Good Operations 2017 How we live our mission - Novamedia Sverige AB - Postkodlotteriet
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Good Operations 2017
How we live our mission
Novamedia Sverige AB 1
Contents
Scope and boundaries of the report
1. A message from the Managing Directors 4 and guidance for reading
2. About Novamedia Sverige 6 This sustainability report is about Novamedia Sverige AB (company registration no.
556375-6328), a company operating on Sweden’s regulated gaming market.
3. Good Operations – agenda & governance 12 Novamedia Sverige AB develops and operates charity lotteries under the Swedish
Postcode Lottery brand, on behalf of the Swedish Postcode Association (company
4. Stakeholder engagement 16 registration no. 802416-1146). Novamedia Sverige AB is a wholly owned subsidiary
of Novamedia B.V. (registered company no. 33293056) based in Amsterdam (NL)
and, together with other subsidiaries, is part of the Novamedia group.
5. Materiality analysis 18
In the report, Novamedia Sverige AB is referred to as ”Novamedia Sverige” or ”the
6. Good Operations in 2017 20 company”; the Novamedia group as ”Novamedia” or ”the group”; Novamedia B.V.
as ”the parent company”, and the Swedish Postcode Association as ”the
7. Reporting principles 36 association”.
8. GRI index 37 The relationship between Novamedia Sverige and the Swedish Postcode Association
is very much one of mutual dependence. Novamedia Sverige has granted the
Swedish Postcode Association an exclusive licence to use the Postcode Lottery pro-
duct format and brand on the Swedish gaming market. The Swedish Postcode Asso-
ciation holds lottery-operator permits and Novamedia Sverige is the operating com-
pany that handles business development and the operation of the Swedish P ostcode
Lottery on behalf of the association. A significant part of the impact that the compa-
ny’s activities have on society are caused by the donations from the lottery that is
generated by the Swedish Postcode Lottery and distributed by the Swedish Postcode
Association. Guided by discussions with stakeholders and the materiality analysis,
Novamedia Sverige has therefore concluded that the sustainability report should
include parts of the Swedish Postcode Association’s operations, in order to give a
fair picture of Novamedia Sverige’s operations.
2 3
1 A message from the Managing Directors 1 A message from the Managing Directors
1 A message from
the Managing Directors
Sustainability is part of Novamedia Sverige’s Sustainable supply chain Employee engagement
DNA. Its operations, which are based on four For us it is very important to have good know- Without our engaged and competent employees,
core values - courageous, fun, sharing and ledge about our suppliers and partners, not least we will not be able to develop and run successful
sustainable – is driven by the firm belief that the because we want to offer our winners prizes that lotteries. A central priority for us is therefore to
world needs a strong civil society. are produced sustainably and in compliance with offer our employees a good and non-discrimina-
human rights. We therefore work with a code of tory work environment characterized by diver-
Strong and independent non-profit organisations conduct for suppliers and partners. This is an sity and gender equality. Unfortunately, the
can drive the development of society in a important starting point when engaging in dia- Swedish gaming market is currently quite une-
positive direction. Their work is essential if we logues with them on how to bring the develop- qual from a gender perspective. We find it our
are to achieve the aspirations of UN:s Agenda ment forward in our respective supply chains. responsibility not only to ensure that we as a
2030 for sustainable development. company provide equal opportunities, but also
Business ethics to try to push the entire industry in the right
Novamedia Sverige develops and runs charity Novamedia Sverige should always act respon- direction. As a result, we have reached out to
lotteries. The players are core to us as without sibly. For us it is essential to run our business in other gaming operators in an effort to jointly
them we cannot deliver on our vision. As a accordance with laws, regulations and applicable work on this important issue. It will take time,
result, our sustainability work – Good Opera- ethical guidelines. We are required to follow the but we are convinced that together we can make
tions – is closely linked to the needs and Lottery Act, the stipulations in the lottery per- progress and eventually make the entire industry
expectations of those who buy tickets, and mits and a number of other applicable laws in more equal.
include the following areas; Sweden. One example is the General Data Pro-
tection Regulation (GDPR) that will enter into Agenda 2030 is everyone’s business. Year 2030
The environment force in May 2018. We have worked hard during may feel far away, but time is short if we are to
We want to contribute to a positive development 2017 to ensure compliance with the new law. achieve the seventeen Sustainable Development
of society and that includes a healthy planet. To This is an important step forward to ensure that Goals that define the world’s aspirations for the
strive to minimize the negative climate impact of we safeguard the integrity of our player’s perso- future. For us this entails continuing to run the
the business is therefore a priority for Novame- nal information. lottery that thanks to our players can generate
dia Sverige. The largest carbon footprint from charitable donations to the non-profit sector as
the business arise from the purchases of prizes Responsible gaming well as to run our business in respect to people
that is provided to winners of the lottery. In Gambling is associated with a risk. About two and the planet across the entire value chain. But
order to counteract this negative impact, Nova- percent of the adult population in Sweden suffer we cannot do this in isolation. We therefore look
media Sverige climate offsets for its carbon foot- from gambling problems*. We work with pre- forward to yet another year of engagements with
print of its entire value chain. The next step for ventive measures to create a safe gaming our player and other stakeholders so that we can
us is to work innovatively with the prize plan to environment for our players to counter any jointly contribute to putting the world on a sus-
ensure a lower carbon footprint while simulta- adverse consequences of gaming. Among other tainable path.
neously maintaining a high level of satisfaction things, we educate all our staff in responsible
amongst our players. gaming and provide our players with responsible Anders Årbrandt and Cecilia Bergendahl
gaming tools. In 2018, we will take additional Managing Directors, Novamedia Sverige
* Source: The Swedish Public Health steps within this area as high consumer protec-
Agency’s Swelogs Prevalence Study 2015. tion is very important to us.
4 5
2 About Novamedia Sverige 2 About Novamedia Sverige
2 About Novamedia Sverige
Novamedia Sverige believes that the world is for the non-profit sector and increases awareness
better off with a strong civil society. This of the important work of non-profit
belief is at the heart of the company’s busi organisations.
ness model. Novamedia Sverige operates the
Swedish Postcode Lottery on behalf of the From the start, Novamedia B.V. has been a media Vision – the Why
Swedish Postcode Association with the aim of organisation that aimed to generate revenue for
We believe the world is better
offering an entertaining lottery that generates the non-profit sector. A few years after it was off with strong social
funds for charity. established, Novamedia B.V. developed the Post- organisations. There can be
code Lottery format and in 1989 the first Post- no change without them.
The vision and history behind code Lottery was launched in the Netherlands,
Novamedia which enhanced the parent company’s ability to
Novamedia Sverige is a wholly-owned subsidiary provide financial support to non-profit organisa-
of Novamedia B.V. The parent company Nova- tions. Given the success of the Dutch Postcode Mission – the How
media B.V. was established in 1983 with the Lottery, Novamedia B.V. later established Post-
To raise funds for social
vision and the belief that the world is better off code Lotteries in the UK, Germany and Sweden. organisations worldwide,
with a strong civil society. The purpose of Nova- In 2018, a Postcode Lottery will be established increase awareness of their
media B.V.’s and Novamedia Sverige’s operations in Norway. Novamedia B.V. is the creator and work and to promote their
new initiatives.
is to act as an enabler for civil society by opera- owner of the product format and the Postcode Why
ting business in a way that is sustainable in the Lottery brand. The idea behind the Postcode
long term. Business that in turn generates money Lotteries is illustrated on page 7.
Activity – the What
We operate charity lotteries
to raise funds for social How
organisations and good
causes and make good
citizenship fun.
What
6 7
2 About Novamedia Sverige 2 About Novamedia Sverige
Novamedia Sverige and beneficiaries of the donations from the lottery.
the Swedish Postcode Association The Swedish Postcode Association decides who
To enable Novamedia to launch the Postcode may be a member and distributes the donations
Lottery in Sweden, the Swedish Postcode Associ- to its members. The Swedish Gambling Autho-
ation was set up in 2005. This was because rity oversees and checks the lottery operations of
Sweden has a gambling monopoly, meaning that the Swedish Postcode Association on an ongoing Novamedia Fundatie
the state-owned company Svenska Spel is basis, and checks and approves the donations (Foundation)
currently the only company that can carry out generated by the Swedish Postcode Association
gambling operations in Sweden. A precondition for the public good.
for operating independent lotteries in Sweden is
that it must contribute to the public good. It is The organisational structure of the Novamedia Novamedia Holding B.V.
the Swedish Gambling Authority that grants group and the relationship between Novamedia
lottery permits and the convention is that per- Sverige and the Swedish Postcode Association
mits are granted only to non-profit organisations are illustrated on pages 9 and 11.
and foundations. Novamedia B.V.
The current state of
The Childhood Cancer Foundation (Barncancer- the Swedish gambling market
fonden), Save the Children (Rädda Barnen), the The Swedish gambling market consist partly of a
World Wildlife Fund (Världsnaturfonden WWF) regulated market operating under the Swedish Netherlands UK Germany
The Swedish Licence and
and the Swedish Postcode Foundation (Svenska Gambling Authority’s supervision and partly of Postcode Association Novamedia Sverige AB
operating agreement
Postkodstiftelsen) have been members of the In the Netherlands and the UK, non-profit organisations are
an unregulated market with actors without a the holders of lottery licences for their respective markets.
association from the start. Novamedia Sverige permit to operate in Sweden. These actors are Like the Postcode Association in Sweden, these organisa-
has granted an exclusive licence to the Swedish based and operate from abroad. The actors ope- tions have agreements with the Novamedia group that
Postcode Association to use the product format governs their cooperation.
rating in the unregulated market are increasingly
and the Postcode Lottery brand on the Swedish gaining market share. These new market condi-
gaming market. The Swedish Postcode Associa- tions have spurred the government to put forth
tion holds the permits to operate a lottery and an Inquiry of a Re-regulated Gambling Market.
Novamedia Sverige is the operator company A proposal of the inquiry was presented in
that, on behalf of the association, handles busi- March 2017. Novamedia Sverige has been part of
ness development, operations, and the produc- the referral rounds and the company’s main mes-
tion of TV programmes and lottery products that sage in the discussions has been to underline the
go under the Swedish Postcode Lottery brand. importance of securing revenues for a strong,
Novamedia Sverige is responsible for all employ- independent non-profit sector by exempting
ees and has its office in Stockholm. charity lotteries from taxes. The Government
will submit the bill to the Parliament in March
The Swedish Postcode Association has an inde- 2018 and the decision in Parliament is expected
pendent board and 57 members. The members to take place in May 2018. A new law is
are nonprofit organisations, 55 of which are expected to enter into force 1 January 2019.
8 9
2 About Novamedia Sverige 2 About Novamedia Sverige
An entertaining lottery Novamedia Sverige’s core values
In 2017, Novamedia Sverige operated six lotte- Novamedia Sverige’s operations are based on
ries on behalf of the Swedish Postcode Associa- four core values – courageous, fun, sharing and
tion, for which the association had six active lot- sustainable. These values are shared by all
tery permits. The main product – the Swedish entities within the Novamedia group and are
Postcode Lottery – is a subscription lottery that intended to inspire and unite all the employees.
is based on the idea of one player winning with The values should inform all the company’s day-
his or her neighbours. In addition to the sub- to-day operations and guide activities and deci-
scription lottery, an online portfolio with bingo sions within Novamedia Sverige. Lottery prizes
and scratch card games are offered. Entertain- 1.4 billion
ment is also an important element of the
Swedish Postcode Lottery. TV programmes Revenues from
lottery and games
include PostkodMiljonären (Postcode Millio- 3.5 billion Operating costs
naire), En ska bort (Odd One Out) and Dröm ≈ 1 million lottery players include:
≈ 19 million lottery tickets sold
pyramiden (Dream Pyramid). Operating costs
1 billion
Lottery economics in a nutshell
The Swedish Postcode Association reimburses
123 45 AB 123
Postkod Personligt nummer
Personnel
costs
Permit holder Novamedia Sverige AB
Novamedia Sverige for the costs incurred in Game operator
developing and operating the lotteries and pro- 1.1 billion !
ducing the TV programmes. Around 40% of the Costs of sales,
total proceeds from lotteries and gaming go back ex. advertising
to the players in the form of lottery prizes. The
donation is what remains after costs and lottery 20 milj
prizes have been deducted. The donation is dist-
Other costs,
ributed by the Swedish Postcode Association to ex. IT
the non-profit organisations and foundations
that are members of the association and benefici-
aries to the lottery donations. In 2017, the total
Novamedia B.V.
income from lotteries and games was SEK 3.5 Licence fee to brand owner
... and 51 more beneficiaries
billion, lottery prizes amounted to SEK 1.4 bil- * All figures are in SEK.
lion and the lottery donation was SEK 1.1 bil-
lion. Since it started twelve years ago, the
Swedish Postcode Lottery has generated just
over SEK 9.4 billion to charities.
10 113 Good Operations – agenda & governance 3 Good Operations – agenda & governance
3 Good Operations
– agenda & governance
Novamedia Sverige was founded on the basis People and Openness. These pillars form the
Novamedia Sverige’s objectives
of a desire and ambition to contribute to a foundation of the group’s sustainability priorities
positive development of society. It is therefore and implies that the business shall be operated Strong civil society • We communicate and are transparent in regards to how and on what basis
natural that the company integrates a sustain transparently and with respect to people and the the charitable donations are distributed.
ability perspective in its daily operations. environment across the entire value chain. Nova-
media Sverige’s prioritized areas include: Responsible gaming • We create a safe gaming environment for lottery players to counter any
Good Operations agenda adverse consequences of gaming.
The Novamedia group is a values-driven com- • Strong civil society: To enable the Swedish • We aim for zero upheld complaints regarding commercial
pany that since its inception has worked on sus- Postcode Association to generate donations communications.
tainability by operating a business with a clear from the lottery for charities, so that these • We transparently disclose any upheld complaints.
social mission. In 2009, Novamedia broadened charities can carry out their important work.
the concept of sustainability and developed a Business ethics • We have zero tolerance for bribery, kickbacks and corruption.
sustainability vision – Planet First. It was based • Responsible gaming: To actively promote • We tolerate zero errors in draws and payment of prizes.
on the fundamental idea that a healthy planet is responsible gaming with a focus on prevention • We minimise risks to customer privacy by implementing
an essential precondition for both social and and responsible campaigning in order to technological innovations.
economic growth. Since then the concept of sus- reduce the adverse consequences of gaming. • We train staff in relevant laws and regulations.
tainability for Novamedia has broadened even • We communicate openly in case of incidents.
further and today the group’s operations are gui- • Business ethics: To operate the business in a
ded by a s ustainability vision that goes under the responsible and ethical way in close dialogue Sustainable supply chain • We strive to purchase non-cash prizes from suppliers that run sustainable,
name Planet & People. Based on this new vision, with stakeholders. socially responsible operations.
the group has developed a Good Operations • We strive to work with local suppliers.
agenda that is based on three pillars – Planet, • Sustainable supply chain: To work with • We request our significant suppliers to commit to our code of conduct.
responsible suppliers with sustainable value
chains to ensure that purchases are made at the
Climate and environment • We strive to reduce our CO2 emissions.
”right price” with social and environmental
• We purchase green electricity produced locally.
costs factored in.
• We strive to generate our own renewable energy.
• Climate and environment: To operate the
business with the aim of minimising the nega- Attractive employer • We aim for an equal gender balance at the top.
tive impact in the short term and in the long • We aim for a diverse workforce throughout the company.
term having a positive impact on the climate • We advocate equal treatment regardless of age, ethnicity, gender,
and the environment. sexual orientation or disability.
• We consult our employees on how they perceive the company as an employer.
• Attractive employer: To engage in good
employment practices and offer a good and
non-discriminatory working environment that
is characterised by equality and diversity.
12 133 Good Operations – agenda & governance 3 Good Operations – agenda & governance
Governance Monitoring Responsibility
Strong civil society
• The Lottery Act • Annual evaluation of beneficiaries and special projects The lottery director has the overarching responsibility for
• Guidelines of the Swedish Fundraising Council (FRII) on • Beneficiary forum (twice a year) governance and reports to the Swedish Gambling Autho-
impact reports • Regular contact and dialogue with beneficiaries rity. The Charity department has operational responsibility
Sustainability governance Strong civil society – part of • Business process – Monitoring of the association’s • Regular contact with the Swedish Gambling Authority for monitoring beneficiaries.
beneficiaries
The sustainability agenda Good Operations is set Novamedia Sverige’s vision, • Business process – Admission of the association’s The board of the Swedish Postcode Association has the
centrally by Novamedia B.V. in co-operation with sustainability agenda and mandate beneficiaries ultimate responsibility for taking decisions concerning the
• Business process – Special projects which beneficiaries and special projects should be
the national entities. There is an international Since Novamedia Sverige’s vision of a strong civil • Voluntary work policy supported. The Swedish Postcode Association’s board
Good Operations team with representatives from society is central to its operations, it is naturally decides how the charitable donations generated by the
The Swedish Postcode Association’s governance documents: Postcode Lottery should be distributed between the
each country, which functions as a working also a prioritised sustainability area. It is through • Lottery permits beneficiaries.
• Distribution policy and distribution model
group. The Good Operations agenda is then app- the mandate from the Swedish Postcode Associa-
lied within the framework for each country’s tion, which holds the permits to run the lottery, Responsible gaming
operations, allowing for local adaptation to meet that Novamedia Sverige realises its vision. There- • The Lottery Act and the Swedish Gambling Authority’s • Annual situational analysis based on legal requirements The CSR department has the overarching responsibility for
regulations for the protection of social interests and SPER’s guidelines the governance and monitoring of responsible gaming.
respective country’s circumstances. fore, the majority of policy documents that origi- • The guidelines of SPER • Annual GamGard risk analysis on the product portfolio Operational responsibility is an integral part of day-to-day
• The Swedish Marketing Act • Regular quality checks of customer service activities, as well as being the responsibility of the manager
nate from the Swedish Postcode Association also • The International Chamber of Commerce rules on adverti- • Responsible gaming education in charge.
Since 2015, Novamedia Sverige has been run by guide and control the work of Novamedia Sve- sing and marketing communications
• The Swedish Direct Marketing Association’s business and
two Managing Directors – Cecilia Bergendahl rige. The table on page 15 provides an overview ethics guidelines
and Anders Årbrandt. Cecilia Bergendahl also of the governance for Novamedia Sverige’s sus- • Kontakta’s ethical rules for sales and marketing by
telephone to consumers
holds the position as the lottery director at the tainability work.
Swedish Postcode Association. The lottery Business ethics
director is responsible for ensuring that the lot- • The Lottery Act and other legislation • External audit of financial accounts The Risk Management & Legal department and the CSR
• Policy for Risk Management • External assurance report describing the entire lottery department supports the company’s employees and external
tery operations are carried out in accordance • Authorisation policy process for players stakeholders and helps them to take responsible, ethical
• Guidelines governing the acceptance of gifts to reduce and well-founded decisions. Operational responsibility is
with applicable permits, conditions and provi- the risk of bribes an integral part of day-to-day activities, as well as being the
sions. To provide support for the implementation responsibility of the manager in charge.
of the Swedish Postcode Lottery’s lottery-specific
Sustainable supply chain
processes, Novamedia Sverige has an administra- • Contract policy • Contract review The CSR department has the coordinating responsibility for
• Code of conduct for suppliers • Regular reconciliations in the contract database to ensure minimising any adverse effects that the supply chain may
tive support unit known as the lottery office. • Risk analysis that code of conduct targets are being achieved cause. The department also fulfils a supporting role for staff
• Annual self-assessment by selected suppliers based on making purchase decisions, and is responsible for monito-
the risk analysis ring suppliers. Those with responsibility for purchasing
It is the management of Novamedia Sverige that • Review of external audit reports from production sites of have operational responsibility to ensure the company
is ultimately responsible for governing Nova selected products works with suppliers who meet its sustainability
requirements.
media Sverige’s sustainability work. The compa-
ny’s CSR department has the operational respon- Climate and environment
• Contract policy • Contract review The CSR department has the overarching responsibility for
sibility for adapting the group’s sustainability • Code of conduct for suppliers • Emissions calculations according to the GHG Protocol’s emissions calculations and offsetting, and supports those
agenda to the Swedish context and to ensure that • Travel policy Corporate Value Chain (Scope 3) Accounting and responsible for purchasing in reducing the climate impact.
Reporting Standard Those with responsibility for purchasing have operational
the agenda is integrated into the company’s day- • Investments in emissions-reducing projects certified by responsibility for taking well-informed purchasing decisions
to-day operations. Gold Standard from an environmental perspective.
Attractive employer
Novamedia Sverige’s sustainability work is also • Equality and diversity plan • Employee survey – Great Place to Work The Human Resources department has the overarching
• Work environment policy and work environment plan • Annual salary survey responsibility for the governance and monitoring of work-
governed by the company’s sustainability policy. • Guidelines concerning harassment and abusive behaviour • Regular manager/employee dialogue place issues and management relating to equality and diver-
• Recruitment policy sity. The CSR department plays a supporting role and a
• Wages policy coordinating function. Operational responsibility is integra-
ted into the day-to-day activities and all managers have
responsibility for ensuring compliance with policies and
guidelines.
14 154 Stakeholder engagement 4 Stakeholder engagement
4 Stakeholder engagement
Key questions Examples of dialogues & activities Results
The Swedish Postcode Association
• Selection process of new members • Revision of the beneficiary application process • New beneficiary application process
• Evaluation of fulfilment of membership criteria • Distribution of funds to the beneficiaries • Two new members – Mind and Raoul Wallenberg
• The distribution model and distribution of funds Academy
The stakeholder perspective is a starting is Novamedia Sverige that, on behalf of the • Two approved reviews to ensure adequate membership of
two existing beneficiaries
point for Novamedia Sverige’s Good Opera Swedish Postcode Association, is responsible for • Approval by the Swedish Gambling Authority of the
tions. A transparent dialogue with stake all customer communication and for ensuring distribution of funds to the beneficiaries
holders is integral for the development of the that the prize draws are carried out correctly. The Swedish Postcode Association’s members
operations as well as for defining the The Swedish Postcode Association’s members are • Gambling license inquiry • Regular meetings with a working group with representatives from • Better understanding among beneficiaries of the gambling
• Evaluation of eligibility selected beneficiaries concerning the gambling inquiry license inquiry’s potential impact on funding and grants
company’s responsibility. equally important, as they are affected by how • The frame work of Agenda 2030/the Sustainable • Regular follow-up and monitoring meetings with existing • Announcement of two special projects funds
effectively Novamedia Sverige carries out its ope- Development Goals (SDGs) beneficiaries
• Challenges and needs in the world • Beneficiary forums and participation in beneficiaries´ events as
Novamedia Sverige’s stakeholders include all rator mandate from the association. The diagram part of needs assessment
actors and individuals that in one way or below illustrates all interest groups of relevance
another are affected by or have an effect on the to Novamedia Sverige. Lottery players
(The Swedish Postcode Association’s customers) • Customer satisfaction and experience surveys • Launch of a new customer centric strategy
company’s operations. For instance, the operator • Customer satisfaction and attitudes towards the • Qualitative interviews
mandate includes responsibility towards the lot- A close and transparent dialogue is important for Swedish Postcode Lottery • Easily accessible customer support
• Customers’ perception of the chances of winning
tery players, i.e. the Swedish Postcode Associa- increasing transparency within the company and
tion’s customers. This stakeholder group is of raising awareness about the company among
vital importance as the lottery players are key relevant groups. Page 17 contains a table of key Employees
• Employee perception of the company as an • Great Place to Work survey • The result of the GPTW survey was a Trust index of 73%
actors in enabling the donations from the lottery issues and the results of the dialogues conducted employer
to be generated for the association’s members. It with identified stakeholders during 2017.
Suppliers
• Quality and sustainability requirements for • Regular contact between suppliers and staff responsible for • A small scale-up of the new process of monitoring
purchasing purchasing suppliers that was launched in 2016
• Self-assessment of a number of selected suppliers
The Swedish
Employees Postcode Public authorities and politicians • Participation in the gambling licence inquiry’s reference group
Association • Gambling licence inquiry • Regular dialogue with the Swedish Gambling Authority and the • The result of the gambling inquiry. Novamedia Sverige
• Monthly supplementary applications to the Public Health Agency has pursued the following issues: i) continued tax exem-
The Swedish
Swedish Gambling Authority for the Swedish • Production of the podcast #speleffekten that focuses on the ption for non-profit organisations, ii) technology-neutral
Suppliers Postcode
Association’s Postcode Association’s lottery permits gaming market and the gambling inquiry law, iii) strong consumer protection
members
Interest groups and other gaming companies
• Gambling licence inquiry • Regular dialogue and meetings with other gaming companies • Joint position on the gambling licence inquiry
• Responsible gaming with permission to operate on the Swedish gaming market and
• Ethical and responsible marketing organisations supporting gaming addicts, through the mem-
bership of the Swedish Gambling Association (SPER) and the
Independent Gambling Collaboration (OSS)
Interest groups Lottery players
Media
• Product and company matters • Continuous dialogue with media to enhance engagement and • Regular flow of articles concerning Novamedia Sverige
brand recognition and the Swedish Postcode Lottery
Other gaming The state and
companies local authorities
Media Politicians
16 175 Materiality analysis 5 Materiality analysis
5 Materiality analysis
In order to create value in a changing world, Step 1: Identification of material aspects
Novamedia Sverige has opted to take a proac Novamedia defined material aspects as the areas
tive approach where the sustainability agenda where Novamedia has or may have an impact – Material sustainability aspects
1 Community engagement
is continuously developed in collaboration internally, in the value chain or in society. To
with its stakeholders. gain an overview of all material areas linked to Beneficiaries’ work made
2 possible by charitable
Novamedia’s operations, a summary was drawn 5 1
donations
of Novamedia Sverige
In 2015, the Novamedia group carried out an up based on input from GRI’s guidelines, stake-
extensive materiality analysis, which shone a holder dialogues, trendspotting and media moni- 2 3 Diversity and equality
spotlight on the expectations of the group’s toring. This resulted in a list of thirty areas lin- Emissions and environmental
stakeholders. The purpose of the analysis was to ked to Novamedia’s operations that were identi- 4 management
9
identify the group’s most material sustainability fied as having a potential material impact. 3 5 Regulatory compliance
areas based on the actual impact of its activities
on society, and the relevance for the group’s sta- Step 2: Prioritisation of material aspects 6 6 Responsible gaming
för externa intressenter
keholders. The analysis involved interest groups 7 4
The Novamedia group used two parameters to
from all countries where the Novamedia group pick out priorities from the material aspects 8 Responsible and ethical
7 marketing
stakeholders
operates, including Sweden. The group result of identified in step 1: 1) the significance for Nova-
the analysis provided the basis for the Good media’s internal stakeholders, i.e. employees, Transparency when distribu
8 ting charitable donations
Operations agenda. The result from the dialogue and 2) the significance for Novamedia’s external
with Novamedia Sverige’s stakeholders is presen- stakeholders. A comprehensive survey asking 9 Competitive practices
Betydelsen
ted on page 19 and forms the basis for determi- Novamedia’s stakeholders to prioritise and rank
Importance for external
10
ning the content of this as well as last year’s sus- identified areas then provided the basis for the 10 Supplier monitoring
tainability report. subsequent prioritisation by Novamedia.
The materiality analysis was conducted in a Step 3: Implementation
three-stage process as follows: The ten aspects ranked highest by Novamedia
Sverige’s stakeholders are the ones that are inclu-
ded in this sustainability report. In section 6, the
work carried out within these aspects is
presented.
Betydelsen
Importance for internal för interna intressenter
stakeholders of Novamedia Sverige
18 196 Good Operations in 2017 6 Good Operations in 2017
6 Good Operations in 2017
In 2017, the sustainability work continued to ethics, sustainable supply chain, climate and STRONG CIVIL SOCIETY 2017, the funds that were previously distributed
be characterised by a combination of the environment, and attractive employer. This between the three foundations are concentrated
company’s vision, core values and the require report includes those aspects identified as most Community engagement | Beneficiaries’ work to the Swedish Postcode Foundation (the 2016
ments and expectations of the company’s material by the company’s stakeholders, accor- made possible by charitable donations | Trans funds were distributed in March 2017). There-
stakeholders. ding to the materiality analysis carried out in parency when distributing charitable donations fore out of the 57 members, 55 organisations are
2015. The table below provides an overview of currently beneficiaries.
Novamedia Sverige works on a number of diffe- the most material aspects, followed by a more Through its operator mandate, Novamedia Sve-
rent aspects within its six sustainability areas – detailed description of each aspect framed within rige makes it possible for the Swedish Postcode During 2017, no members ended its membership
strong civil society, responsible gaming, business the company’s six sustainability areas. Association to generate and distribute the funds and two new members were elected to the asso-
from the lottery to its members. As part of the ciation – Mind and Raoul Wallenberg Academy.
mandate, Novamedia Sverige engages in active Mind is an organisation that aims to promote a
Sustainability areas Material sustainability aspects
monitoring and evaluation of all the beneficiaries society where everyone with a mental health
STRONG CIVIL SOCIETY 1 Community engagement to ensure that the donations are used for the issue gets the respect and support they need. The
Implementing activities that improve living conditions in the communities where the public good. This work serves the purpose of Raoul Wallenberg Academy is acting in the spirit
company operates.
2 Beneficiaries’ work made possible by charitable donations
maximizing the positive impact of the donations of Raoul Wallenberg, by supporting young
The enabling effect of the charitable donations from the work of the members of the as well as to ensure continued trust from the people to find the courage to make a difference.
Swedish Postcode Association. association and thereby a continued operating
8 Transparency when distributing charitable donations
Transparency as regards to how and on what basis the charitable donations are mandate.
distributed between the members of the Swedish Postcode Association.
Members of the
RESPONSIBLE GAMING 6 Responsible gaming
Measures that allow lottery players to play responsibly. Swedish Postcode Association
7 Responsible and ethical marketing At the end of 2017, the Swedish Postcode Asso-
Production of marketing that is fact-based and moderate, in order to minimise
misunderstanding.
ciation had 57 members. Of the association’s 57 The Swedish Postcode Association
members, 54 are non-profit organisations with
BUSINESS ETHICS 5 Regulatory compliance Total donations
fundraising 2012–2017
operations in Sweden that are active Number
Numberofof
beneficiaries 20122012–2017
beneficiaries - 2017
Compliance with laws and regulations that the company is bound to follow and
compliance with guidelines adopted voluntarily. both in Sweden and internationally within areas
9 Competitive practices such as the rights of the child, environment and
Affirmation of the company’s competitiveness without acting in an anti-competitive climate, health and research, vulnerable people,
1100
manner.
cooperation across borders and education. In 55
SUSTAINABLE SUPPLY CHAIN 10 Supplier monitoring addition, Novamedia Sverige has established
Monitoring of suppliers’ compliance with the company’s code of conduct.
three foundations which, up until the distribu-
CLIMATE AND ENVIRONMENT 4 Emissions and environmental management
tion of the 2016 funds, were beneficiaries of the
The volume of emissions (measured in carbon dioxide equivalents) that the Swedish Postcode Lottery: Svenska Postkodstif-
operations directly and indirectly generate. Environmental management refers to how telsen (the Swedish Postcode Foundation), Post-
the company directs, leads and develops its environmental work.
kodlotteriets Kulturstiftelse (the Swedish Post-
ATTRACTIVE EMPLOYER 3 Diversity and equality code Lottery’s Cultural Foundation) and Post-
Proactive work to counter discrimination and promote equal rights and opportunities kodlotteriets Idrottsstiftelse (the Swedish Post-
regardless of gender, transgender identity or expression, ethnic group, religion or
other beliefs, disability, sexual orientation or age. code Lottery’s Sports Foundation). Starting2017
from 2017
Fördelning av lotteriöverskott Distribution of total donations 2017
20 2006-2016 212017 2017
6 Good Operations in 2017 2017 2017 2017 2017 6 Good Operations in 2017
Fördelning av lotteriöverskott Distribution of total donations 2017
Fördelning
2006-2016 av
Fördelning
lotteriöverskott
av lotteriöverskott Distribution ofDistribution
total donations
of total
2017
donations 2017
Total donations 2012–2017 Number of beneficiaries 2012–2017 2006-2016 2006-2016
18%
Charitable donations distributed as follows: Un-earmarked donations Un-earmarked donations 18% funds 18%
of the level generated by the Swedish Post-
Overall since 2005 the lottery operations have around 65%, project support via the Swedish In order for the non-profit sector to make an code Lottery are unusual in the non-profit
1100
55
generated SEK 9.4 billion in charitable dona- Postcode Foundation max. 25%, and special impact, it is essential that the organisations
17%
sector.
tions, which has subsequently been distributed projects around 10%. The distribution of the themselves are allowed to decide where 17%the 17%
65%
by the Swedish Postcode Association to its mem- 2017 donations is shown in the diagram below funds are most needed. The majority of the sup- In 2017, the 65% 65% donations amounted
un-earmarked
bers. In 2017, the charitable donations amoun- and is described in more detail on the following port to the Swedish Postcode Association’s bene- to around SEK 719 million, which corresponds
ted to SEK 1.1 billion. The donations are pages. ficiaries is therefore un-earmarked, which means to 65% of the total donations. The diagram
Un-earmarked donations
below shows how the un-earmarked donations
that the organisations themselves decide what Un-earmarked Un-earmarked
donations donations
Special projects
activities the money is used for. Un-earmarked areSpecial
Special projectsdistributed
projectswithin the Swedish Postcode
The Swedish Postcode Foundation
2017 2017 The SwedishAssociation’
Postcode s Postcode
The Swedish focus areas.
Foundation Foundation
The Swedish Postcode Association The Swedish Postcode Association The Swedish Postcode Association The Swedish Postcode Association
Fördelning
Total donations av lotteriöverskott
2012–2017 Number of Distribution
beneficiariesof2012–2017
total donations 2017 Distributions of un-earmarked Distributions of un-earmarked
Distributions Distributions of un-earmarked
of un-earmarked Distributions Distributions
of un-earmarked
of un-earmarked
2006-2016 donations 2006–2017 donations 2017
donations 2006–2017
donations 2006–2017 donations 2017donations 2017
2% 2%
18% 2% 2% 2% 2%
16% 13%
1100
55 16% 16% 27% 13% 13%
27% 27% 25%
25% 25%
9% 13%
17% 9% 9% 13% 13%
65%
23% 23% 26%
23% 23% 23% 23% 21% 26% 26%
21% 21%
Un-earmarked donations Children’s rights Children’s rights
2017 2017 Children’s rights
Children’s rights Children’s rights
Children’s rights
Special projects Vulnerable peoble Vulnerable peoble
Vulnerable peoble
Vulnerable peoble Vulnerable peoble
Vulnerable peoble
The Swedish Postcode Foundation Health and research Health and research
Health and research
Health and research Health and research
Health and research
Cooperation across borders Cooperation across borders
Cooperation across
Cooperation
bordersacross borders Cooperation across bordersacross borders
Cooperation
Environment and climate Environment and climate
Fördelning av lotteriöverskott Distribution of total donations 2017 Environment andEnvironment
climate and climate Environment and climate and climate
Environment
Education Education
2006-2016 Education Education Education Education
Distributions of un-earmarked Distributions of un-earmarked
donations 2006–2017 18%
donations 2017
2% 2% All of the charitable donations are distributed to organisations within the Swedish Postcode Association’s focus areas.
16% 13% All of the
All of the charitable charitable
donations aredonations aretodistributed
distributed to organisations
organisations within Postcode
within the Swedish the Swedish Postcode Association’s
Association’s focus areas. focus areas.
This also applies to the special projects and the projects that receive support via the Swedish Postcode Foundation.
27% 25% Thisto
This also applies also
theapplies
specialtoprojects
the special projects
and the andthat
projects the projects that receive
receive support support
via the via Postcode
Swedish the Swedish Postcode Foundation.
Foundation.
17%
9% 13% 65%
23% 23% 26%
Un-earmarked21%donations
Special projects
Children’s rights Children’sFoundation
The Swedish Postcode rights
Vulnerable peoble Vulnerable peoble
Health and research Health and research
Cooperation across borders Cooperation across borders
22 Environment and climate Environment and climate 23
Distributions of un-earmarked Distributions of un-earmarked
Education
donations 2006–2017 donations 2017 Education6 Good Operations in 2017 6 Good Operations in 2017
Project support via foundations Local community engagement Transparency process in place to allow for annual monitoring
With the charitable donations generated in 2017, The beneficiaries run projects both in Sweden Openness and transparency are key issues for and evaluation. The monitoring is based on,
the Swedish Postcode Foundation will provide and internationally. The Swedish Postcode Foun- Novamedia Sverige. Transparency is of particular among other things, the effect reporting develo-
support to projects working in the areas of dation also supports projects that benefit both importance in regards to the charitable dona- ped and used by the Swedish Fundraising Coun-
nature, the environment, culture, sport and the local and global community. In 2017, 47% of tions generated by the lottery and how it is dist- cil (Frivilligorganisationernas Insamlingsråd or
people’s living conditions. The task of the foun- the funds granted by the foundation was granted ributed by the Swedish Postcode Association. FRII). In addition, there is an ongoing close dia-
dation is to channel support to organisations and to projects that benefit the local, i.e. the Swedish, The distribution of the donations is reported in logue with the beneficiaries, with the aim to
projects that are active both in Sweden and community. As part of increasing the employees’ the Swedish Postcode Association’s annual report maximise the positive impact of the charitable
abroad. The Swedish Gambling Authority reviews community engagement, Novamedia Sverige and at postkodlotteriet.se. donations. The monitoring and evaluation is
and approves each of these projects. The Cultural decided in 2015 that all employees should have managed by Novamedia Sverige.
Foundation and the Sports Foundation will con- opportunity to carry out voluntary work during In 2015, a new distribution model was introdu-
tinue to be members of the Swedish Postcode working hours for two working days per year. In ced, since the Swedish Gambling Authority was In order for an organisation to be considered as a
Association and will remain active until their 2017, 15% of all employees took advantage of of the opinion that the earlier model was not potential beneficiary, it must meet a number of
existing funds have been distributed and final this benefit and engaged in volunteer work. sufficiently transparent and predictable. The new criteria. These criteria include, but are not
reporting to the Swedish Gambling Authority for model is based on each beneficiary’s own ability limited to, that the organisation must be a
all the projects has taken place. to finance its operations. The purpose of the new non-profit organisation or foundation, have
model is to reduce subjectivity and increase pre- fundraising activities in Sweden and contribute
Special projects dictability in the distribution process, allowing to the public good. An organisation will be
In addition to the un-earmarked funds passed on the beneficiaries greater opportunity for forward examined by a number of bodies before possibly
to the Swedish Postcode Lottery’s beneficiaries, planning of their activities. However, the final being approved. The decision of new mem-
the beneficiaries can obtain financial support for distribution depends on the amount of funds berships is taken by the board of the Swedish
specific projects from a number of special project generated by the lottery as well as the total num- Postcode Association. The organisation must
funds. The aim of the special project funds is to ber of beneficiaries. The model was applied for also be approved as a beneficiary by the Swedish
inspire the beneficiaries to develop and contri- the first time in 2016 for the 2015 donations. Gambling Authority.
bute new knowledge on relevant issues. Two The Swedish Gambling Authority carried out a
calls for proposals of a total amount of SEK 160 follow-up of the distribution model in 2016 and
million were announced via special project funds concluded that it is now both predictable and
in 2017. The first fund focuses on the following more transparent.
Sustainable Development Goals – 10 (reduced
inequalities), 13 (climate action) and 14 (life Monitoring and evaluation of
below water). The other fund focuses on the fol- beneficiaries
lowing Sustainable Development Goals – 5 (gen- As part of the operator mandate, Novamedia
der equality), 12 (responsible consumption and Sverige conducts monitoring of the beneficiaries
production) and 15 (life on land). to ensure compliance with all applicable laws
and regulations as well as the statutes of the
Swedish Postcode Association, and hence, are
eligible to be granted funds. There is a formal
24 256 Good Operations in 2017 6 Good Operations in 2017
RESPONSIBLE GAMING in the regulated Swedish gambling market. problems in order to reduce the risks of gaming for the company to continue to push the agenda
problems arising, and communicate the fact that of high consumer protection forward. In 2017,
Responsible gaming | Responsible and SPER works for a responsible gambling industry gaming problems are a public health issue. OSS there were two incidents of non-compliance with
ethical marketing with a high level of consumer protection. Nova- provides a good platform for dialogue and for sha- voluntary codes concerning marketing communi-
media Sverige’s Managing Director Anders ring knowledge with other organisations that, cations, compared to zero in 2016.
The lottery and games that Novamedia Sverige Årbrandt was a board member of the Ethics along with Novamedia Sverige, are working to
develops and operates must be entertaining and Council of the Swedish Gaming Industry and was ensure a high level of consumer protection. Responsible gaming measures
fun, as well as offering chances of winnings. elected deputy chairman of the Swedish Gambling A large part of Novamedia Sverige’s responsible
However, gaming is associated with a risk. About Association in conjunction with its reformation. Responsible and ethical marketing gaming efforts are preventive efforts aimed at
two percent of the adult population in Sweden Responsible gaming efforts are central to the players. Responsible gaming measures include:
suffer from gambling problems. Novamedia Sve- As a member, Novamedia Sverige undertakes to company’s operations. One particularly impor- • A strict minimum age of 18 years.
rige takes its role as a gaming operator seriously. abide by the organisation’s guidelines on marke- tant area is marketing. Novamedia Sverige strives • Maximum stakes of SEK 3,400 per month
Therefore, it carries on active work in the area of ting and sales of games, and to make responsible to only produce marketing that is responsible (20 subscription tickets).
responsible gaming, focusing on preventive gaming an integral part of its daily operations. and ethical, with the starting point that all legal • A limit of SEK 10,000 per gaming account/
efforts, in order to minimise the negative conse- The membership also provides an opportunity requirements as well as SPER’s guidelines on month on funds placed in accounts for online
quences of gaming. for Novamedia Sverige to reqularly evaluate its marketing must be complied with. Training of gaming. Players are only allowed to have one
responsible gaming efforts, as this is one of the both personnel and partners involved in marke- gaming account.
The initiatives related to responsible gaming is requirements of a membership. ting and sales is one example of how the com- • The website postkodlotteriet.se offers tools for
based primarily on the ambition that no indivi- pany works to ensure that all the rules and ethi- restricting deposits, losses and gaming time per
dual shall be adversely affected. However, the Participation in the Independent cal guidelines are followed. Novamedia Sverige month.
legislation also makes requirements concerning Gaming Collaboration safeguards lottery players’ privacy and does not • Free and anonymous self-testing at
work on responsible gaming. Working actively Since 2015, Novamedia Sverige has been part of contact people who have opted out of communi- postkodlotteriet.se, that provides an opportu-
and seriously with responsible gaming is there- the Independent Gaming Collaboration (Obero- cation via Nix, a national barring system, or have nity to gain knowledge about one’s own
fore also a compliance issue, i.e. a prerequisite ende Spelsamverkan or OSS), a voluntary inde- registered with the company’s own barring gaming habits.
for the association’s lottery permits and subsequ- pendent collaboration between operators in the system. • Information about the helpline – Stödlinjen-
ently Novamedia Sverige’s operating mandate. regulated Swedish gaming market, relevant can be found on the website and in marketing
authorities such as the Public Health Agency of Novamedia Sverige encourages examination of its communications. The helpline is a national
Membership of SPER Sweden (Folkhälsomyndigheten) and the marketing. There are a number of bodies, inclu- support facility financed by the Public Health
Novamedia Sverige has been a member of SPER Swedish Gambling Authority, as well as volun- ding the Patent and Market Court (Patent- och Agency of Sweden with the task of providing
since 2014. In December 2016, the board of tary organisations that provide support to Marknadsdomstolen), the Swedish Consumer advice and support to individuals with gaming
SPER decided that the organization should be gaming-addicted people and their relatives. Agency (Konsumentverket) and the National problems and their relatives.
reshaped from the Ethics Council of the Swedish Board for Consumer Disputes (Allmänna Rekla-
Gambling Industry into a trade organisation for The shared ambition of the stakeholders in OSS is mationsnämnden) to which lottery players or the In 2015, Novamedia Sverige developed a digital
the gambling industry. The reformation was the aim that gaming for money and lotteries public can turn to report the lottery’s marketing. training concept, as part of the ambition to edu-
completed in April of 2017, and the organisation should be developed in a healthy and responsible In fact, during the year the company decided to cate the staff and relevant partners that have
became the Swedish Gambling Association or way, with a focus on responsible gaming and report two of its own marketing activities to contact with lottery players on gaming problems
SPER (Spelbranschens Riksorganisation). The social protection aspects. The participants in OSS SEEM, in an effort to create clarity in the inter- and responsible gaming. The aim is for all
members of SPER currently consist of operators all carry out preventive work on gaming-related pretation of SPER’s guidelines. This is one way employees to have completed the training as
26 276 Good Operations in 2017 6 Good Operations in 2017
soon as they are employed and thereafter once BUSINESS ETHICS and ethical guidelines and principles. conjunction with the drawing up of contracts.
every second year. The company has been subject to an investiga-
Regulatory compliance | Competitive practices To ensure regulatory compliance, the company tion by the Swedish Competition Authority
At the end of 2017, 98% of employees had com- has a number of policies and systems in place to regarding potential misuse of a dominant posi-
pleted the training, (including those that started Compliance with laws and regulations is a prere- minimise the risk of infringements. Starting from tion. In November 2017, the Swedish Competi-
their employment at the very end of 2017), up quisite for any business that wants to be sustai- the General Terms and Conditions of the tion Authority decided to close the case.
from 84% in 2016. nable in the long run. Running a business in a Swedish Postcode Lottery and the company’s
responsible and ethical way, in close dialogue policy on data security, among others, a large In 2017, as in the previous year, the company
Novamedia Sverige develops new bingo products with stakeholders, is of highest priority to Nova- number of checkpoints are examined both inter- met its objective of zero tolerance; in other
and scratch cards every year. During the product media Sverige and is essential to deliver on the nally and by external parties. The checks are in words, no legal actions or sanctions were
development process the tool Gamgard is used mandate from the Swedish Postcode Association. place to ensure the lottery player’s route through brought against Novamedia Sverige during the
to identify the risk components in the game. If Novamedia Sverige fails to run the operations the lottery and to guarantee correct processing, year in respect to the failure of complying with
This tool, which is used by many other operators of the lottery in accordance with regulations and from customer registration to payout of lottery laws and regulations or in regards to anti-compe-
in the gaming industry both in Sweden and ethical guidelines, there is a risk that the prizes. The checks are also designed to ensure titive practices.
internationally, makes it possible to identify how Swedish Postcode Association will get reprehen- correct authorisation and access to data and pre-
risky a game is. This is an important part of ded by The Swedish Gambling Authority. The mises. As an operator company, Novamedia Sve-
Novamedia Sverige’s responsible gaming efforts, authority has the power to withdraw a lottery rige works actively to report and follow up inci-
since the company aim is to not offer any high- permit if it finds the operator to be dents, in order to discover shortcomings and
risk games. non-compliant. improve the company’s processes. Novamedia
Sverige’s policy on risk management involves
Although Novamedia Sverige has taken a num- The Swedish gaming market is a strictly regula- increased focus on the work of following up and
ber of responsible gaming measures in recent ted market that is under the supervision of the improving processes, and systematically building
years, the work continues. The gambling regula- Swedish Gambling Authority. The Swedish Gam- in relevant checkpoints relating to regulatory
tion that is expected to enter into force 1 January bling Authority is led by a board appointed by compliance.
2019 will raise the bar in the responsible gaming the government and ensures that the Swedish
area. Novamedia Sverige will take additional gaming market is lawful, safe and reliable. Novamedia Sverige has an anti-corruption policy
measures in the forthcoming year to be fully that describes the company’s guidelines in
compliant. In 2014, Novamedia Sverige became a member regards to accepting gifts from external parties.
of SPER. SPER works to increase knowledge Additionally, the company has an authorization
concerning ethical issues related to gaming. schedule in place to minimize the risk of corrup-
Novamedia Sverige has also chosen to become a tion by ensuring that the signing of contracts
member of the Swedish Direct Marketing Associ- and approval of invoices involve several check
ation (SWEDMA) and of Kontakta, memberships points at different levels in the organisation.
that entail that the company has signed up to
certain ethical rules relating to marketing and Issues concerning competition and any
sales. New marketing and sales campaigns are anti-competitive practices are important to
examined by Novamedia Sverige’s corporate Novamedia Sverige. These issues are dealt with
lawyers to ensure that they comply with laws on an ongoing basis as they arise, e.g. in
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