4.3 CSR – risks, opportunities, strategy and performance

In 2018, the Sustainable Development and CSR Department and Risk and Internal Control Department worked together to identify non-financial risks and integrate them into the Group’s risk map. After flagging up nearly 40 non-financial risk events and opportunities divided into four categories – labour impacts, environmental impacts, respect for human rights and fighting corruption – the risk and sustainable development teams analysed them against the existing materiality matrix (see section 4.2.1.C).
This cross-analysis of the 40 events helped narrow the list down to 13 non-financial risks and opportunities. These 13 risks were then assigned a rating for each of the Group’s main businesses, ranked using the Group’s risk scoring methodology and weighted based on revenue to factor in the Group’s strategic plan to refocus its business on Lagardère Publishing and Lagardère Travel Retail. 
The ranking process highlighted the following nine areas as carrying non-financial risks and opportunities:

  • management of skills and key talent;
  • diversity and gender balance in human capital;
  • access to and dissemination of education, culture and entertainment;
  • quality of products and services, promotion of health and well-being;
  • management of resources and respect for the environment;
  • management of energy and carbon impacts;
  • respect for privacy;
  • respect for fundamental freedoms;
  • fighting corruption.

Section 4.3 describes the Group’s strategy for each of these priorities, its implementation within the business lines, the indicators in place to monitor progress, and areas for improvement.

4.3.1 LABOUR IMPACTS OF THE GROUP’S ACTIVITIES

4.3.1.1 MANAGEMENT OF SKILLS AND KEY TALENT

Today’s world is changing fast, with new growth models emerging all the time. To keep up, the Lagardère group must attract and support the career development of talented, creative and engaged employees to design innovative products and services and produce high-quality content. The Group’s business success is a direct result of the skills and expertise of its employees; these skills are valuable resources that are constantly being adapted to maintain the quality and diversity of the workforce.

A.1 STRATEGY
Under the supervision of the human resources departments at Group and divisional levels, operating entities manage their employees independently and locally to bring out the best in their human capital. To achieve this, they implement measures to respond to the specific needs of their activities, businesses and environments. In line with the Group’s organisational approach, divisions must nevertheless adhere to a set of shared commitments, including an internal talent management policy, that are regularly monitored by the Group’s Human Resources Department, with meetings held every fortnight. Developing the professional expertise and individual responsibilities of employees is crucial to the Lagardère group’s success. It therefore focuses on developing employees, through promotion, internal mobility and training, to enhance their individual employability. Lagardère also provides guidance and training for young people by hosting interns and promoting work-study placements and programmes.
It is also Group policy to use remuneration and pay rises – contingent on the value employees bring to their position and on variable pay scales that reflect the measure of individual objectives – to recognise and reward employee performance levels, using quantitative and qualitative criteria defined by the subsidiaries. The priority given to managing skills and key talent also addresses UN Sustainable Development Goals 4 “Quality Education” and 8 “Decent Work and Economic Growth”.

A.2 APPLICATION
TRAINING
In order to offer employees guidance throughout their career, the Lagardère group makes available a large selection of training options in a broad range of fields, including digital technologies, management, communication, health and safety, foreign languages, businesses, etc. Each year, the training hours data highlights how well-adapted the Group’s training policy is: more than 66% of total training hours provided focus on “business” or “management”. These training courses are closely correlated to employees’ current performance and development potential.
The divisions also organise their own in-house training courses. For example in France, Lagardère Publishing runs the Hachette Livre forum, three one-day events over the course of each year that provide new employees with the opportunity to learn more about the publishing business.
For many years, Lagardère Travel Retail has provided an internal training programme for its sales teams. The division also set up the Lagardère Travel Retail Academy in early 2017, with the aim of developing the skills of high-potential employees and top managers by organising three-day seminars for participants from various countries. Several renowned international experts from major universities (MIT, Harvard, ESSEC, Sciences Po Paris, etc.) have been invited to talk at these events during which around 15 employees are trained on subjects such as change management, leadership, finance, innovation and marketing. In 2019, eight seminars were organised in Europe, the United States and Asia.

Items appearing in the Annual Financial Report are cross‑referenced with the following symbol AFR

INTERNAL MOBILITY
Internal mobility is a key component of human resource management, building on the training and employee skills development initiatives. Group-wide, nearly 1.8% of vacancies for permanent positions were filled through internal mobility in 2019. While this figure may appear to be low, it is heavily impacted by the high employee turnover at Lagardère Travel Retail of mainly retail sales staff, for whom internal mobility is not a major issue. When adjusted for this factor (recruitments in the “Other employees” category at Lagardère Travel Retail), in 2019, the Group’s internal mobility rate came out at 14.9%.
Furthermore, the stark differences in the Group’s business activities make mobility for operating staff between divisions practically impossible. However, in France the Lagardère group has developed a special process to evaluate the various opportunities (mainly for support functions) and profiles of candidates who have submitted a request for mobility. The inter-divisional committee (made up of HR representatives in charge of mobility) handled around five mobility transfers in 2019 and reviewed 240 jobs and 20 candidates.

REMUNERATION
To take into account employees’ skill levels, training and responsibility and the specific nature of the business sectors they work in, individual rather than collective pay rises are increasingly common. As such, most of the Group’s entities reward employees through individual as well as collective performance incentives such as bonuses and variable pay. These practices enable the Group to correlate employee remuneration to the achievement of individual and collective objectives at the level of the subsidiary concerned.
In return for these individually tailored pay measures, to ensure optimum transparency between staff and their management on remuneration, the Group encourages annual interviews, which give employees a better perception of their performance with regard to the requirements of their job.
Lagardère also seeks to build loyalty among key talent through regular awards of shares in the parent company, Lagardère SCA. It has done so since 2007 using free share awards (see the Special Report of the Managing Partners in section 2.9.9).

A.3 PERFORMANCE
The Lagardère group now focuses on a narrower range of indicators, which it will monitor more closely. These key indicators include voluntary departures (which cover only resignations and departures for retirement, and do not include redundancies or mutually agreed contract terminations), variable remuneration, and length of service of managers and executives within the Group.

Voluntary departures(1)

      2019  
Division Division Unit Executives Managers Other
employees		 2018
Lagardère group Lagardère Publishing % 7,8 6,8 11,5 NA
Lagardère Travel Retail % 7,5 15,3 44,3 NA
Lagardère News % 0,0 2,7 73,9 NA
Lagardère Live Entertainment % 0,0 9,1 17,2 NA
Other Activities % 0,0 10,4 10,2 NA
Other assets pending disposal
at Lagardère Active		 % 7,7 7,0 9,2 NA
Lagardère Sports % 5,3 9,4 20,4 NA
Groupe % 6,9 9,0 36,9 NA

The significant divergences in the percentage of voluntary departures by division and professional category in the table above mainly reflect local job markets and radically different approaches to work between countries. Stark differences are also found between the Group’s various business divisions. Voluntary departures are especially common at Lagardère Travel Retail, as retail employees are included in this indicator across a broad scope.

(1) Compte tenu principalement de l’importance des mouvements d’entrées et de sorties de collaborateurs au cours de l’année, le chiffre présente un certain niveau d’incertitude en dépit des contrôles réalisés, représentant environ 1 % des effectifs 2019 (contre 3 % des effectifs 2018) et 1 % des sorties des collaborateurs.

Other performance indicators

Indicator Unit 2019 2018 2017
Percentage of managers and executives with more than ten years of service % 43 43 42
Percentage of employees with a portion of variable remuneration % 36 44 40

4.3.1.2 DIVERSITY AND GENDER BALANCE IN HUMAN CAPITAL(1)

Discrimination based on factors such as gender, disability, sexual orientation, race and religion undermines self-esteem, while diversity helps create social harmony. The Lagardère group believes that having a diverse workforce (particularly in terms of gender, disability, ethnic and socio-economic background) drives creativity and growth.

A.1 STRATEGY
Adapting to local cultures, the diversity of consumers and the increasing number of markets are strategic factors in the development of all Group businesses. Given its wide range of business activities and the broad array of expertise provided by its workforce, the Lagardère group promotes diversity in its divisions. Working diligently on this issue, as with the above-mentioned one, the Group-level, division and other operational human resources departments play a leading role in ensuring that its employees are representative of society at large.
Lagardère is opposed to all forms of discrimination based on a person’s origin, lifestyle, age, sex, political or religious opinions, trade union affiliation, disability or sexual orientation. It works to apply and promote the ILO’s fundamental principles on eliminating discrimination in respect of employment and occupation and stamping out forced and compulsory labour.
Lagardère’s strategy to promote diversity and gender balance has translated these principles into three main focal points:

  • gender balance in the Group;
  • breaking down stereotypes based on race or social class;
  • integrating employees with disabilities.

This priority also addresses UN Sustainable Development Goals 5, “Gender Equality” and 10 “Reduced Inequality”.

A.2 APPLICATION
GENDER BALANCE IN THE GROUP
Women continue to occupy a central position in the Group’s workforce. In 2019, women represented 64% of the Group’s total permanent workforce, 44% of executives and 55% of managers. Not surprisingly, they also made up the majority of training participants (women took 62% of the training hours provided, and 65% of the total number of trained employees were women) as well as the bulk of promotions and pay rises (65% of promotions and 62% of pay rises).
In November 2017, the Group launched the LL Network internally, addressing all employees in France, to promote diversity. The network continued to expand in 2019 to include around 500 members, of which about one quarter were men.
The LL Network has three goals: (i) improving gender balance in the Group’s business lines, (ii) helping women into management positions, and (iii) strengthening constructive dialogue between members of the various Group entities. It does this through three types of initiative: personal and professional development workshops, business presentation breakfasts and themed after work events. From its launch, the LL Network has also been the vector through which the Group demonstrates its commitment to a range of causes in support of women, such as its endorsement of the Women’s Empowerment Principles, the partnership with Digital Ladies & Allies, and the #StOpE initiative to put an end to everyday sexism in the workplace. The network also aims to support constructive dialogue between the business lines and to be instrumental in attracting and retaining talent. The LL Network organised around 30 events (after work events, breakfasts, an annual day-long event, workshops and conferences) in 2019 and also extended its support to an additional 18 mentoring arrangements.
Lastly, 2019 was marked by initiatives to put an end to everyday sexism in the workplace, with the Group launching new training programmes for around 60 human resources managers during the year. At the level of the divisions and entities, a range of local initiatives help promote gender balance in the workplace. For example at Lagardère Publishing, the July 2017 agreement concerning gender equality entered into by Hachette Livre in France commits to improving gender balance during recruitment processes for all types of employment (from publishing via IT distribution through to logistics) by 2020. It also includes a commitment to offer promotions to an equal number of men and women and to balance the average percentage pay rise granted to women with that offered to men. In the United Kingdom, Hachette UK published its third annual Gender Pay Gap Report, which highlighted improvements in the pay gap and an increase in the proportion of women classified as “highly paid”.

BREAKING DOWN STEREOTYPES
This theme is relevant day to day, across all businesses. The broad diversity of employees reflects both the large number of regions in which the Group operates and the diversity of the customers and consumers that buy its products and services.
At the Group level, the situation at the various entities is surveyed regularly, in particular by analysing recruitment procedures to test the selection criteria for candidates applying for full employment and work placements. A second survey was carried out between 2016 and 2017, and mainly helped fine-tune the assessment procedure and identify both progress and further areas for improvement. A third survey was organised at the end of 2019 and will run for around 18 months from 2020. These surveys, carried out based on the criteria of ethnic origins and gender, help identify whether candidates may be victims of such discrimination at the recruitment stage.
The Group also provides training programmes for managers in the subsidiaries and operating entities on breaking down stereotypes and resisting confirmation bias, which are held regularly throughout the year. The human resources departments and executive committees of each division were among the first employees to be given this training course, which is now given to several dozen managers each year.
Following on from previous years, numerous initiatives, conducted in partnership with charitable associations promoting cultural or social diversity, were continued within the Group, such as Nos Quartiers ont des Talents (NQT) and the Divertimento Orchestra, which help young people from disadvantaged neighbourhoods to gain access to training and employment opportunities that are sometimes unavailable to them due to their ethnic or social backgrounds. Lagardère Publishing runs initiatives and action plans across all of its operational geographies, with the aim of boosting inclusivity and promoting diversity in all of its forms.
In France, Hachette Livre teamed up with Sciences Po to provide book bursaries for students under France’s programme to support equal opportunity in education (Conventions Éducation Prioritaire – CEP). Hachette Livre also supports the CEP programme in different ways, such as traineeships, tutoring and participation in admission committees. Also in 2019, Hachette Livre and non-profit association NQT (Nos Quartiers ont des Talents) partnered to help young people from disadvantaged neighbourhoods gain access to training and employment opportunities. the United Kingdom, Hachette UK has been running a programme called Changing the Story since 2017. It aims to promote diversity of culture, race, gender, religious beliefs and sexual orientations, in both the books it publishes and in the employees it hires. Hachette UK also teamed up with the Stephen Lawrence Trust for a school and higher education-level mentoring programme. In April 2019, Hachette UK became the first publisher in the United Kingdom to release an Ethnicity Pay Gap Report, in which it commits to raising the proportion of employees from ethnic minorities to 15% within five years.
In Spain, the Anaya group pressed ahead with efforts to promote
respect for diversity, shared values and gender equality in all of its publications, and also supports several initiatives promoting cultural and educational activities that encourage social integration. Lastly, in the United States at Hachette Book Group (HBG), the Diversity Committee spearheads initiatives such as the Read Our World program, which promotes acceptance, education and open dialogue through books representing diversity. In addition, HBG partners with organisations that promote diversity in the book publishing industry, such as We Need Diverse Books, The Children’s Book Council and the Association of American Publishers.

INTEGRATING EMPLOYEES WITH DISABILITIES
The Group underscored its commitment to the inclusion of people with disabilities by taking part in the national DuoDay event in France held on 16 May 2019. In total, more than 180 Group employees in France volunteered to be shadowed during a working day by a disabled person.
In France, Hachette Livre set up its own Mission Handicap programme and was also among the leading business signatories of the charter for the inclusion of people with disabilities in the workplace, which comprises 10 on-the-ground commitments aimed at encouraging businesses to drive inclusion and in-work support for people with disabilities.

(1) The information in section 4.3.1.2 is presented pursuant to the obligations provided for in paragraph 6 of article L. 225-37-4 of the French Commercial
code (Code de commerce).

A.3 PERFORMANCE

Indicator Unit 2019 2018 2017
Percentage of women executives % 44 42 43
Percentage of women managers % 55 56 55

In addition to the indicators described above, for several years the Group has also closely followed a number of formal disputes concerning discrimination alleged against one of its entities (see section 4.3.3.2 on respect for fundamental freedoms).

4.3.1.3 ACCESS TO AND DISSEMINATION OF EDUCATION, CULTURE AND ENTERTAINMENT

The Lagardère group’s businesses aim not only to instil the love for reading and learning, and develop critical thinking, but also to enhance knowledge, culture and education through the full range of content available across all media and in brick-and-mortar retail spaces. The wide array of content and products available, countries where it broadcasts and cultures highlighted in points of sale, together with the multiple points of view and types of content promoted by the Group’s brands, supports cultural diversity and freedom of expression.

A.1 STRATEGY
Culture – sometimes referred to as the fourth pillar of sustainable development – plays a central role in the Group’s businesses. With its involvement in the worlds of reading, writing, travel and information, Lagardère bears a special responsibility as a world leader in content publishing, production, broadcasting and content distribution. Culture, in all its forms and all its diversity, is the driving force behind the Lagardère group. This is shown in the variety of the books published by Lagardère Publishing, reflecting a broad spectrum of opinions in more than 70 countries and 15 languages, the reach of the Lagardère Travel Retail network (more than 4,800 points of sale in 39 countries), the diversity of the teams and the extensive range of products on offer.
Diversity in content, culture and ideas, freedom of expression, development of critical thinking, the ability to analyse and understand the world and knowledge transmission are all issues traditionally related to the activities and values of the Lagardère group. All the Group’s brands contribute, at their level and in their own way shaped by the local context, to supporting individuals in their everyday lives by helping them understand the major issues in contemporary society (environment, social justice, diversity, health, human rights, etc.) or by satisfying their need to learn, discover, gain knowledge and open up to the world around them.
This priority target is covered by the Group’s operating entities which ensure the accessibility, dissemination and promotion of their products and services to all possible audiences, and primarily addresses UN Sustainable Development Goals 3 “Good Health and Well-being” and 4 “Quality Education”. Since the Group’s content helps to educate, inform and raise awareness, it also indirectly addresses UN Sustainable Development Goals 5 “Gender Equality”, 10 “Reduced Inequality”, 12 “Responsible Consumption and Production” and 16 “Peace, Justice and Strong Institutions”.

A.2 APPLICATION
ACCESS
In France, the United States and the United Kingdom, Lagardère Publishing helps promote and develop audiobooks through its various brands. This format supports the visually impaired and those with reading difficulties, such as young dyslexics, and facilitates access to reading in general. However, audiobooks also have broader appeal, whether for the quality of the narrator’s voice, simple convenience or education. They offer an ideal way of passing on the pleasure of reading and encouraging people to read.
In 2019, the Hachette Livre group together with the Hachette UK and Hachette Book Group subsidiaries, signed the Accessible Books Consortium (ABC) Charter, in which they commit to increasing the number of books in accessible formats, including the blind and visually impaired, or otherwise print disabled.
In November 2019, Hachette UK also partnered with the Royal National Institute of Blind People (RNIB) to make 33,000 books in its catalogue available via the RNIB Bookshare platform. Bookshare is a free online library of digital educational books for learners with a print-disability, including those with dyslexia or who are blind or partially sighted. In the United States, Hachette Book Group runs a number of initiatives aimed at facilitating access to reading among the visually impaired and from underprivileged backgrounds, as well as getting people interested in reading and writing, by donating books and e-books and providing free access to its audiobook catalogue.
Hachette Livre is a founding member of the PEN International Publishers Circle. PEN International is an NGO formed in 1921 to protect freedom of expression, particularly that of persecuted writers, and to promote literature worldwide. In the three countries where it operates (France, the United Kingdom and the United States), Hachette Livre actively helps to finance PEN and various other initiatives that seek to protect freedom of expression and publication around the world.

PROMOTING READING, EDUCATION AND PLURALISM OF IDEAS
French Publishers’ Union) in all public events related to combating illiteracy and encouraging reading, Lagardère Publishing leads many initiatives that promote reading and support education in all of the regions in which it operates.
In France, Le Livre de Poche’s Le Camion qui livre mobile library has travelled up and down the beaches of France every summer for the past six years. By going out in search of readers on the beaches and, above all, attracting people that might not otherwise have visited a bookshop, this operation ties in with Le Livre de Poche’s historical purpose of making reading and culture accessible to all. Le Livre de Poche also works with Unicef in its mission to educate the 128 million children worldwide who are not enrolled in school, by publishing previously unpublished works and donating a portion of the proceeds to the cause.
Still in France, Hachette Livre and Hatier are involved in Savoir Livre, a non-profit organisation that works with the French national education authority and the Books and Reading Department of the Ministry of Culture. Savoir Livre monitors the education system through studies, surveys, conferences and debates with the underlying aim of giving children the best chance of succeeding in life. In 2013, Hatier also launched a contest called Le Tremplin Prépabac for secondary school students, with a €5,000 winning prize intended to fund future career plans. Hatier received recognition for this initiative in December 2019 in the form of a publishing trophy in the CSR category.
Since October 2017, Hachette Livre has been a founding member of Educapital, a European investment fund dedicated to education and training. Educapital identifies and partners innovative start-ups in the education and training sectors, particularly in primary, secondary and higher education segments as well as in extra-curricular activities. Hachette Book Group continued its partnership with the Read Ahead organisation for the eighth straight year. This has led a number of employees to help pupils of a state school in New York to practise and improve their reading abilities over a full school year, and more generally to provide mentoring throughout their course. At the end of 2019, Éditions JC Lattès, together with RFI and Cité internationale des arts, launched the “Voix d’Afriques” (African Voices) literary prize for young African writers, which showcases new African novel-writing talent in French.
Education also involves raising awareness about the major issues facing society. As the publishing business is primarily driven by the diversity of the books it releases and the ideas it develops, Lagardère Publishing’s primary responsibility is to help readers understand the major issues across the world today. In 2018, Hachette Livre bought La Plage, which publishes books by authors involved in environmental issues and well-being topics. This acquisition has enhanced the division’s variety of available works and has provided La Plage with a broader platform for its authors to wave the environmental flag.
Hachette UK set up its Changing the Story programme as part of its objective to promote diversity, social inclusion, equality, accessibility, dissemination of culture, reading and writing. This 360-degree programme involves a range of initiatives (partnerships, workshops, mentoring, fundraising, donations, editorial choices, employee engagement, training, enterprise network, etc.) designed to make Hachette UK the leading publisher in the United Kingdom. In France, Lagardère Travel Retail has contributed to developing freedom of expression for over 15 years. Through its network of Relay sales outlets, the division supports the work of Reporters Without Borders (Reporters Sans Frontières) by promoting the association’s three annual publications, free of charge. Moreover, the amount raised from their sale is passed on to Reporters Without Borders in full. Relay also promotes the organisation on its website and in its stores.
In 2019, Lagardère’s media activities helped explain, through their content, opinions and/or partnerships, many topical issues to various audiences. With its new baseline, Écoutez le monde changer (Listen to the world change), and by staging the Trophées de l’Avenir awards for excellence in social innovation and commitment, the Europe 1 radio station is demonstrating its commitment to raising awareness of major social issues among its audience.

A.3 PERFORMANCE

Indicator Unit 2019 2018 2017
Number of audiobooks available in the
Lagardère Publishing catalogue at year-end		 No. 14 203 12 363 -

4.3.1.4 QUALITY OF PRODUCTS AND SERVICES, PROMOTION OF HEALTH AND WELL-BEING

All companies have a duty to ensure the health and safety of the people who use their products and services, as well as complying with applicable regulations. These priorities apply to every division within the Lagardère group in different ways. As an example, both physical products delivered with books (accessories, household items, toys, etc.) and food products must be compliant.
With the increasing growth of the Foodservice business at Lagardère Travel Retail, food hygiene and safety issues have become a priority. An incident involving the quality of food products sold at Group stores would not only endanger the health and physical safety of consumers but could also jeopardise the Group’s credibility and reputation among both customers and partners.
At the same time, this risk creates a genuine opportunity to enable people to find ways of living healthy lifestyles, promote well-being for anyone at any age, and contribute to today’s topical social discussion around well-being and eating habits that are good for both people and the planet. Along with having the opportunity to educate and inform, the Lagardère group is also able to influence (content produced/disseminated) and take action (food offering), helping change the way people think, behave and act.

A.1 STRATEGY
At Lagardère Publishing, Hachette Livre’s suppliers select packaging and accessories based on criteria defined by the Group Purchasing Department. Suppliers are contractually committed to only delivering products that meet the applicable consumer health and safety standards. In addition, products such as toys that are subject to specific regulations are screened for safety post-development and are controlled by independent laboratories before being marketed to the public. This is also the case for products such as kitchen utensils, electrical equipment and cosmetics. Hachette Livre makes available to its wholesale customers all of the compliance declarations for products subject to safety regulations and standards. Its international subsidiaries are also subject to the same stringent requirements. Hachette Book Group, for exemple, has a quality process and safety testing programme for certain products.
The expansion of Foodservice at Lagardère Travel Retail since 2014 means food hygiene and safety issues have become a priority, as the division now offers food at more than 1,100 points of sale in 23 countries. Food Safety Guidelines were defined to serve as a reference in all countries in which the Group operates. These standards set out the policy along with strict rules that are sometimes more demanding than local hygiene regulations.
The division is also focusing more on the issue of food waste and issues relating to the agriculture bill passed in France in late 2018 on improving animal welfare, encouraging safe, healthy and sustainable food, and reducing the use of plastic.

A.2 APPLICATION
Since the end of 2012, Lagardère Publishing has provided compliance certificates on both a systematic and intermittent basis on a dedicated portal to French retailers and booksellers for products requiring certification. It also set up a product safety committee that meets quarterly and has put in place incident and crisis management procedures for product safety which went into effect in early 2015. Product development and manufacturing teams are also regularly trained on product safety issues. 
In France, the division is also a member of the toy standardisation committee and participates in developing toy safety standards, including the EN 71 European safety standard series.
Lagardère Travel Retail has drawn up a policy with the support of Bureau Veritas and its local network of food safety and brand conformity experts. Since 2018, this policy is implemented in the following three areas:

  1. Food Safety Guidelines include tools for implementing action plans as well as objectives.
    In France, an HACCP(1) system for controlling food safety applies both to catering operations and the sale of packaged food. Daily food hygiene and safety checks are performed at each point of sale, following strict and specific procedures, from the supplier delivery phase to final sale to the consumer.
  2. An annual audit plan is conducted at each of the subsidiaries, including in-depth questionnaires for each point of sale and audits for the headquarters of each of the divisions. Eight countries were audited in 2016, ten in 2017, fourteen in 2018 and sixteen in 2019, with seventeen audits planned for 2020.
  3. Building on its work the previous year, awareness-raising campaigns were run in all new Foodservice geographies in 2019, including the Gabonese Republic. In 2020, an e-learning module will also be rolled down following a successful pilot in France.

In early 2018, Lagardère Travel Retail pledged that it would no longer sell eggs or egg-based products from caged hens as of 2025 throughout its network worldwide.
Alongside the food hygiene and safety issues, the division is becoming increasingly aware of growing demand from contractors and consumers for healthier foods that promote traveller well-being. This has given rise to partnerships with brands that are committed to improving the intrinsic quality of the products or providing locally sourced products.
In line with its sustainable development policy, and beyond the food hygiene, safety and product traceability aspects, Lagardère Travel Retail runs four types of initiatives to prevent food wastage at its subsidiaries:

  1. Optimisation of production:
    • where possible, Lagardère Travel Retail and its subsidiaries choose fresh, seasonal and less perishable ingredients, and favour on-site preparation to remain aligned with demand and avoid overproduction. Products are produced in smaller quantities but more frequently;
    • for example, the products produced or purchased by Lagardère Travel Retail’s Czech subsidiary are vacuum-packed to extend their shelf life.
  2. Food preservation:
    • in the Netherlands, a product called Slowd – which absorbs ethylene contained in fresh produce, slowing down the maturation process – is used to perfectly preserve fresh produce such has fruit, vegetables and herbs for up to 30 days.
  3. Waste prevention: targeting a 50% reduction in waste by 2025:
    • in Bulgaria, the Czech Republic, Poland and Romania, “happy hour” events are organised at the end of the day, aimed at limiting waste;
    • in Romania, public service announcements are run both online and in stores to raise customers’ awareness of the prevention of food waste;
    • in France, the Too Good To Go app enables customers to buy unsold meals online at reduced prices;
    • in the Czech Republic, a milk dosing system for hot drinks has been set up at Costa Coffee to reduce milk wastage as well as to improve food security in view of its short shelf life.
  4. Waste transformation:
    • in the Czech Republic, the coffee grounds generated by Costa Coffee branches are made available to both customers and a gardening association. At UGO juice bars, there are plans to transform unused fruit and vegetables into compost.
  5. Distribution of unsold products:
    • distribution of unsold products to zoos, circuses and animal shelters in the Czech Republic and Romania;
    • cooperation with charities for the homeless such as the Salvation Army in the Czech Republic;
    • cooperation with local food banks in the United States and Italy;
    • Lagardère Travel Retail launched a partnership in Romania with Caritas, a not-for-profit organisation, under which on four days each week, employees from several points of sale deliver products nearing the end of their shelf life. Caritas then redistributes the products to disadvantaged children and elderly people.

A.3 PERFORMANCE

Indicator Unit 2019 2018 2017
Number of countries audited for healthand safety during the year No. 16 14 10
Percentage of countries audited for health and safety at year-end % 70 70 -

(1) HACCP: Hazard Analysis Critical Control Point.

4.3.2 ENVIRONMENTAL IMPACTS OF THE GROUP’S ACTIVITIES

4.3.2.1 MANAGEMENT OF RESOURCES AND RESPECT FOR THE ENVIRONMENT
A simple, ubiquitous product, paper is historically the Group’s main raw material. When produced from renewable sources, paper can be a quintessentially eco-friendly material – if the impacts of its production are managed properly. Like any product, paper leaves an environmental footprint throughout its life cycle, from the forest and purchase of raw materials to production and recycling unsold copies. Paper pulp, which is transformed to produce paper, is a globalised resource that is transported worldwide and imported by paper manufacturers from around the world. This global chain means that the paper manufacturing process can combine several sources and supply must be managed carefully.

A.1 STRATEGY
The Lagardère group has long led a policy of responsible paper management which applies throughout the paper life cycle. From supply to production to the management of returns, Lagardère works with all its trade partners involved at every stage. Lagardère has been committed to the circular paper economy for many years.
The Group’s goal is first to increase the proportion of certified paper from sustainably managed forests it purchases each year, and wherever possible, to use PEFC or FSC certified paper (sourced directly from paper suppliers or supplied by printers) or recycled paper.
A sustainably managed forest is one in which the amount of wood harvested every year does not exceed biomass growth over that same year. This guarantees carbon sequestration in the forest, unlike overexploited forests or areas of deforestation. This sustainable approach involves controlling forest resources, but also takes into account criteria such as the productive and protective functions of forests, biological diversity, and forest health and vitality. Buying certified paper has an impact on the preservation of biodiversity. Lastly, the sustainable use of natural resources practised by technical paper manufacturing staff and functions in charge of paper procurement, helps gradually reduce any negative impact of the Group’s operations on endangered forests and allows the Group to address UN Sustainable Development Goals 12 “Responsible Consumption and Production”, 13 “Climate Action”, and 15 “Life on Land”.

Paper cycle
The main raw material used to make paper is wood, which is a renewable resource. The wood is processed into a pulp which is used to make reels of paper. The reels are shipped to the printer to be made into books, magazines and newspapers. Once used, these products can be collected and recycled to be used as a raw material for the production of recycled paper pulp. This virtuous circle helps to instil a circular economy mindset at the Group.

A.2 APPLICATION
PAPER PROCUREMENT
Several measures are implemented alongside responsible paper procurement to control the quality of paper purchased. Initiatives focusing on traceability and monitoring of the quality of paper purchased by printers have made it possible to significantly reduce the proportion of fibres used for publications whose origin cannot be traced and/or to ensure that no fibres are used from forests that are not replanted. Lagardère Publishing asks its suppliers in Asia to ban certain qualities of paper that do not meet the requirements (traceability, fibres from sustainably managed forests, etc.).
At the end of 2016, Hachette Book Group launched a new
programme to verify fibres sourced from Asia that are introduced into the paper it purchases. Each quarter, samples of the paper used for publications distributed by the American subsidiary are tested to obtain assurance that the paper purchased from Asian markets is from suppliers that respect their environmental commitments. To do this, Hachette Book Group has contracted a specialist laboratory to test the fibres of inside pages, cover pages, sleeves and book covers which are selected at random from among the publications printed in Asia. The aim is to ensure that no precious exotic woods are mixed into the weave and that the paper meets the specifications of Lagardère Publishing.
This programme was progressively extended to all Lagardère Publishing entities in France, the United Kingdom and Spain. This represents a significant initiative that rounds out and reinforces the division’s policy of purchasing certified and recycled paper. In 2010, the Group’s Press business committed to using only certified PEFC (or recycled) paper printed by certified suppliers, allowing it to place its printers’ “PEFC certified” logo on mastheads and in credits. Recycled paper is very well suited to the production of newsprint. Le Journal du Dimanche is printed entirely on recycled paper. However, as the supply of recycled paper for magazines remains limited due to the significant volumes required and small number of suppliers in the market, certified paper is preferred. The Group’s operating staff in charge of paper procurement have for some time run a policy to raise awareness of environmental issues with their paper suppliers and printers, both in France and abroad, by encouraging certification. Consequently, around 99% of the paper purchased by Lagardère Publishing was sourced from ISO 14001-certified suppliers.

MONITORING PAPER CONSUMPTION
Operating staff have adopted a number of initiatives to limit wastage (percentage of paper wasted) during the production process (printing and after-press). The wastage rate is calculated by comparing the amount of paper used in the printing process with the amount of paper delivered in the form of books, newspapers or magazines. The rate can vary greatly depending on the printing technology used (type of machine or colours) and the number of books or magazines produced (the print run).
As part of the policy for reducing the paper wastage rate, the teams concerned determine the best technical inputs and carry out detailed calculations of the amount of paper to be allocated to the printer. Improving wastage rates is a key factor in negotiations with printers.
Paper consumption and wastage rates are monitored regularly to:

  • validate the choices of printers, optimal printing techniques and paper (optimisation of reel width and paper size);
  • calculate the number of copies of magazines and newspapers to print according to sales statistics;
  • identify new technologies that could be used (rotating rapidcalibration tools, automatic setting of ink devices);
  • implement rigorous printing press control procedures and optimised machine calibration (inking, size of paper cuts, etc.);
  • inform editorial managers of the most economical formats to help them best meet market requirements;
  • define and validate the best paper allocation schedules in conjunction with each supplier;
  • identify areas for continuous improvement in conjunction with suppliers.

Adjusting the format of publications is another way of optimising book and magazine production. Lagardère Publishing offers a large range of single-format textbooks by title that are optimised to reduce the paper wastage rate in production. Compact textbooks have proved popular with teachers, buyers and pupils, who welcome lighter school bags.
Print-on-demand technology also helps to reduce paper consumption while limiting greenhouse gas emissions for production, storage and transportation. The Group has developed the use of this technology in France, the United States and the United Kingdom, and its catalogue continued to expand in 2019.
In France, Hachette Livre is also using print-on-demand technology as part of a large-scale project launched in association with France’s national library (Bibliothèque Nationale de France), to enable a selection of more than 200,000 works to be made available for purchase via Hachette Livre’s network of bookstores.

WASTE PAPER
With regard to the circular economy (waste prevention and recycling), managing unsold printed material (books and magazines) represents the biggest environmental priority for the Lagardère group. The Group’s Press activities take action upstream to reduce the rate of returns, optimising the number of copies of each title sent to stores. Returns are an inevitable part of newsstand sales; to manage them as effectively as possible, sales managers use specialist software to constantly fine-tune quantities printed and delivered. Over many years, these actions have reduced rates of returns to below the national average.
At Lagardère Publishing, the rate of returns for books concerns operations managed by Hachette Livre Distribution, i.e., all activities in France, Belgium, Switzerland and Canada as well as global export. Returns that are not pulped for recycling are added back to inventories.

A.3 PERFORMANCE

Indicator Unit 2019 2018 2017
Total weight of paper purchased directly kiloton 123,3 180,2 180,6
Total weight of paper purchased and supplied kiloton 152,6 210,9 212,4
Percentage of certified paper % >87 87 87
Percentage of recycled paper % <10 10 10
Rate of returns for Lagardère Publishing % 21,2 22,6 21,7
Percentage of returns pulped and recycled % 76,5 77,1 72,6
Percentage of returns added back to inventories % 23,5 22,9 27,4

4.3.2.2 MANAGEMENT OF ENERGY AND CARBON IMPACTS

The increase in greenhouse gas emissions caused by human activities is undeniably accelerating climate change, which is a global challenge that affects many regions and calls for both a concerted international effort involving many different countries and smaller-scale initiatives led by individual countries, corporates and people. Fighting climate change is a major challenge of our time that needs to be addressed by all companies, both public and private. Taking carbon footprints into account has therefore become essential for any company committed to pursuing a serious CSR strategy.

A.1 STRATEGY
As a leading publisher, producer, broadcaster and distributor of content, the Lagardère group’s main responsibility on the issue of climate change is to use its ability to raise awareness, inform and educate the general public on the issue. Helping to improve the development and sharing of knowledge around climate change, its origins, causes and the various options that exist for reducing its impacts are all topics addressed by the Group’s various media over the course of the year as they cover, handle and analyse the latest developments in this area.
Beyond this specific responsibility, the Group’s activities are largely tertiary in nature, which therefore limits the direct impact it has on the environment and therefore on climate change. Nevertheless, in order to identify the activities responsible for the most greenhouse gas emissions and the actions that could be taken to reduce these emissions, in the first half of 2016, the Lagardère group conducted its first consolidated Bilan Carbone® audit.
In terms of the methodology, the audit was carried out using 2015 business data. It covered all the activities of the Group’s four divisions at that time, and therefore included all direct and indirect emissions, both upstream and downstream, connected with its many operations and sites. The goal of this exercise was not so much to arrive at an accurate number, but to get an idea of the orders of magnitude involved (particularly for most Scope 3 emission sources) and to assess the level of carbon dependence in the value chain. This audit is effectively a strategic analysis tool that has enabled the Group to test numerous assumptions relating to its carbon priorities formulated over the years thanks to its in-depth knowledge of its businesses. The emissions were divided into three main categories in line with the scope for action available to the Group. The last category consists of residual items. The breakdown is illustrated in the chart below.

Breakdown of the Lagardère group’s carbon emissions by scope for action

 

  • 55 % Leverage via influence
  • 26 % Operating leverage
  • 17 % Leverage via sales strategy
  • 2 % Other categories

The highest emissions category is therefore the category offering leverage through influence and includes the following:

  • production and use of the audiovisual and digital equipment used by end customers for the consumption of the Group’s media content (televisions, radios, computers, mobile phones, tablets and e-readers) = 39%;
  • transportation used by spectators attending sports and cultural events in the entertainment venues and stadiums operated by the Group = 13%;
  • transmission of TV/ radio/digital signals to broadcast the Group’s media content = 3%.

In each of these categories, the scope for action is very limited:

  • production and use of audiovisual and digital equipment: the only two actions that are possible for this item are lobbying equipment manufacturers and educating users on responsible ways of operating their equipment (energy consumption and depreciation over time), two areas over which the Group has little influence;
  • transportation used by spectators to attend events: promoting green mobility, partnerships that encourage the use of public transport, car sharing, etc.; these are valid options for spectators that are already at the venue or who live a reasonable distance away. Nevertheless, these actions do little to stop international travel, the majority of which is by air;
  • transmission of TV/radio/digital signals: the Lagardère group is entirely dependent on these networks which are controlled by public and/or private operators

The second highest emissions category is a category that offers scope for action via the sales strategy (17%). This category relates to the manufacture of the products sold at Lagardère Travel Retail’s various points of sale (food and drink, newspapers and magazines, miscellaneous accessories, fragrances and cosmetics, clothing and textiles, etc.). The scope for action is more obvious in this category, namely offering products that are less carbon-intensive and that are produced locally. Many of Lagardère Travel Retail’s stores already sell a large range of local products at points of sale around the world. Offering products that have a lower carbon impact involves implementing a major overhaul of the product offering across the store network.
These first two categories alone account for 72% of the Group’s emissions.
The third category, and one that does offer operational scope for action, accounts for just over a quarter (26%) of the Group’s emissions and includes the following categories:

  • production of paper goods (books, magazines and newspapers) = 11%;
  • distribution of products sold (logistics) = 10%;
  • energy consumed by the Group’s buildings (offices, warehouses, points of sale, venues, etc.) = 5%.

These categories represent the main sources of greenhouse gas emissions that the Group can tackle with a certain amount of ease. The fourth and last category, accounting for 2% of emissions, includes the three remaining emitters linked to the following activities: event organisation/production, production of TV/radio/digital content and end-of-life products.
Lastly, it is worth noting that there is still a great deal of uncertainty surrounding this type of analysis, particularly with regard to the average emissions factors used, assumptions retained, extrapolations and estimates made, etc. The different levels of uncertainty relating to all the emitting activities included in the analysis are summarised in the table below.

Level of uncertainty of emitting items

Emission factor Uncertainty
Manufacture and use of audiovisual and digital equipment +++
Manufacture of goods sold at points of sale ++
Transportation of spectators +++
Manufacture of paper goods +
Distribution of goods sold (logistics) ++
Energy consumed by buildings +
Television/radio/digital signals +++
Event organisation/production ++
Production of TV/radio/digital content +++
End-of-life products ++

The results of this analysis are used to support the initiatives started many years ago by the Group as part of its carbon-reduction strategy. This consists in focusing on the areas in which the Group has genuine scope for action, namely:

  • production of paper goods, books and magazines (see section 4.3.2.1);
  • controlling energy consumption in offices, points of sale, warehouses and entertainment venues (see next section);
  • optimisation of logistics (see next section).

The Group has not yet identified any operations likely to be heavily impacted by the increase in frequency or intensity of climate-related incidents. Accordingly, since the Group considers that this situation is not likely to hinder the smooth functioning of its activities, it has not yet put in place any specific measures to adapt to the consequences of climate change.

A.2 APPLICATION
WITHIN THE BUSINESS LINES
Lagardère Publishing continued its policy of verifying the fibres used in the production of paper sourced from Asia. Initially launched in the United States in 2016, this initiative was rolled down to the division’s other geographies in 2017. This environmental performance tool rounds out the Cap Action Carbone programme, through which Lagardère Publishing has displayed two labels on all French language books for the last five years: the carbon footprint of the item and the source (certified or recycled) of the fibres used in their production.
Lagardère Travel Retail’s programme to refurbish its Relay stores in France provided the opportunity to test an upcycling project which has helped limit greenhouse gas emissions and reduce transportrelated emissions from warehouse deliveries. Lagardère Duty Free has operated a fleet of hybrid vehicles since 2015. The use of this fleet at Paris-Charles de Gaulle and Paris Orly airports has reduced fuel consumption by 20% per year. Elsewhere, across the international store network operated by the division, energy optimisation programmes have been set up involving such actions as switching to LED bulbs and using refrigerators with doors.
The Group and its divisions each organise their own approach to this challenge, for instance by developing awareness campaigns and training programmes to help their employees understand the concerns specific to their particular business and the tools and measures available to manage them.

OFFICE PREMISES
The Lagardère group is implementing a strategy to reduce its carbon footprint at its office premises in three ways:

  • opting for energy-efficient buildings and/or buildings with environmental certification for employees of Group companies. For example, the headquarters of Hachette Livre at Vanves in the Paris area, obtained HQE NF very high environmental standard certification for commercial buildings, as well as the BBC energy efficiency label. The new headquarters of Hachette UK, Carmelite House, has BREEAM certification;
  • implementing a programme to increase its use of low-carbon energy sources. Several of its premises in Paris have been heated for years by a district heating system supplied by Compagnie Parisienne de Chauffage Urbain (CPCU). In late 2017, the Group switched to clean electricity to supply all of the sites that it controls in France;
  • using offices in a rational and pragmatic way. The Group’s office premises are increasingly being configured for optimal daily energy consumption (LED lighting, occupancy sensors, labelled computer equipment, equipment sharing, etc.).

A.3 PERFORMANCE

Indicator Unit 2019 2018 2017
CO2 emissions per €m of revenue tCO2 eq 15,6 14,6 15,6

The ratios presented in the table above refer to Scopes 1 and 2 emissions described in A.1 of section 4.4.3.

4.3.3 RESPECT FOR HUMAN RIGHTS

4.3.3.1 RESPECT FOR PRIVACY

With the explosion in the amount of data available online and the surge in cyber-attacks in recent years, personal data protection has become a major social issue that requires increased responsibility and vigilance. Information systems are of critical importance in the day-to-day operations of the Group, and contain confidential data relating to how its businesses are run as well as personal data concerning third parties (particularly customers, suppliers and web users) and the Group’s employees.

A.1 STRATEGY AND APPLICATION
The Group’s IT systems contain personal data on Group employees and third parties, including magazine and partworks subscribers, the travelling public (Duty Free) and website visitors (Media, Education). Since the adoption of the General Data Protection Regulation (GDPR) applicable in France and all EU Member States as of 25 May 2018, this issue has been brought into the spotlight and to the public’s attention, requiring the close involvement of the relevant authorities. Legal precedent has begun to be established, particularly concerning sanctions and the exercise of certain rights such as the “right to be forgotten”.
The Group has been actively implementing the Regulation since 2016 with the full support of the Managing Partners. After initial awarenessraising initiatives run by the Group in its divisions as from mid-2016, a dedicated task force was set up at Group level, coordinated by three departments and comprising the Data Protection Officer (DPO), the Group IT Director and the Chief Compliance Officer.
A Steering Committee was also set up with the divisions under the responsibility of the DPO, and a network of officers created in the divisions. This has enabled various applications, tools and policies to be validated for compiling information on data processed and ensuring that personal data are duly protected (see section 3.2.6.5). The GDPR compliance programme is now part of the Group’s continuous improvement process, alongside all other risk management and compliance programmes. As an example, a number of internal audit missions were conducted in 2019 with additional engagements planned for 2020.
Chapter 3 - Risk factors and control system, describes all measures undertaken in the area of information system security and the application of the General Data Protection Regulation. Protecting intellectual property is a central priority at Lagardère Publishing, as its publishers are the custodians of their authors’ rights.

4.3.3.2 RESPECT FOR FUNDAMENTAL FREEDOMS
In an increasingly transparent world, companies are faced with growing expectations from all quarters to demonstrate that they respect human rights in their operations and value chains. It is the responsibility of governments to transpose international human rights obligations into national legislation and ensure they are applied. But companies must also respond to the objective and challenge to enforce internationally recognised human rights. As business organisations have some control over the human rights of their employees and contractors, the people who work for their suppliers, the communities that revolve around their business activities, and the end users of their products and services, many nations have passed regulations that set out protective measures to prevent human rights violations by companies, including laws on labour, discrimination, the environment, and health and safety. Business conduct can therefore have a direct or indirect positive or negative impact on human rights.
In practice, some rights are more relevant than others depending on the industry, region or circumstances. For the Lagardère group, human rights issues can be split into three main categories. First is the positive external influence of the Group’s businesses on culture and education and its operational experience of human rights issues (especially the right to education and freedom of expression). This positive impact is described in detail in section 4.3.1.3. Second, human rights are also an internal priority, affecting all Group employees and including risks associated with working conditions, health, safety and security, and discrimination. In addition to the information above, section 4.3.1.2 goes into further detail on the Group’s policy on diversity and gender balance in human capital. Lastly, the risk of human rights violations is also considered to be a priority in the supply chain and sustainable procurement, and in the relations that the Group’s operating entities maintain with their suppliers and subcontractors.

A.1 STRATEGY
Since it signed the United Nations Global Compact in 2003, the Lagardère group has pledged to make respect for human rights and fundamental freedoms a key focus of its sustainable development policy. Although the Group’s businesses are service-oriented, which tends to limit its negative impacts, all Group employees take steps to ensure that business development and growth do not conflict with respect for human rights.
In addition to the Global Compact, the Lagardère group undertakes to uphold internationally recognised human rights set out in documents such as the International Bill of Human Rights (Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights), the fundamental conventions of the International Labour Organization, and the Guiding Principles on Business and Human Rights (implementing the United Nations “Protect, Respect and Remedy” Framework, or Ruggie Principles). The Group’s Code of Conduct also outlines a set of guiding principles which employees undertake to apply, including individual respect, working conditions and social dialogue – all issues to which the Group is strongly committed.
The Code formally prohibits discrimination and any form of harassment, capital punishment, mental or physical coercion. As regards working conditions, the Lagardère group is committed to applying the laws in force governing health, hygiene and safety at work, and to taking all reasonable precautions to keep the working environment safe and secure for all. Where there is a risk to life and limb, the Group recognises employees’ right to withdraw their labour in accordance with the law. The Group also strives to reduce occupational health risks, ensuring that all employees are sufficiently well-informed to carry out their duties, and committing to maintaining open social dialogue so that issues can be dealt with effectively at the local level.
In terms of social dialogue, Lagardère acknowledges the importance of having freely-elected, independent employee representatives, with whom it can discuss occupational health and safety issues, working conditions and organisational changes that impact the professional environment. This relationship is underpinned by the basic principle of maintaining the right balance between economic and labour priorities at all levels of the organisation (entities, divisions and corporate). Lastly, in 2013, the Group adopted a continuous improvement process to advance its sustainable procurement strategy and practices. Since then, the Group’s strategy in this area has been based on:

  • a Sustainable Procurement policy that promotes issues such as respect for the environment, diversity and social inclusion, quality of governance and easier access to VSEs and SMEs for the Group’s procurement specialists, encouraging them to consider the cash flow constraints of small suppliers and select sustainable suppliers;
  • a Responsible Supplier Charter based on a certain number of international standards, such as the OECD Guidelines, the ILO Conventions and the UN Global Compact, which must be signed by new contractors working with a Group company;
  • a joint project with EcoVadis to conduct regular assessments of the social, environmental and ethical performance of its suppliers and subcontractors.

A map of the Group’s risks associated with the activities of suppliers and subcontractors was defined in 2017 as part of the duty of care plan. This map has strengthened the Group’s sustainable procurement strategy by identifying seven major procurement categories that are most likely to generate risks involving personal health and safety, human rights or the environment (see section 4.7.1 for further details on these seven procurement categories).

A.2 APPLICATION
In terms of labour relations and social dialogue (see section 4.4.1.A.2 for further information), the Lagardère group has freely-elected independent employee representatives through whom it can regularly discuss labour issues that have an impact on employment such as working conditions and restructuring.
On the topic of health and safety, each division has a policy to reduce occupational health risks through preventive action and training. The Lagardère group closely monitors the indicators covering work-related accidents and their prevention.
The Group has also used three indicators for several years to report any human rights violations in which one of its operating entities could to some degree be indirectly involved. The number of formal disputes involving discrimination, forced labour and child labour was monitored to measure the maturity level of Group companies. In 2019, a harassment barometer was added to the list, bringing the number of formal dispute key indicators to four. Throughout the year, the Group’s operating entities implemented action plans designed to address specific business concerns, based on the decisions made under the duty of care plan. They primarily focused on suppliers and subcontractors operating in procurement categories at the highest risk level and in countries considered to have the most exposure to CSR risks, and with which procurement spending was most significant.
Based on this ranking, 65 suppliers were assessed in 2019 in partnership with EcoVadis.
At Lagardère Publishing, supplier assessments concerned businesses operating in publishing (printers, paper suppliers and after-press businesses) and wholesale accessories and household items.
The priority assessment category for Lagardère Travel Retail concerned suppliers of own-label products sold in stores, although it also conducted assessments of food product, accessory and textile suppliers.
The Responsible Supplier Charter stipulates that publishers can initiate on-site compliance audits at the supplier or subcontractor premises, or at any of their production sites, with penalties applied for any infringements. Hachette Livre commissioned six such on-site supplier audits in 2019, and at its request, was also given access to 35 social audits on other suppliers. As a result of these 41 social audits, the Group identified three major breaches, giving rise to the following decisions: Hachette Livre decided to discontinue its commercial relationships with two suppliers; a third service provider carried out the required remedial actions to correct critical non-compliance issues. Compliance was then retested in a follow-up audit carried out six months later.

A.3 PERFORMANCE

Indicator Unit 2019 2018 2017
Number of formal disputes involving discrimination No. 16 12 6
Number of formal disputes involving forced labour No. 5 5 0
Number of formal disputes involving child labour No. 0 0 0
Number of formal disputes involving harassment No. 11 - -
Proportion of workforce covered by employee representation
at 31 December		 % 70 68 71

Number of work accidents and days’ absence due to work accidents

Division Number of
accidents		 Number of days
of absence due
to work accidents
Lagardère Publishing 131 4 985
Lagardère Travel Retail 622 20 396
Lagardère News 6 170
Lagardère Live Entertainment 1 48
Other Activities 22 547
Other assets pending disposal at Lagardère Active 4 134
Lagardère Sports 12 148
Group total 2019 798 26 428
Group total 2018 670 21 776

Frequency and severity rate(1) and lost time(2) due to work accidents

Division Frequency rate Severity rate Lost time
  2019 2018 2019 2018 2019 2018
Lagardère Publishing 11,77 % 8,70 % 0,45 % 0,26 % 0,11 % 0,06 %
Lagardère Travel Retail 17,16 % 16,09 % 0,56 % 0,52 % 0,19 % 0,11 %
Lagardère News 3,96 % 4,29 % 0,13 % 0,10 % 0,01 % 0,01 %
Lagardère Live Entertainment 10,26 % 0,00 % 0,49 % 0,00 % 0,00 % 0,00 %
Other Activities 58,56 % 27,91 % 1,40 % 2,04 % 0,03 % 0,05 %
Other assets pending disposal
at Lagardère Active		 6,33 % 4,67 % 0,17 % 0,74 % 0,01 % 0,03 %
Lagardère Sports 5,18 % 9,41 % 0,06 % 0,20 % 0,01 % 0,03 %
Group total 2019 15,28 % 13,26 % 0,50 % 0,43 % 0,44 % 0,31 %

Social dialogue and health and safety

Indicator Unit 2019 2018 2017
Percentage of the workforce at an entity with a health and safety committee % 91 91 86
Percentage of the workforce at an entity with regular health monitoring % 59 68 73
Percentage of training hours dedicatedto health and safety % 13 13 11

Several formal disputes(3) involving harassment, forced labour and discrimination were recorded in 2019.
Three-fifths of these incidents concerned a single entity in the United States. Out of a total of ten discrimination disputes at this entity, one was settled out of court, five were decided in favour of the entity further to arbitration (complaint dismissed by the competent authorities), and four remain under investigation. All five disputes concerning forced labour recorded at this entity have been resolved. Out of the four cases of harassment at the same entity, one is pending mediation, another is under investigation, one was settled in favour of the entity further to arbitration (complaint dismissed by the competent authorities) and the final case was decided in favour of the complainant.

(1) Taux de fréquence = nombre d’accidents du travail avec arrêt x 1 000 000/nombre d’heures travaillées ; taux de gravité = nombre de jours d’arrêt x 1 000/nombre d’heures travaillées.
(2) Taux d’absentéisme : (nombre de jours d’arrêt x nombre moyen d’heures travaillées par jour)/(nombre d’ETP permanents sur l’année x nombre moyen d’heures travaillées par an).
(3) Par contentieux, nous entendons toute action ou plainte légale enregistrée formellement auprès de toute autorité compétente.

4.3.4 PREVENTING CORRUPTION

Due to the broad diversity of its businesses and those of the outside organisations with which it deals, and its international operations and/or expansion in countries that may be vulnerable to political or legal upheaval, the Group is exposed to risks, including corruption (see section 3.1.3.1).

A.1 STRATEGY
The Group has adopted a zero-tolerance policy in respect of corruption. This policy has taken shape in a special compliance programme that has been gradually implemented since 2013. The programme includes an anti-corruption policy applicable to all, setting out the Group’s ethical standards. As such, the Group refuses to promise, offer, authorise, grant, solicit or accept illicit payments or other undue benefits with a view to winning or retaining contracts, illegally influencing the decisionmaking process, abusing any real or supposed influence on a third party to obtain a favourable decision or any other illegitimate advantage.
Overseen by the Group Compliance Department, this policy is applied through specific procedures that provide a framework for business activities deemed at risk, as well as control processes to ensure procedures are followed.

A.2 APPLICATION
The anti-corruption programme is designed and coordinated centrally by the Group Compliance Department. It has been implemented gradually since 2013 and applied by the operating entities.
On the ground, Compliance Correspondents communicate anti-corruption principles through training and provide operational staff with assistance and support in analysing risks, carrying out the necessary due diligence on future partners, taking appropriate measures to prevent the occurrence of acts of corruption and answering questions from employees.
Managers and employees are trained in anti-corruption issues. They are required to comply with regulations in force and to apply the anti-corruption policy in their relations with all third parties, including governments, quasi government bodies, and public and private customers and suppliers. When the Group embarks on external growth transactions, specific due diligence is conducted to identify any corruption risks. Furthermore, the Group prohibits political donations.
Details of the measures undertaken in this area are described in section 3.2.6.5 – Description of internal control and risk management procedures – of this Universal Registration Document, in the sub section on business ethics.

A.3 PERFORMANCE
Anti-corruption performance is monitored at several levels:

  • twice a year, the divisions prepare a dashboard which includes a progress report on the implementation of anti-corruption procedures, training provided and any incidents, as well as priorities set for the upcoming period;
  • any significant issues are reviewed by the Financial Committee and undergo specific analysis to measure compliance risks, including corruption risk;
  • internal control procedures cover compliance aspects;
  • lastly, internal audit regularly checks the implementation of the anti-corruption programme at the different entities.