil and South Africa participated in training on the UK Bribery Act,

the Foreign Corrupt Practices Act and the UMG Code of Conduct. A total

of 279 employees participated in these training sessions (134 in Mexico,

101 in Brazil and 44 in South Africa).

In order to combat fraud and abuses in the ticketing black market, Digitick

set up zePass, a trusted third-party service, unique in France, enabling

the non-speculative resale of tickets between individuals on a secure

platform. zePass also offers event organizers (including L’Olympia) the

introduction of an official public market for ticket exchanges.

TOTAL NUMBER OF INCIDENTS HAVING RESULTED IN

NON-RENEWAL OF CONTRACTS WITH COMMERCIAL

PARTNERS DUE TO VIOLATIONS RELATED TO CORRUPTION

GRI

UNGC OECD Scope covered

G4-S05

10

II, VII

UMG

Canal+ Group

Vivendi Village

In 2015, Canal+ Group, UMG and Vivendi Village did not record any

incidents causing non-renewal of a contract with their business partners

as a result of violations linked to corruption.

4.5.2.

CONTRIBUTION TO PUBLIC POLICY/

RESPONSIBLE LOBBYING

Vivendi and its subsidiaries adopt transparent lobbying practices

(disclosure of membership in professional associations, registration

in lobbyist registers, and clear communication about the

main positions taken).

UMG and Canal+ Group are registered in the European Parliament and

Commission’s Transparency Register. In the United States, as required by

regulations, UMG declares its lobbying activities and related expenses in

quarterly reports sent to Congress.

SIGNIFICANT THEMES AND POSITIONS

TAKEN IN LOBBYING ACTIVITIES

GRI

UNGC OECD Scope covered

G4-DMA S0

Public Policy aspect

-

-

UMG

Canal+ Group

In 2015, Canal+ Group made its position known to French public

authorities on the following three significant issues in particular:

during debates on the draft bill for growth and economic activity

proposed by the French Minister of Economy, Industry and Digital

Affairs, the group defended the freedom of distributors of pay-TV

to offer specific editorialized packages which are different from the

numbering assigned by the CSA to the channels with a free-to-air

DTT offer;

with the arrival of new offers proposed by unregulated international

groups, discussions with public authorities have focused on the status

of these new players on the French market, and how this coexistence

will affect competition. These discussions were an opportunity to

recall the very onerous regulatory environment for pay-TV distributors

in France and the obligations imposed on Canal+ Group to finance

creation; and

with regard to projects and goals in relation to content development,

including original fiction, and in cooperation with public authorities,

in 2015, Canal+ Group also contributed to discussions intended to

continue the reform of relations between audiovisual broadcasters

and producers and improve the balance between them in order to

enable consolidation of the audiovisual groups and promote a better

return on investment.

In Poland, Canal+ Group is a member of Sygnał and PIRS (Polish Chamber

of Broadcasters), which work to protect intellectual property and which

contributed in 2015 to the European debate on the single digital market

and the revisions of the Satellite and Cable Directive. In Africa, in addition

to its upstream positioning on calls for tenders, the group is making

efforts to raise the awareness of authorities about combating piracy,

particularly through its membership in the association Convergence (see

Section 4.3 of this chapter).

Universal Music Group belongs to several industry associations (such as

IFPI at the worldwide level and national affiliates including BPI in the

United Kingdom and SNEP in France) through which it conducts many of

its lobbying activities. These associations make their positions known

EXTRA-FINANCIAL INDICATORS HANDBOOK

2015

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