As one of the leading sports and entertainment media groups in the world, beIN Media Group is constantly inspired by its vision for how a global media company in the twenty-first century should set an example and lead the industry. Our group is determined not only to be considered as a reliable service provider and a major player in the market, but also to be a pioneer for progress and a catalyst for positive change in our increasingly interconnected world.
It is our belief that by broadcasting sports and entertainment content to citizens and communities all around the globe – from the Middle East and Europe to Asia Pacific and North America – beIN Media Group has a responsibility in building the world of tomorrow: a world in which equal access to information is guaranteed; where a common respect and understanding of differences in culture and background is encouraged and promoted; and where the rich diversity of the constantly changing world that we live in is championed every day, bringing the world closer together.
That is why beIN Media Group has been committed since its launch to promoting the values of sportsmanship, fair play, honor and dignity, team spirit and mutual solidarity. We believe that these values, coupled with the universal principles at the heart of our identity – accountability, integrity, and respect – will build a better world for tomorrow, in which there is more that unites than divides.
In this context, the confidence and loyalty that our stakeholders place in our group means that we have to conduct our business activities in accordance with all applicable laws and regulations in all countries where we operate. We also have a duty to constantly improve our service and to strive for excellence in everything we do to build a sustainable future.
Business ethics is not a matter reserved for the few: all individuals associated with beIN Media Group contribute every day to its success through their participation in our culture of mutual responsibility and commitment to integrity and compliance. It is only through leading by example, both as individuals and collectively, that beIN Media Group will continue to be a pioneer for progress and a catalyst for positive change. This code of business conduct (the “Code”) constitutes the cornerstone of beIN Media Group’s Global Compliance Program and is especially aimed at preventing and addressing bribery and corruption risks that our enterprise may face in the context of its global activities, and encouraging all beIN MEDIA GROUP Associates to act with integrity and do the right thing in our dealings with each other, our customers and the communities that we serve. Our Global Compliance Program includes in particular:
- this Code,
- an anti-bribery & anti-corruption policy,
- a working with third parties’ policy, and
- a speak up whistleblowing policy.
All of these policies will also be made available on the beIN Media Group intranet. Any compliance tools that our group has developed or will develop in the future in the context of this Global Compliance Program, including a standard set of contractual compliance clauses, are also made available on our intranet site.
This Code applies to beIN Media Group LLC and all its affiliates, including its subsidiaries and its shareholders (“beIN Media Group”), as well as all individuals working for or occupying any position or office within beIN Media Group, wherever located and whatever their status (“Associates”), its consultants, contractors, agents and any other persons acting for or on its behalf or otherwise associated with it.
General principle: In some countries local laws and regulations may be more stringent or detailed than the principles set out in this Code. Where this is the case, the more stringent and/or detailed rules apply.
If you have any question about this Code, (i) which relates to a matter, contract, issue, relationship or interaction of a Local Nature (as defined below) please contact your manager, the Local Compliance Officer (“LCO”, i.e. the local employee designated as responsible for compliance) or the Local Compliance Committee (“LCC”), or (ii) which relates to a matter, contract, issue, relationship or interaction of a Group Nature (as defined below) please contact the beIN Media Group General Counsel, the Chief Compliance Officer (“CCO”) or the Group Compliance Committee (“GCC”). Any suspected violations of this Code or of any other beIN MEDIA GROUP policies, should be reported immediately in accordance with the beIN Media Group speak up whistleblowing policy.
A matter, contract, issue, relationship or interaction is of Local Nature, if it is specifically linked to a beIN Media Group subsidiary or a jurisdiction/region
A matter, contract, issue, relationship or interaction is of Group Nature, if it concerns group projects e.g. in the field of M&A, strategy, digital, is not specifically linked to a beIN Media Group subsidiary, jurisdiction or region, concerns a region which is not covered by any LCC, has been referred by the LCC to the GCC or is deemed by the GCC to require its involvement.
Respect of all laws and regulations applicable to us is the responsibility of each Associate and more generally of all persons acting for or on behalf of beIN MEDIA GROUP. Therefore, our group expects that each individual fully understands and complies with our internal policies.
Delegation to Associates does not relieve managers of their overall responsibility. Likewise, the overall responsibility of the management does not relieve Associates of their individual responsibilities.
• know and fully comply with all relevant laws and regulations that apply to beIN Media Group as well as with all internal policies included within beIN Media Group’s Global Compliance Program and any other policies that beIN Media Group may adopt in the future,
• engage in honest and ethical conduct, including avoiding any actual or apparent conflicts of interest between personal affairs and professional duties to beIN Media Group, protecting our group’s reputation, property and confidential information, fostering a good working environment, and more generally helping beIN Media Group to ensure that its Global Compliance Program is effectively implemented and complied with in all jurisdictions where we operate.
To help you know your duties and the applicable rules, beIN Media Group provides training tailored to the role and mission upon recruitment of all new Associates and will provide periodic training thereafter in compliance with the training plan determined by beIN Media Group.
All managers are accountable for ensuring appropriate communication and shall endeavor to detect compliance issues in their respective areas of responsibility (for instance by following-up on red flags, implementing adequate supervision of operational teams, ensuring that all tasks are adequately staffed considering the required workforce and expertise, demonstrating by their conduct and tone their commitment to ethics, compliance and our Global Compliance Program). Managers must carefully select employees based on their personal and professional qualifications, and assess employee performance based on criteria that must include a compliance component, such as integrity and adherence to beIN Media Group’s Global Compliance Program.
The board of directors bears overall responsibility for creating a work and business environment that fosters compliance with laws and where there is zero tolerance for deviations from applicable laws and our Global Compliance Program. The board of directors is committed to ensuring that a proper level of supervision is maintained throughout beIN MEDIA GROUP considering its activities and risks related thereto.
In this respect beIN Media Group also requires that all third parties associated with it commit to respect its compliance policies or to evidence that they have effectively implemented their own policies aimed at ensuring compliance with laws and regulations, in particular as regards probity and integrity.
In all situations where the requirements of applicable laws and regulations, of this Code or of any other beIN Media Group policy appear incomplete or unclear, Associates shall use good judgment and common sense and seek advice, if needed, from their manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or GCC, as applicable, depending on the Local or Group Nature of the relevant matter or issue.
Example Your colleague asks you to route free of charge products to third party commercial and technical service providers or to grant discounts to a business partner in violation of approved processes and policies.
A first course of action may be to express your concerns directly to your manager. If you feel your manager has not adequately addressed your concerns or if you are uncomfortable raising the issue with him/her, you can take further steps to resolve this issue by contacting any appropriate manager, your LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC, as applicable, or raise the issue via beIN Media Group’s speak up whistleblowing policy.
Bribery and corruption gravely distort fair market conditions, constitute a threat to society and are prohibited in most countries of the world. Beyond the fact that the fight against bribery and corruption is therefore a legal obligation for beIN Media Group, we adopt, as part of our compliance commitment, a zero-tolerance approach to any type of bribery, corruption or related activities from Associates or any third parties acting for us or on our behalf, or otherwise associated with us.
We expect our Associates and counterparts to strictly adhere to this approach, which is a prerequisite condition of having any work or business relationship with beIN Media Group.
Bribery and corruption» refer to :
• direct or indirect offering, promising, or giving anything of value with the intention of improperly influencing or rewarding the behavior of someone, whether a private person or a public official, to, notably but not limited thereto, obtain or retain a commercial, contractual, regulatory or personal advantage, or in exchange for such person to abuse his real or alleged influence to obtain any favorable decision from a public body, or
• soliciting or receiving anything of value in the above conditions.
All such behaviors are strictly prohibited by beIN Media Group. This prohibition of bribery and corruption applies indifferently to interactions with domestic and foreign public officials as well as to bribery and corruption between private commercial counterparts, and also extends to influence peddling, facilitation payments, illegal kickbacks, and any other unlawful payments or similar behaviors aimed at obtaining undue advantages in exchange for benefits, regardless of whether or not the national laws of a given country prohibit all such conducts.
An infringement of anti-bribery and anti-corruption laws and regulations may result in significant fines and other sanctions for beIN Media Group and its Associates, including jail sentences, fines and penalties for involved individuals.
Any Associate who participates in any such activities may also be subject to strict disciplinary action, including termination of employment, mission, office or assignment in compliance with applicable laws.
beIN Media Group has adopted specific policies that will help you better address situations requiring a particular level of attention, applicable to the following risk areas:
• Interactions with public officials
they represent unique compliance risks considering in particular that public officials are often subject to specific rules and restrictions regarding the interactions they may have with the private sector (including higher scrutiny from the authorities that leads to higher sanctions). Associates are responsible for complying with the rules or prohibitions applicable to these interactions as set out in the anti-bribery & anti-corruption policy.
• Interactions with third parties
considering the fact that our group makes extensive use of third parties, we have adopted rigorous and robust control mechanisms aiming to ensure that the third parties we select and with whom we work not only provide the quality and value that best meet defined needs, but are also committed to respecting the values of compliance and integrity that are at the core of our way of doing business. The selection and the monitoring of the activities of third parties are governed by the working with third parties policy and, where applicable, the beIN Media Group Tendering and Auctions Policy and/or local tender procedures, if any, or any other specific additional policies.
• Gifts, hospitality and invitations & Grants, donations and sponsorship
the anti-bribery & anti-corruption policy sets out a list of situations where gifts, hospitality and invitations are prohibited, further specifies the procedure and applicable thresholds (including through our internal rules) for situations where gifts, hospitality and invitations are acceptable, and explains what prior verifications and procedures must be followed to approve making donations or grants or to sponsor an event.
You are negotiating an agreement with a third-party representative for a territory known to involve a considerable bribery and corruption risk. The third party explains that in the relevant territory it is a standard process that the service provider receives a significant upfront payment to cover any business expenses, including in particular gifts, invitations, and hospitality to local public officials.
This situation presents several risks and you should not proceed without consulting with your manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC, as applicable, depending on the Local or Group Nature of the relevant matter or issue. In order to select a third party, you must carry out an extensive risk-based due diligence and make sure to comply with applicable tender or other contract procedures, (depending on the case) the beIN Media Group Tendering and Auctions Policy, local tender procedures (if any) or any other specific additional policies. Any unusual payment terms (such as upfront payments) that may involve a compliance risk must be separately assessed on a case-by-case basis by your manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC, as applicable. In addition, gifts, invitations and hospitality to public officials raise particular compliance risks and beIN MEDIA GROUP has therefore adopted specific rules regarding such situations.
Prevention of conflicts of interest is an essential component of our way of working and constitutes one of the cornerstones of free and fair markets. It is therefore important for beIN MEDIA GROUP that all Associates understand which situations may raise conflicts of interests and know how to avoid, and as the case may be, resolve them.
A “conflict of interest” occurs when the personal interests of an Associate interfere in any way – or even appear to interfere – with the interests of beIN Media Group. A conflict of interest can also arise from personal interests of a family member, a close friend or a business partner of an Associate.
As all Associates must avoid any situation that may interfere with the interests of beIN Media Group, it is their responsibility to contact their manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC depending on whether the matter or issue is of a Local or Group Nature in any situation of potential conflict of interest without delay before accepting to undertake work or to continue to work on the relevant matter / decision.
A conflicted Associate may not participate in any way in the relevant matter / decision (whether being present at the decision-making process or by preparing the matter). However, on a case-by-case basis, the person to whom the conflict was declared can decide, after analysis, to maintain the relevant Associate on the matter / decision in question, provided that the conflict is deemed not to impact the objective and appropriate handling of the matter / decision and is in whole minor and indirect. If the declaration of conflict of interest does not contain sufficient factual details to allow an assessment of the impact of the conflict, the relevant Associate will be requested to stop working on the matter / decision in question immediately.
A proper implementation of the working with third parties policy and, where applicable, the beIN Media Group Tendering and Auctions Policy and/or local tender procedures, is important to identify and mitigate the risks associated with conflicts of interests.
These rules apply to Associates at all levels. Any reported conflict of interest situation must be recorded in a confidential register kept by the LCO of the concerned beIN Media Group entity, subject to local laws, and such register will be reviewed regularly by the applicable LCC. A synthesis of these local registers is prepared annually by the beIN Media Group General Counsel or CCO and is subject to annual review by the GCC.
Example You are in charge of selecting sales agents from whom a proposal will be solicited in the context of a product launch in your country. You believe that your niece has exactly the expertise that is required.
You may suggest the name of your niece’s company, after having declared the existence of the conflict of interest, but cannot participate in the selection of the bidders.
beIN Media Group is committed to complying with all domestic and international laws and regulations relating to the prevention of money laundering and terrorism financing, and firmly prohibits any behavior that could violate such laws or regulations.
“Money laundering” refers to the process of concealing the illegal origin (e.g., terrorism, bribery, corruption, fraud, etc.) of assets by introducing them into the regular financial cycle.
Associates and all people acting for or on behalf of beIN Media Group are strictly prohibited from participating in any business activity that violates applicable laws or regulations regarding the prevention of money laundering and terrorism financing. To this end, beIN Media Group provides the relevant Associates with adequate guidance and training regarding identification of at-risk situations and requires them to report any known or suspected events immediately to their manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC depending on whether the issue is of a Local or Group Nature so that they may determine the appropriate course of action. Moreover, beIN Media Group will conduct business only with vetted third parties that are involved in legitimate and lawful business transactions and activities.
Involvement in money laundering or terrorism financing may result in significant fines and other sanctions for beIN Media Group and its Associates, including jail sentences, fines and penalties for involved individuals.
Any Associate who participates in any such activities, may also be subject to strict disciplinary action, including termination of employment, mission, office or assignment in compliance with applicable laws.
A proper implementation of the working with third parties policy is important to identify and mitigate the risks associated with money laundering.
Example A business partner requests you to route a payment to an off-shore account of a company that you do not know rather than to the business partner’s local bank account.
You should never agree to wire funds to a bank account other than the one mentioned in the written agreement with the business partner. Unnecessarily complex transaction structures can also hide money laundering activities.
Due to beIN Media Group’s global presence, it continuously monitors national and international trade laws and regulations to ensure that its business activities comply with such rules and do not infringe any related embargo or international sanctions.
beIN Media Group’s business transactions may, due to their global nature, be subject to various trade laws and regulations. Furthermore, international (including, unilateral) decisions may restrict or prohibit economic or commercial relations with a particular state or group of individuals or entities.
As a consequence, beIN Media Group may face particularly severe sanctions if it fails to comply with such international regulations and decisions, which could even ultimately challenge the future of our business model and the durability of our activities.
It is therefore of utmost importance that Associates act in accordance with all applicable laws, rules and regulations relating to embargo laws and trade sanctions.
A proper implementation of the working with third parties policy is important to identify and mitigate the risks associated with embargoes and trade sanctions.
In case of doubt, Associates must contact their manager and request further instruction. If needed, you or your manager must solicit and obtain adequate advice and clearance on the matter from the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC depending on whether the issue is of a Local or Group Nature to ensure that all transactions are properly evaluated to prevent any potential violations.
Example beIN Media Group is considering acquiring a company that operates in various countries of a continent. Reviewing the list of countries from which the turnover originates, you realize that some of them might be subject to international sanctions.
You must bring this possibility to the attention of your manager without delay and obtain adequate advice and clearance before proceeding with the transaction.
beIN Media Group operates in a large number of diverse countries in a highly competitive environment and is committed to the principle of unrestricted markets and fair competition. Understanding and working in compliance with anti-trust laws and regulations enables us to compete effectively and fairly on a level playing field and to foster value and continuation of our business.
Many countries where beIN Media Group is operating have adopted laws and regulations aimed at preventing adverse effects of unfair market practices on their economies and populations. As one of the leading sports and entertainment media groups in the world, beIN Media Group must assess in detail its market behavior in order to avoid at-risk situations. Likewise, all Associates must deal fairly with our customers, suppliers, and other third parties and conduct our business with integrity and honesty.
Infringement of anti-trust laws and regulations may lead to extremely high fines as well as other sanctions and adverse consequences, including significant reputational damage. It is the responsibility of each concerned Associate to know all applicable anti-trust laws and regulations and comply with them, together with any and all internal rules that may be adopted by beIN Media Group from time to time in this respect.
In case of doubt, Associates must contact their manager and request further instruction. If needed, you or your manager must solicit adequate advice on the matter from the General Counsel to ensure that all transactions are properly evaluated to prevent potential violations.
Example You attend a football match where representatives of several other companies operating in the sports rights distribution sector are present. A representative of one of these competitor companies starts discussing recent deals and their prices (or other similar topics, such as, costs, business strategy, rebates, discounts, and volumes).
You must not share any information and more generally, are required to immediately put an end to the discussion. Such situations should be reported to your manager, the LCO, the LCC, the GCC or the CCO depending on whether the matter or issue is of a Local or of a Group Nature.
As a major sports and entertainment content distributor worldwide, it is essential for beIN Media Group to protect fundamental rights of its Associates and to create a safe, fair and equal work environment for all of them. All Associates will be treated and are expected to treat others with dignity and respect.
As part of its commitment to foster human rights, beIN Media Group:
• does not tolerate any harassment or discrimination in any form. beIN Media Group is committed to equal treatment of all its Associates irrespective of, notably, origin, race, color, gender, religion, age, citizenship, disability, or any other criterion determined by local laws or regulations,
• prohibits all forms of forced labor and child labor within it and is committed to fair employment practices in compliance with the applicable labor and employment laws and regulations,
• recognizes that the health, safety and wellbeing of its Associates is an integral and essential part of all its business activities. It is the responsibility and duty of each and every Associate to comply with health and safety measures and to follow all relevant laws, rules, regulations, and work instructions.
Example If you are aware of a case of potential human rights violation, a first course of action may be to express your concerns directly to your manager. If you feel your manager has not adequately addressed your concerns or if you are uncomfortable raising the issue with him/her, you can take further steps to resolve this issue by contacting any appropriate manager, your LCO, the LCC, the GCC or the CCO depending on whether the matter or issue is of a Local or of a Group Nature, or raise the issue via beIN Media Group’s speak up whistleblowing policy.
beIN Media Group is committed to complying with all applicable privacy and data protection laws and regulations in all countries where we do business.
“Personal data” is commonly defined as information that can be used on its own or with other information to identify, contact, or locate an individual.
Any and all collection, processing, and use of personal data that could be required for the purpose of our activities will be done in accordance with applicable data privacy and data protection laws and regulations.
All Associates are responsible for the handling of personal data and information in an appropriate manner and in compliance with applicable privacy and data protection laws and regulations. Various countries have their own laws and regulations about the collection, processing, and use of personal data. If you are unsure about what is permissible, you are required to consult with your manager or your LCO for further clarification.
Example An entity of beIN Media Group has developed an update to its apps that would enhance marketing automation features thereof, but is unsure whether the previously collected consents cover such enhanced collection of data.
Prior to launching the update, it must be verified whether the resulting collection of data is compliant with the relevant privacy and data protection laws and regulations.
Protecting confidential information and beIN Media Group’s intellectual property is important for our economic success. Whereas all Associates are required to maintain and foster strict confidentiality of all relevant information pertaining to our business, beIN MEDIA GROUP will guarantee adequate transparency and sharing of information within the group to allow Associates to properly carry out their duties and missions.
“Confidential information”, as defined by beIN Media Group, includes all non-public information, in particular but not limited to information that might be of use to competitors, or harmful to beIN MEDIA GROUP or its customers, if disclosed. All Associates are required to keep all information received as part of their work confidential.
Associates are responsible for the protection of any beIN Media Group confidential information available to them. No such information shall be disclosed and shared with an unrelated individual (inside or outside beIN Media Group) or used for one’s own benefit.
All Associates will have access to any information required to properly perform their duties, missions and legally required declarations, including allowing them to duly confirm that all records and reports they must draw up or disclose are true, accurate and complete.
All reports, documents or communications authorized or legally mandated for disclosure to the public shall be full, fair, accurate, timely and understandable. Moreover, all business transactions must be recorded in a true, accurate and complete fashion. In accordance with established procedures and generally accepted accounting principles, all Associates shall ensure the reliability and accuracy of our accounts and records.
Associates are encouraged to report promptly any suspected violations of laws, rules, regulations or of any policy that is part of beIN Media Group’s Global Compliance Program, in accordance with the speak up whistleblowing policy.
Ethics & Compliance
Code of Business Conduct
As one of the leading sports and entertainment media groups in the world, beIN Media Group is constantly inspired by its vision for how a global media company in the twenty-first century should set an example and lead the industry. Our group is determined not only to be considered as a reliable service provider and a major player in the market, but also to be a pioneer for progress and a catalyst for positive change in our increasingly interconnected world.
It is our belief that by broadcasting sports and entertainment content to citizens and communities all around the globe – from the Middle East and Europe to Asia Pacific and North America – beIN Media Group has a responsibility in building the world of tomorrow: a world in which equal access to information is guaranteed; where a common respect and understanding of differences in culture and background is encouraged and promoted; and where the rich diversity of the constantly changing world that we live in is championed every day, bringing the world closer together.
That is why beIN Media Group has been committed since its launch to promoting the values of sportsmanship, fair play, honor and dignity, team spirit and mutual solidarity. We believe that these values, coupled with the universal principles at the heart of our identity – accountability, integrity, and respect – will build a better world for tomorrow, in which there is more that unites than divides.
In this context, the confidence and loyalty that our stakeholders place in our group means that we have to conduct our business activities in accordance with all applicable laws and regulations in all countries where we operate. We also have a duty to constantly improve our service and to strive for excellence in everything we do to build a sustainable future.
Business ethics is not a matter reserved for the few: all individuals associated with beIN Media Group contribute every day to its success through their participation in our culture of mutual responsibility and commitment to integrity and compliance. It is only through leading by example, both as individuals and collectively, that beIN Media Group will continue to be a pioneer for progress and a catalyst for positive change. This code of business conduct (the “Code”) constitutes the cornerstone of beIN Media Group’s Global Compliance Program and is especially aimed at preventing and addressing bribery and corruption risks that our enterprise may face in the context of its global activities, and encouraging all beIN MEDIA GROUP Associates to act with integrity and do the right thing in our dealings with each other, our customers and the communities that we serve. Our Global Compliance Program includes in particular:
All of these policies will also be made available on the beIN Media Group intranet. Any compliance tools that our group has developed or will develop in the future in the context of this Global Compliance Program, including a standard set of contractual compliance clauses, are also made available on our intranet site.
This Code applies to beIN Media Group LLC and all its affiliates, including its subsidiaries and its shareholders (“beIN Media Group”), as well as all individuals working for or occupying any position or office within beIN Media Group, wherever located and whatever their status (“Associates”), its consultants, contractors, agents and any other persons acting for or on its behalf or otherwise associated with it.
General principle: In some countries local laws and regulations may be more stringent or detailed than the principles set out in this Code. Where this is the case, the more stringent and/or detailed rules apply.
If you have any question about this Code, (i) which relates to a matter, contract, issue, relationship or interaction of a Local Nature (as defined below) please contact your manager, the Local Compliance Officer (“LCO”, i.e. the local employee designated as responsible for compliance) or the Local Compliance Committee (“LCC”), or (ii) which relates to a matter, contract, issue, relationship or interaction of a Group Nature (as defined below) please contact the beIN Media Group General Counsel, the Chief Compliance Officer (“CCO”) or the Group Compliance Committee (“GCC”). Any suspected violations of this Code or of any other beIN MEDIA GROUP policies, should be reported immediately in accordance with the beIN Media Group speak up whistleblowing policy.
A matter, contract, issue, relationship or interaction is of Local Nature, if it is specifically linked to a beIN Media Group subsidiary or a jurisdiction/region
A matter, contract, issue, relationship or interaction is of Group Nature, if it concerns group projects e.g. in the field of M&A, strategy, digital, is not specifically linked to a beIN Media Group subsidiary, jurisdiction or region, concerns a region which is not covered by any LCC, has been referred by the LCC to the GCC or is deemed by the GCC to require its involvement.
1. Accountability
Respect of all laws and regulations applicable to us is the responsibility of each Associate and more generally of all persons acting for or on behalf of beIN MEDIA GROUP. Therefore, our group expects that each individual fully understands and complies with our internal policies.
Delegation to Associates does not relieve managers of their overall responsibility. Likewise, the overall responsibility of the management does not relieve Associates of their individual responsibilities.
Each Associate is required to:
• know and fully comply with all relevant laws and regulations that apply to beIN Media Group as well as with all internal policies included within beIN Media Group’s Global Compliance Program and any other policies that beIN Media Group may adopt in the future,
• engage in honest and ethical conduct, including avoiding any actual or apparent conflicts of interest between personal affairs and professional duties to beIN Media Group, protecting our group’s reputation, property and confidential information, fostering a good working environment, and more generally helping beIN Media Group to ensure that its Global Compliance Program is effectively implemented and complied with in all jurisdictions where we operate.
To help you know your duties and the applicable rules, beIN Media Group provides training tailored to the role and mission upon recruitment of all new Associates and will provide periodic training thereafter in compliance with the training plan determined by beIN Media Group.
All managers are accountable for ensuring appropriate communication and shall endeavor to detect compliance issues in their respective areas of responsibility (for instance by following-up on red flags, implementing adequate supervision of operational teams, ensuring that all tasks are adequately staffed considering the required workforce and expertise, demonstrating by their conduct and tone their commitment to ethics, compliance and our Global Compliance Program). Managers must carefully select employees based on their personal and professional qualifications, and assess employee performance based on criteria that must include a compliance component, such as integrity and adherence to beIN Media Group’s Global Compliance Program.
The board of directors bears overall responsibility for creating a work and business environment that fosters compliance with laws and where there is zero tolerance for deviations from applicable laws and our Global Compliance Program. The board of directors is committed to ensuring that a proper level of supervision is maintained throughout beIN MEDIA GROUP considering its activities and risks related thereto.
In this respect beIN Media Group also requires that all third parties associated with it commit to respect its compliance policies or to evidence that they have effectively implemented their own policies aimed at ensuring compliance with laws and regulations, in particular as regards probity and integrity.
In all situations where the requirements of applicable laws and regulations, of this Code or of any other beIN Media Group policy appear incomplete or unclear, Associates shall use good judgment and common sense and seek advice, if needed, from their manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or GCC, as applicable, depending on the Local or Group Nature of the relevant matter or issue.
Example Your colleague asks you to route free of charge products to third party commercial and technical service providers or to grant discounts to a business partner in violation of approved processes and policies.
A first course of action may be to express your concerns directly to your manager. If you feel your manager has not adequately addressed your concerns or if you are uncomfortable raising the issue with him/her, you can take further steps to resolve this issue by contacting any appropriate manager, your LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC, as applicable, or raise the issue via beIN Media Group’s speak up whistleblowing policy.
2. Integrity
2.1. Fight against Bribery and Corruption
Bribery and corruption gravely distort fair market conditions, constitute a threat to society and are prohibited in most countries of the world. Beyond the fact that the fight against bribery and corruption is therefore a legal obligation for beIN Media Group, we adopt, as part of our compliance commitment, a zero-tolerance approach to any type of bribery, corruption or related activities from Associates or any third parties acting for us or on our behalf, or otherwise associated with us.
We expect our Associates and counterparts to strictly adhere to this approach, which is a prerequisite condition of having any work or business relationship with beIN Media Group.
Bribery and corruption» refer to :
• direct or indirect offering, promising, or giving anything of value with the intention of improperly influencing or rewarding the behavior of someone, whether a private person or a public official, to, notably but not limited thereto, obtain or retain a commercial, contractual, regulatory or personal advantage, or in exchange for such person to abuse his real or alleged influence to obtain any favorable decision from a public body, or
• soliciting or receiving anything of value in the above conditions.
All such behaviors are strictly prohibited by beIN Media Group. This prohibition of bribery and corruption applies indifferently to interactions with domestic and foreign public officials as well as to bribery and corruption between private commercial counterparts, and also extends to influence peddling, facilitation payments, illegal kickbacks, and any other unlawful payments or similar behaviors aimed at obtaining undue advantages in exchange for benefits, regardless of whether or not the national laws of a given country prohibit all such conducts.
An infringement of anti-bribery and anti-corruption laws and regulations may result in significant fines and other sanctions for beIN Media Group and its Associates, including jail sentences, fines and penalties for involved individuals.
Any Associate who participates in any such activities may also be subject to strict disciplinary action, including termination of employment, mission, office or assignment in compliance with applicable laws.
beIN Media Group has adopted specific policies that will help you better address situations requiring a particular level of attention, applicable to the following risk areas:
• Interactions with public officials
they represent unique compliance risks considering in particular that public officials are often subject to specific rules and restrictions regarding the interactions they may have with the private sector (including higher scrutiny from the authorities that leads to higher sanctions). Associates are responsible for complying with the rules or prohibitions applicable to these interactions as set out in the anti-bribery & anti-corruption policy.
• Interactions with third parties
considering the fact that our group makes extensive use of third parties, we have adopted rigorous and robust control mechanisms aiming to ensure that the third parties we select and with whom we work not only provide the quality and value that best meet defined needs, but are also committed to respecting the values of compliance and integrity that are at the core of our way of doing business. The selection and the monitoring of the activities of third parties are governed by the working with third parties policy and, where applicable, the beIN Media Group Tendering and Auctions Policy and/or local tender procedures, if any, or any other specific additional policies.
• Gifts, hospitality and invitations & Grants, donations and sponsorship
the anti-bribery & anti-corruption policy sets out a list of situations where gifts, hospitality and invitations are prohibited, further specifies the procedure and applicable thresholds (including through our internal rules) for situations where gifts, hospitality and invitations are acceptable, and explains what prior verifications and procedures must be followed to approve making donations or grants or to sponsor an event.
You are negotiating an agreement with a third-party representative for a territory known to involve a considerable bribery and corruption risk. The third party explains that in the relevant territory it is a standard process that the service provider receives a significant upfront payment to cover any business expenses, including in particular gifts, invitations, and hospitality to local public officials.
This situation presents several risks and you should not proceed without consulting with your manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC, as applicable, depending on the Local or Group Nature of the relevant matter or issue. In order to select a third party, you must carry out an extensive risk-based due diligence and make sure to comply with applicable tender or other contract procedures, (depending on the case) the beIN Media Group Tendering and Auctions Policy, local tender procedures (if any) or any other specific additional policies. Any unusual payment terms (such as upfront payments) that may involve a compliance risk must be separately assessed on a case-by-case basis by your manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC, as applicable. In addition, gifts, invitations and hospitality to public officials raise particular compliance risks and beIN MEDIA GROUP has therefore adopted specific rules regarding such situations.
2.2. Prevention of Conflicts of Interest
Prevention of conflicts of interest is an essential component of our way of working and constitutes one of the cornerstones of free and fair markets. It is therefore important for beIN MEDIA GROUP that all Associates understand which situations may raise conflicts of interests and know how to avoid, and as the case may be, resolve them.
A “conflict of interest” occurs when the personal interests of an Associate interfere in any way – or even appear to interfere – with the interests of beIN Media Group. A conflict of interest can also arise from personal interests of a family member, a close friend or a business partner of an Associate.
As all Associates must avoid any situation that may interfere with the interests of beIN Media Group, it is their responsibility to contact their manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC depending on whether the matter or issue is of a Local or Group Nature in any situation of potential conflict of interest without delay before accepting to undertake work or to continue to work on the relevant matter / decision.
A conflicted Associate may not participate in any way in the relevant matter / decision (whether being present at the decision-making process or by preparing the matter). However, on a case-by-case basis, the person to whom the conflict was declared can decide, after analysis, to maintain the relevant Associate on the matter / decision in question, provided that the conflict is deemed not to impact the objective and appropriate handling of the matter / decision and is in whole minor and indirect. If the declaration of conflict of interest does not contain sufficient factual details to allow an assessment of the impact of the conflict, the relevant Associate will be requested to stop working on the matter / decision in question immediately.
A proper implementation of the working with third parties policy and, where applicable, the beIN Media Group Tendering and Auctions Policy and/or local tender procedures, is important to identify and mitigate the risks associated with conflicts of interests.
These rules apply to Associates at all levels. Any reported conflict of interest situation must be recorded in a confidential register kept by the LCO of the concerned beIN Media Group entity, subject to local laws, and such register will be reviewed regularly by the applicable LCC. A synthesis of these local registers is prepared annually by the beIN Media Group General Counsel or CCO and is subject to annual review by the GCC.
Example You are in charge of selecting sales agents from whom a proposal will be solicited in the context of a product launch in your country. You believe that your niece has exactly the expertise that is required.
You may suggest the name of your niece’s company, after having declared the existence of the conflict of interest, but cannot participate in the selection of the bidders.
2.3. Fight against Money Laundering and Terrorism Financing
beIN Media Group is committed to complying with all domestic and international laws and regulations relating to the prevention of money laundering and terrorism financing, and firmly prohibits any behavior that could violate such laws or regulations.
“Money laundering” refers to the process of concealing the illegal origin (e.g., terrorism, bribery, corruption, fraud, etc.) of assets by introducing them into the regular financial cycle.
Associates and all people acting for or on behalf of beIN Media Group are strictly prohibited from participating in any business activity that violates applicable laws or regulations regarding the prevention of money laundering and terrorism financing. To this end, beIN Media Group provides the relevant Associates with adequate guidance and training regarding identification of at-risk situations and requires them to report any known or suspected events immediately to their manager, the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC depending on whether the issue is of a Local or Group Nature so that they may determine the appropriate course of action. Moreover, beIN Media Group will conduct business only with vetted third parties that are involved in legitimate and lawful business transactions and activities.
Involvement in money laundering or terrorism financing may result in significant fines and other sanctions for beIN Media Group and its Associates, including jail sentences, fines and penalties for involved individuals.
Any Associate who participates in any such activities, may also be subject to strict disciplinary action, including termination of employment, mission, office or assignment in compliance with applicable laws.
A proper implementation of the working with third parties policy is important to identify and mitigate the risks associated with money laundering.
Example A business partner requests you to route a payment to an off-shore account of a company that you do not know rather than to the business partner’s local bank account.
You should never agree to wire funds to a bank account other than the one mentioned in the written agreement with the business partner. Unnecessarily complex transaction structures can also hide money laundering activities.
2.4. Compliance with Embargo Laws and Trade Sanctions
Due to beIN Media Group’s global presence, it continuously monitors national and international trade laws and regulations to ensure that its business activities comply with such rules and do not infringe any related embargo or international sanctions.
beIN Media Group’s business transactions may, due to their global nature, be subject to various trade laws and regulations. Furthermore, international (including, unilateral) decisions may restrict or prohibit economic or commercial relations with a particular state or group of individuals or entities.
As a consequence, beIN Media Group may face particularly severe sanctions if it fails to comply with such international regulations and decisions, which could even ultimately challenge the future of our business model and the durability of our activities.
It is therefore of utmost importance that Associates act in accordance with all applicable laws, rules and regulations relating to embargo laws and trade sanctions.
A proper implementation of the working with third parties policy is important to identify and mitigate the risks associated with embargoes and trade sanctions.
In case of doubt, Associates must contact their manager and request further instruction. If needed, you or your manager must solicit and obtain adequate advice and clearance on the matter from the LCO, the LCC, the beIN Media Group General Counsel, the CCO or the GCC depending on whether the issue is of a Local or Group Nature to ensure that all transactions are properly evaluated to prevent any potential violations.
Example beIN Media Group is considering acquiring a company that operates in various countries of a continent. Reviewing the list of countries from which the turnover originates, you realize that some of them might be subject to international sanctions.
You must bring this possibility to the attention of your manager without delay and obtain adequate advice and clearance before proceeding with the transaction.
2.5. Promoting Fair and Unfettered Competition
beIN Media Group operates in a large number of diverse countries in a highly competitive environment and is committed to the principle of unrestricted markets and fair competition. Understanding and working in compliance with anti-trust laws and regulations enables us to compete effectively and fairly on a level playing field and to foster value and continuation of our business.
Many countries where beIN Media Group is operating have adopted laws and regulations aimed at preventing adverse effects of unfair market practices on their economies and populations. As one of the leading sports and entertainment media groups in the world, beIN Media Group must assess in detail its market behavior in order to avoid at-risk situations. Likewise, all Associates must deal fairly with our customers, suppliers, and other third parties and conduct our business with integrity and honesty.
Infringement of anti-trust laws and regulations may lead to extremely high fines as well as other sanctions and adverse consequences, including significant reputational damage. It is the responsibility of each concerned Associate to know all applicable anti-trust laws and regulations and comply with them, together with any and all internal rules that may be adopted by beIN Media Group from time to time in this respect.
In case of doubt, Associates must contact their manager and request further instruction. If needed, you or your manager must solicit adequate advice on the matter from the General Counsel to ensure that all transactions are properly evaluated to prevent potential violations.
Example You attend a football match where representatives of several other companies operating in the sports rights distribution sector are present. A representative of one of these competitor companies starts discussing recent deals and their prices (or other similar topics, such as, costs, business strategy, rebates, discounts, and volumes).
You must not share any information and more generally, are required to immediately put an end to the discussion. Such situations should be reported to your manager, the LCO, the LCC, the GCC or the CCO depending on whether the matter or issue is of a Local or of a Group Nature.
3. Respect
3.1. Fundamental Rights
As a major sports and entertainment content distributor worldwide, it is essential for beIN Media Group to protect fundamental rights of its Associates and to create a safe, fair and equal work environment for all of them. All Associates will be treated and are expected to treat others with dignity and respect.
As part of its commitment to foster human rights, beIN Media Group:
• does not tolerate any harassment or discrimination in any form. beIN Media Group is committed to equal treatment of all its Associates irrespective of, notably, origin, race, color, gender, religion, age, citizenship, disability, or any other criterion determined by local laws or regulations,
• prohibits all forms of forced labor and child labor within it and is committed to fair employment practices in compliance with the applicable labor and employment laws and regulations,
• recognizes that the health, safety and wellbeing of its Associates is an integral and essential part of all its business activities. It is the responsibility and duty of each and every Associate to comply with health and safety measures and to follow all relevant laws, rules, regulations, and work instructions.
Example If you are aware of a case of potential human rights violation, a first course of action may be to express your concerns directly to your manager. If you feel your manager has not adequately addressed your concerns or if you are uncomfortable raising the issue with him/her, you can take further steps to resolve this issue by contacting any appropriate manager, your LCO, the LCC, the GCC or the CCO depending on whether the matter or issue is of a Local or of a Group Nature, or raise the issue via beIN Media Group’s speak up whistleblowing policy.
3.2. Data Privacy
beIN Media Group is committed to complying with all applicable privacy and data protection laws and regulations in all countries where we do business.
“Personal data” is commonly defined as information that can be used on its own or with other information to identify, contact, or locate an individual.
Any and all collection, processing, and use of personal data that could be required for the purpose of our activities will be done in accordance with applicable data privacy and data protection laws and regulations.
All Associates are responsible for the handling of personal data and information in an appropriate manner and in compliance with applicable privacy and data protection laws and regulations. Various countries have their own laws and regulations about the collection, processing, and use of personal data. If you are unsure about what is permissible, you are required to consult with your manager or your LCO for further clarification.
Example An entity of beIN Media Group has developed an update to its apps that would enhance marketing automation features thereof, but is unsure whether the previously collected consents cover such enhanced collection of data.
Prior to launching the update, it must be verified whether the resulting collection of data is compliant with the relevant privacy and data protection laws and regulations.
3.3. Access to information and Confidentiality
Protecting confidential information and beIN Media Group’s intellectual property is important for our economic success. Whereas all Associates are required to maintain and foster strict confidentiality of all relevant information pertaining to our business, beIN MEDIA GROUP will guarantee adequate transparency and sharing of information within the group to allow Associates to properly carry out their duties and missions.
“Confidential information”, as defined by beIN Media Group, includes all non-public information, in particular but not limited to information that might be of use to competitors, or harmful to beIN MEDIA GROUP or its customers, if disclosed. All Associates are required to keep all information received as part of their work confidential.
Associates are responsible for the protection of any beIN Media Group confidential information available to them. No such information shall be disclosed and shared with an unrelated individual (inside or outside beIN Media Group) or used for one’s own benefit.
All Associates will have access to any information required to properly perform their duties, missions and legally required declarations, including allowing them to duly confirm that all records and reports they must draw up or disclose are true, accurate and complete.
All reports, documents or communications authorized or legally mandated for disclosure to the public shall be full, fair, accurate, timely and understandable. Moreover, all business transactions must be recorded in a true, accurate and complete fashion. In accordance with established procedures and generally accepted accounting principles, all Associates shall ensure the reliability and accuracy of our accounts and records.
4. Alerts
Associates are encouraged to report promptly any suspected violations of laws, rules, regulations or of any policy that is part of beIN Media Group’s Global Compliance Program, in accordance with the speak up whistleblowing policy.
Modern Slavery and Human Trafficking Statement 2024
beIN Media Group WLL (“beIN”) is a multi-national media company with operations in Pay-TV, Sport, Original Programming, Movies and General Entertainment in 40 countries across 5 continents and in 9 different languages spanning across Europe, North America, Asia, Australia and the Middle East & North Africa (“MENA”). We recognize that our activities, and those of third parties that form our supply chain, provide numerous opportunities to positively impact our employees’ working conditions and living environments. This is why beIN means to set a standard as a responsible global employer.
This statement is made in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”) on behalf of beIN IP Limited, and beIN IH Limited (the “Companies”). Our statement identifies the steps we have undertaken (in our most recent financial year) to better identify and address the risk of Modern Slavery or human trafficking that may potentially occur as a result of our relationship with certain suppliers or partners.
This statement has been approved by the Board of Directors of beIN Media Group on March 25, 2024.
About us
beIN IP Limited is the content acquisition management platform for the beIN Group and the network of the beIN Sports channels worldwide. The functions of beIN IP Limited are supportive of beIN’s Group strategy, with its responsibility for the acquisition of sports media rights on behalf of beIN Media Group and its subsidiaries. beIN IP operates under the strategic direction of the Group CEO. beIN IH Limited is the holding company of beIN IP Limited and beIN Entertainment LLC in the U.S.
Our Commitment
beIN has a zero-tolerance policy regarding modern slavery or human trafficking in any form. Our goal is to uphold the highest work ethical standards while remaining performant in business by looking for and implementing continuous improvement.
beIN is against all forms of Modern Slavery and is committed to ensuring that Modern Slavery and such inhumane practices are not taking place in our business operations or within our supply chains. Modern Slavery and Human Trafficking are the most fundamental breach of human rights. They can take many forms, such as debt bondage, forced labour, bonded labour, etc. We believe that all businesses and their employees have a responsibility in identifying and eliminating Modern Slavery in all its forms.
As one of the world’s leading sports and entertainment media companies, we recognize that while our direct operations have a low risk of Modern Slavery, there may be some risk inherent in our supply chains, depending on the sector of the services we require, the labour source employed, the operating context of the supplier and the contract type employed. We are committed to identifying, remediating and preventing Modern Slavery in our supply chain.
Our supply chain includes:
How we address Modern Slavery
We recognize that we cannot meet this commitment alone. Preventing Modern Slavery is a collective responsibility and any meaningful impact requires a continual dialogue with our suppliers and business partners. We have undertaken a massive effort to understand and identify Modern Slavery risks in our business and we work with suppliers, experts, partners, civil society and government entities to prevent them. We also seek to assist our suppliers and partners in adhering to our commitments and compliance standards and are committed to cease any partnerships with entities that fail to meet those standards, if necessary.
In this respect, we have deployed policies and procedures designed to combat Modern Slavery and promote human rights in our supply chain and our business generally
Our progress this year
OUR “INDICATIVE RISK” MODEL
To direct our further due diligence on the contracts and suppliers that could be at-risk of Modern Slavery, we continued to use data sources on the country and labour basis where the goods or services would be sourced from and delivered. We used two primary external data sources; a country-level labour market risk rating provided by a global specialist risk consultancy Control Risks’ CORE platform and open-source data from the Global Slavery Index 2018 (“GSI”). Our indicative risk model (supplier risk assessment model) combines data from both sources to determine an initial risk rating for each contractor to guide further due diligence practices. By March 2024, our supplier risk assessment model shall reflect all updates made to the GSI, if any.
We have deployed customized due diligence processes on new and renewed suppliers. We have requested signed statements from our lowest value contractors and developed several questionnaires which address questions designed to identify noncompliance issues and in particular modern slavery and human trafficking risks based on each supplier risk level.
We also introduced guidelines in the questionnaires to better educate our suppliers on the behaviours and ethical standards that we expect from them. We also have standard contractual terms for suppliers to prohibit the use of forced, compulsory or trafficked labour force. While we limit our in-depth due diligence to contracts above $250,000, we are now deploying questionnaires to capture lower value contracts as well.
Continuously improving the scrutiny on our supply chain to better assess our risk areas, since March 2023, we:
Key Risk Areas
Our understanding of the risks of Modern Slavery in our supply chain is improving.
We have now mapped our tier one 1 suppliers within the group with a focus on MENA and Turkey and have since expanded our review to beIN’s global tier one suppliers in Asia Pacific, France and the U.S.
Our review was conducted using a developed and tested supplier risk assessment model designed to provide an indicative assessment of the risk of Modern Slavery based on the country- level risk factors and the labour-type risk factors used in the supply of the goods or services by third parties.
This review identified that our operations in MENA and Turkey were likely more exposed to certain Modern Slavery related risks within their supply chains (than our operations in other jurisdictions) due to:
Looking ahead
As we look to 2024-2025, we remain committed to improve and refine the processes in place to safeguard against Modern Slavery, forced labour and human trafficking. We intend to continue discussions and consultations with internal stakeholders in our business, as well as the end-users who interact and deal with suppliers within the wider global network, to maintain assurance that all our tier one suppliers and other main suppliers have been mapped and assessed in an accurate and consistent in our global compliance standards and supplier risk assessment practices.
Furthermore, we will use the key contact persons appointed in each of these jurisdictions to continue to monitor and review the implemented supplier risk assessment and due-diligence process, which will provide additional insight on any potential supplier risk exposure.
We are currently considering how best to apply these risk identification and management procedures to more suppliers below tier one or lowering tier one value. We have thus started working on automating the vendor compliance due diligence and will make the compliance risk assessment tool, interact with the vendor portal software used by our finance team We are also benchmarking various third-party risk management consultants in order to help develop a fully dedicated and CSR compliance process, including the fight against human trafficking and Modern Slavery.
Labour rights policy
We introduced a labour rights policy and compliance requirements, setting out our commitment to the fair and equal treatment of all workers in our operations and supply chains before the World Cup. The policy is based on best practices from the United Nations Guiding Principles on Business and Human Rights, the International Labour Organisation Fundamental Conventions, and recognised international frameworks including the Dhaka Principles for Migration with Dignity.
We have rolled out our policy to all employees and tier one suppliers. We require that our commitments are understood and implemented by all employees, tier one suppliers and business partners, who are contractually required to adhere to and apply them in their own supply chain. We have also liaised with all key contact persons in each of our main jurisdictions to ensure the application of the beIN labour rights policy and associated compliance requirements by all responsible end-users and have requested notification of any high risk or disqualified suppliers identified.
Any new vendor is also asked to sign a dedicated statement according to which it is complying with beIN policy with regards, among other subjects, the fight against Modern Slavery. This statement is applicable to all vendors, notwithstanding their size, region or value.
Looking ahead
The labour rights policy, trainings and commitments will continue to be reviewed and updated as necessary to remain inline with international best practices. We recognise that a policy alone does not prevent Modern Slavery abuses. To ensure that our suppliers ‘walk the walk’, we have included an express acknowledgement of and undertaking to comply with our labour rights policy in any new or renewed contracts with suppliers. Throughout 2024-2025, we will continue working with procurement and end-users for feedback on the labour rights policy and whether we can further identify ways in which its implementation can be improved and local solutions shared.
Due diligence and monitoring
To support the compliance with our labour rights policy, we have developed a due diligence process for our procurement department to use during contract tender and renewal, that builds on our indicative risk model and requires our internal end-users to provide relevant and up to date information about suppliers – followed, where required, by an assessment of documentation to ensure compliance with our labour rights policy.
The application of the supplier risk assessment model, labour rights policy and its supplier compliance checklist and guidance enables us to implement a robust supplier due diligence program and procedures for new suppliers as part of the group contract awarding evaluation process.
Our due diligence process (Procurement)
All new suppliers will first be rated by our end-users using the indicative risk model (supply risk assessment model). The procurement team will work with end-users within the business to confirm the country where the services are performed, and the labour type used to deliver the service required. Where a supplier is assessed as medium or high risk, we will require the supplier to submit evidence of compliance with our labour rights policy and compliance requirements. In addition, where a supplier is still found to be a high risk following the submission of evidence, a further dialogue will be held with the supplier to manage the risk or disqualify the supplier from the tender process. Where the supplier is accepted, monitoring will be triggered to address the root causes of the issues identified. Any supplier assessed as extreme risk will be automatically disqualified from the tender.
Looking ahead
The supplier compliance checklist and guidance has been implemented within our procurement and supplier awarding process and will be an evolving document as we strengthen our Compliance Program and Risk Management Process. In the course of the coming months, aligning our automated due diligence process with our procurement vendor portal software, will enable us to refine and update the supplier compliance checklist and guidance based on feedback from the suppliers, internal end-users and the assessment findings, and the automated reports generated by our software.
We are also looking to further implement due diligence processes and internal controls with regards to vetting third parties beIN intends to work with by developing dedicated trainings on third party identification. We are also negotiating additional commitments in this respect within our contracts notwithstanding their value.
Monitoring
All Risk Champions appointed in the regions in which we operate have reported that no suppliers had been disqualified during 2023 on the basis of non-compliance with our Labour Rights Policy or the Modern Slavery Act (nor any other violation of a beIN Compliance Policy).
Our monitoring criteria are based on international and local laws and regulations, our own compliance program and policies, which details high level principles and specific compliance requirements, and the processes we are implementing and enforcing on a regular basis for any new Request for Proposals, Tender Offer, Agency Letter or Agreements. We will be training employees and managers on the basis of the highest standards: Respect, Integrity, Accountability and Promoting Human Rights through reporting any potential violations, are the core of our compliance program and the basis for our Code of Business Conduct.
Looking ahead
In 2024-2025, we will continue to identify medium and high-risk suppliers and conduct monitoring activities targeting suppliers operating within all the jurisdictions covered by beIN.
The monitoring activities will vary depending on the type of services or products provided by the supplier, but may include visits to the suppliers’ corporate offices to review documentation indicative of their employment practices, direct interviews with suppliers’ employees, inspections of employer-provided accommodation to assess living conditions or inspections of production facilities to assess the working conditions.
We can also ask end-users to provide sufficient supporting documentation for revalidation of any suppliers identified as being medium or high-risk Each monitoring activity will be conducted in line with our compliance program and corporate social responsibility project. It will consist not only in identifying the compliance concerns but also in working with the supplier to mitigate and remedy any such concerns.
Education
We have an opportunity to have a positive impact in our supply chain through educating our suppliers and working with them to improve their employment practices. To support the implementation of our labour rights policy we have developed guidance for suppliers and have communicated our expectations and compliance policies throughout our entire supply chain, especially tier one suppliers and intend to continue to update this guidance when and as necessary.
We also continued involving internal end-users in the initial assessment of suppliers and provided training on how to properly enforce the supplier risk assessment model and labour rights policy so as to ensure that they are actively seeking assurance of the suppliers’ ability to comply with all requirements. The findings of our assessments and subsequent risk ratings are analysed and salient issues of concern are extracted and reported on to relevant internal stakeholders.
Looking ahead
In 2024-2025, we intend to review and update our supplier guidance as necessary to continue the positive impact and improve our suppliers’ employment practices. We will also continue to provide any additional internal training to the end- users and procurement team as required and to promote charities supporting this cause.
We intend to align the e-procurement and vendor portal software with the automated due diligence on third party questionnaires so that any compliance risk assessment in particular linked to Modern Slavery or an activity having a significant negative impact on human rights is reported in real time to both procurement, compliance and risk management teams.
Grievance reporting and remedy
We understand that the success of tackling Modern Slavery risks in our supply chain will depend on communicating our labour rights policy throughout our supply chain and in enabling concerns within our operations to be reported to us. It is important to us that those affected, as well as those witnessing violations, can raise complaints freely and get effective resolutions at all stages of employment, including the recruitment process.
Looking ahead
In the past years we have been investigating potential options to assess which grievance reporting mechanism would be most suitable to meet our above mentioned aims. A whistleblowing policy has been validated by the Board and deployed in April 2023, trainings on the best use of our compliance inbox and speak up mechanism will be made available in English with local sub-titles this year along with crisis management exercises and quiz when all the values of the Group have been duly explained, implemented and as the case may be, enforced.
1 A tier one supplier for this purpose is a third party that provides goods or services directly to beIN whose contract value exceeds USD 250,000 per annum.
Global Tax Strategy
Introduction
beIN MEDIA GROUP and its subsidiaries (collectively the “Group”) are a global sports and entertainment media group that carry out TV production, media rights acquisitions and their distribution. The Group broadcasts across 5 continents within 43 countries and in 9 different languages.
Governance and Risk Management
beIN MEDIA GROUP is committed to paying the right amount of tax within the timelines set by relevant laws/regulations, in all the jurisdictions in which it operates. beIN Media Group seeks to structure its affairs based on sound commercial principles and in accordance with relevant tax legislation.
The importance of commercial needs should in no circumstances override compliance with applicable tax laws. As a matter of practice appropriate external professional and specialist advice is sought. This is particularly so, where there may be areas of uncertainty.
beIN MEDIA GROUP identifies, evaluates and mitigates tax risks. As part of its governance beIN Media Group has established the following in relation to taxation:
The Group Head of Tax, together with his team, manages and oversees the Group’s tax compliance. This includes and not limited to providing support on tax matters across the Group.
The Tax Function is also supported by external tax advisors where appropriate.
The Group Head of Tax ensures that they are up to date through regular professional and industry training. In addition, they are charged with responsibility for providing relevant updates and training to wider business functions, as appropriate.
In this regard, the tax function provides appropriate input as part of the approval process for business transactions/proposals to ensure a clear understanding of the tax consequences is established at the outset.
Tax planning
Tax decisions are made in a manner that is consistent with beIN Media Group’s business strategy and operations. Appropriate professional advice is sought from external professional firms. Transactions undertaken are driven by the business and commercial needs of the operating business. The advice sought from reputable firms enables us to evaluate both non-tax and tax implications and associated risks.
In its approach to the level of risk in relation to taxation, beIN Media Group is not prepared to accept a level of risk that would expose the business to reputational harm.
Relationship with tax authorities
beIN Media Group is committed to the principles of openness and transparency in its approach to dealing with the tax authorities wherever we operate around the world. All dealings with the tax authorities and other relevant bodies are conducted in a collaborative, professional, courteous and timely manner.
This document is published in compliance with Paragraph 19(2), Schedule 19, Finance Act 2016 which requires beIN Media Group to set out the tax strategy of its UK companies. This global tax strategy covers the entire Group, including the UK entities , and applies for financial year end 31 December 2023.
Corporate Criminal Offence
Anti-Facilitation of Tax Evasion – Corporate Criminal Offence (“CCO”) Policy
Introduction
The CCO was introduced in the UK Criminal Finances Act 2017 and became effective as of 30 September 2017. A business is criminally liable if it fails to prevent those who act for it, or on its behalf (“Associated Persons”) such as employees, agents or service providers, from criminally facilitating tax evasion in the UK or overseas. beIN MEDIA GROUP LLC and its subsidiaries (“beIN”) therefore have a legal responsibility to ensure that those acting for, and on its behalf, do not facilitate tax evasion. Any breach may result in unlimited fines and other sanctions for beIN, as well as significant reputational damage.
beIN is committed to preventing the facilitation of tax evasion by individuals or businesses within its operations. The following policy (the “Policy”) outlines the expectations regarding tax evasion and its facilitation of those who work for or on behalf of beIN.
What is the facilitation of tax evasion?
Tax evasion means deliberately and fraudulently underpaying or not paying tax and “criminal facilitation of tax evasion” refers to deliberate and dishonest action (or omission) to assist another person to evade tax in the UK or abroad.
Tax means all forms of taxation, whether owed in the UK or abroad, including corporation tax, incometax, withholding tax, value added tax, stamp duty and national insurance contributions.
Who must comply with this Policy?
This Policy applies to all persons working for beIN, or on its behalf, including employees, volunteers, interns, casual workers, agency staff, contractors, distributors and other third partiesincluding agents, freight forwarders, advisors and service providers.
All members of staff and all who have, or seek to have, a business relationship with beIN must familiarise themselves with this Policy and are required to act at all times in a way which is consistent with the Policy.
Policy
The purpose of this Policy is to:
Business should be conducted at all times in a manner such that the opportunity for, and incidence of, tax evasion is prevented. beIN is committed to the following principles:
Employees, agents and all people acting for or on behalf of beIN must not:
Any employee, agent or person acting for or on behalf of beIN who participates in any such activities will also be subject to strict disciplinary action, including termination of employment or the assignment in compliance with applicable laws.
Potential Risk Scenarios
The following is a non-exhaustive illustrative list of possible red flags that may raise concerns related to tax evasion:
Implementation and Review
This Policy will be published on beIN’s website and reviewed annually by the Board of Directors.
Training and Communication
All beIN Directors are aware of the UK’s CCO rules. A CCO video-based training module is distributed to all UK staff and those whose actions may come under the scope of the legislation.
Reference to this Policy is included in applicable agreements with suppliers, contractors and others who intend to have a business relationship with beIN, and these parties must read, agree and adhere to it (and by extension, agree to beIN’s zero-tolerance approach to tax evasion).
beIN’s Associated Persons are encouraged to raise concerns about any issue or suspicion of tax evasion as soon as possible. Any known or suspected events should be reported immediately to the local Finance Director copying the Group CFO and the Group Head of Tax.
Labour Rights Policy
belN Labour Rights Policy
belN MEDIA GROUP WLL (“belN”) is a multi-national media company with operations in Pay-TV, Sport, Original Programming, Movies and General Entertainment with a presence in over 43 countries across 5 continents and in 9 different languages spanning Europe, North America, Asia, Australasia and the Middle East & North Africa (“MENA”). We recognise that our activities, and those of third parties that form our supply chain, provide opportunities to positively impact our employees’ working and living environments and set a standard as a responsible global employer.
Our responsibility
belN has a responsibility in building the world of tomorrow, where a common respect and understanding of differences in cultural diversity and background is encouraged and promoted. To this end, we have incorporated our corporate values of sportsmanship, fair play, honour, dignity and mutual solidarity and coupled them with the principles at the heart of our identity – accountability, integrity and respect to develop this labour rights policy.
Our policy and commitments
We are committed to upholding the employment rights of all those who work for belN, whether employed directly by us or indirectly by our third parties. This policy defines our commitments to the well-being, safety, security and dignity of employees and is based on best practices from the United Nations Guiding Principles on Business and Human Rights 1, the International Labour Organisation Fundamental Conventions 2 and recognised international frameworks, including the Dhaka Principles for Migration with Dignity 3
belN Compliance Requirements
Our commitments are supported by the following compliance requirements.
Applying our commitments
We recognize that due to beIN’s international footprint, these commitments may differ from legal requirements in some of our countries of operation and in such instances the applicable governing law shall prevail. beIN’s labour rights policy and commitments are however an integral part of our corporate values and we will seek to implement them to the fullest. Our labour rights policy and the compliance requirements derived from each commitment are applicable to all beIN employees as well as the employees of our third parties.
How we will meet them
We require that our commitments are understood and implemented by all employees, suppliers and business partners, who are contractually required to adhere to our commitments and apply them in their own supply chain.
We continually monitor our own operations and assess third-party suppliers at the procurement stage to ensure conformance with the commitments and make improvements and will take necessary actions where required.
Our monitoring criteria are based on our principle and compliance requirements, which incorporate key applicable elements from the international Finance Corporation Performance Standards 2 on Labour and Working Conditions4 and the Global Reporting Initiative Social Standards.5
This labour rights policy and commitments are managed by a dedicated group compliance team and will be updated as necessary on a yearly basis to remain in line with international best practices.
1https://www.ohchr.org
2https://www.ilo.org
3http://www.ihrb.org
4http://www.ifc.org
5http://www.globalreporting.org