Business Ethics

Overview & Highlights
Compliant Business
How we govern
Memberships in associations
Our stakeholder engagement
Value chains

Overview & Highlights

An ethical business culture is a key aspect of our commitment to making a positive social impact. Our Code of Conduct and associated policies clearly set out the values and standards we expect from each other. We also take the extra step of enhancing the understanding and knowledge of our employees by training them on core policies such as the Code of Conduct, Anti-Bribery and Corruption Policy, Data and Asset Protection and Competition. We have appropriate mechanisms to address any instance when we fall short, which strengthens our governance and encourages a culture of transparency and accountability. We respect the rights of every individual to data privacy, and by 25th of May 2018, we were GDPR ready on a high level. Throughout 2018 we have continued with the implementation of work streams to continuously improve. We also partner with associations that aim to make a positive difference in the areas of professional integrity, anti-piracy and fraud.

Compliant Business

At MTG we promote a culture of openness, responsibility and accountability. We want to conduct business in full compliance with laws, regulations, international initiatives and standards.

Code of Conduct

Our Code of Conduct is built on our values; striving to inspire and ignite, exploring opportunities, enhancing lives and shaping the future. More importantly, the code is a guide for all our employees on how we do (and don’t do) business. It helps us navigate the ethical and legal situations we face daily. Our code describes our responsibilities towards customers, business partners, shareholders and each other. It also sets out our position on topics such as fair working conditions, asset protection, anti-corruption practices, conflicts of interest, competition, data privacy and much more.

As a responsible global business, we are committed to international initiatives and standards such as the OECD Guidelines for Multinational Enterprises, the UN Global Compact, the Fundamental Conventions of the International Labour Organisation, the UN Universal Declaration of Human Rights, and the UN Guiding Principles on Business and Human Rights. We review our policy framework annually and if significant changes are made we need approval from the Board.

Training and courses

To ensure that all our employees understand and adhere to our values and commitment, we ask them to sign our Code of Conduct when starting their employment with MTG. During 2018, 82% of new employees signed. In 2018, we launched and rolled out four e-learning courses for all fixed employees covering our Code of Conduct, Data & Asset Protection, Competition and Anti-Bribery & Corruption. Our overall completion rate for all four courses by the end of 2018 was 89%. The aim of the courses is to familiarise our employees with the content of our steering document framework by providing practical examples and questions. Both the e-learning courses and the steering documents clearly state whom to reach out to with questions and concerns.

During autumn 2018, the Legal and Compliance team initiated face-to-face compliance training with our local management teams, deep diving into topics such as anti-bribery and corruption, conflicts of interest, competition and data protection amongst others. The next step in 2019 is to provide the same training to middle management and do more targeted and tailored face-to-face training.

Whistleblower process

As we promote a culture of openness, responsibility and accountability, we want everyone to feel comfortable about raising concerns, including possible violations of our Code of Conduct, policies, applicable laws and regulations. It is important for all our employees to know that their concerns will be taken seriously and investigated properly without fear of retaliation and that their confidentiality will be respected. Therefore, we have established a Whistleblower process and encourage our employees to raise their concerns directly. Should an employee not feel comfortable to raise a concern with their line manager or manager’s manager, they can contact our Whistleblower officers or use our anonymous external option via Speak-Up Line.

Anti-bribery and corruption

At MTG we take anti-bribery and corruption seriously, which is why we have the Anti-Bribery and Corruption Policy as well as the e-learning course. 88% of our employees completed this course. During 2018 we had no confirmed incidents of corruption and no incidents that lead to employee dismissal or disciplinary action. No contracts with business partners had to be terminated or not renewed due to violations related to corruption, and no legal cases were brought against us or our employees.

Supplier Code of Conduct

We also want to develop and maintain strong business relationships with suppliers who are committed to ethical standards equivalent to our own. Our new Supplier Code of Conduct sets out the standards with which all companies providing products or services to MTG are expected to comply. It is important to note that failure to comply with the standards and provisions in the Supplier Code may result in MTG reviewing and potentially ending a co-operation with a supplier.


On the 25 May 2018, the General Data Protection Regulation (GDPR) came into force across the European Union. We were prepared and ready after having started the GDPR project in early 2017 to ensure compliance with the regulation. A core central team consisting of the Group Compliance Officer, Central Data Protection Officer, the Chief Security Information Officer (later replaced by the head of IT) and two GDPR Project Managers have worked closely with our appointed local Data Protection Managers and Human Resources to make sure data protection matters are handled correctly.

We have continued to follow our roadmap which includes activities such as updating privacy notices and data processing agreements, reviewing retention periods, handling data subject requests, establish data breach procedures, as well as producing policies/guidelines and different types of training and awareness activities. A data protection awareness video was launched for all employees as well as the Data & Asset Protection e-learning which has a 89% completion rate. During 2018 we have continued to use OneTrust to map personal data processed within the organisation and identify data flows and where data is stored.

We have established a clear framework that manages data incidents and breaches which will ensure that we report possible personal data breaches within 72 hours. All personal data breaches are documented centrally. Complying and working with GDPR has become part of our daily work as we have moved into a governance phase and processes are starting to fall into place. In 2019 we will continue to define our strategy to include GDPR into daily work, to keep GDPR relevant and prioritised.

How we govern

Modern Times Group MTG AB is a Swedish public limited liability company. The company’s governance is based on the Articles of Association, the Swedish Companies Act, the listing rules of Nasdaq OMX Stockholm, the Swedish Code of Corporate Governance, and other relevant Swedish and international laws and regulations.


Our valuable investors who can exercise their right to decide on issues affecting the company and its operations at the AGM.


The AGM is the highest decision-making body, at which the MTG shareholders vote on various resolutions, sign off the accounts, appoint MTG’s Board of Directors (the Board) and its Chairman, appoint MTG’s Auditors and may also make other proposals. Shareholders should submit proposals in writing at least seven weeks before the AGM.

Nomination Committee

The Nomination Committee evaluates the Board of Director’s work and composition, submits proposals to the AGM regarding the election of the Board, the Chairman of the Board and the Auditors, prepares proposals regarding fees paid out to the Board and the Auditors as well as proposals for the Chairman of the AGM. Additionally, the Committee prepares proposals for the administration and order of appointment of the Nomination Committee for the AGM.

External Auditors

The External Auditors examine the Annual Report and financial accounting, and the Board’s and CEO’s administration. They report their findings to the shareholders in an Auditor’s Report which is presented to the AGM. They also address detailed findings at each of the Audit Committee’s meetings and to the full Board as necessary.

Board of Directors

The Board comprises of six non-executive directors, all of which are independent of the Company and its management and are independent of the major shareholders. The Board has the overall responsibility for MTG’s organisation and administration and governs MTG’s Corporate Responsibility. The Remuneration Committee appointed by the Board is responsible for issues related to salaries, pension plans, bonus and remuneration programmes, the structure and levels of remuneration at MTG as well as providing advice on long-term incentive schemes and the Guidelines for remuneration applicable to the Chief Executive Officer and Executive Management.

Audit Committee

The Audit Committee appointed by the Board monitors MTG’s financial reporting, efficiency relating to internal control, internal audit and risk management, impartiality and independence of the auditor, assists the Nomination Committee in preparing for auditors’ election at the AGM and when applicable, monitors and secures the quality and fairness of transactions with related parties.


The Corporate Responsibility Advisory Group (CRAG) was established in 2013 to support the Board on corporate responsibility topics. The Group was formed to meet three times a year and consisted of two members of the Board. MTG’s President and CEO, one member of the Executive Management team, the Group General Counsel and the Head of Corporate Responsibility reported to, and were part of CRAG. The CRAG had overall responsibility for the Group’s corporate responsibility strategy, agenda and practices, including issues relating to human and labour rights, anti-corruption and environmental performance. The Group reported its findings to the Board. However, due to the recent structural changes at MTG and increased importance of corporate responsibility matters, it was decided in September 2018 that the CRAG be dissolved and corporate responsibility issues to be now considered by the full Board.

Executive Management

The Executive Management team is in charge of day-to-day implementation of the business strategy and corporate responsibility.

Global Corporate Responsibility Team

The Global Corporate Responsibility Team drives MTG’s corporate responsibility strategy. The team implements a cross-functional corporate responsibility agenda and processes, monitors and reports on progress, and communicates various activities.

Local Business

Local CEOs ensure that MTG’s corporate responsibility strategy is implemented and forms an integral part of our various businesses. We also collaborate with team members across the organisation to drive and execute corporate responsibility initiatives on a group and local level.

Strategic Association Memberships

As a global digital entertainer, MTG maintains memberships in industry associations, national and international organisations and additional bodies. Of these memberships, the following are considered strategic and/or significant to our business:


The Audiovisual Anti-Piracy Alliance (AAPA) is a European organisation addressing media piracy issues. The activities of the AAPA include information sharing between members and dialogue with EU institutions to promote effective anti-piracy legislation.


The Association of Bulgarian Broadcasters (ABBRO) is a non-governmental body representing TV and radio operators in Bulgaria.


The Association of Commercial Television in Europe (ACT) represents the interests of leading commercial broadcasters in 37 European countries. The ACT engages with EU institutions to achieve a balanced and appropriate regulatory framework that encourages investment and growth in the media sector.


The Commercial Broadcasters Association (COBA) is an industry body for UK-based multichannel broadcasters in the digital, cable and satellite television sector and their on-demand services.


The European Digital Radio Alliance (EDRA) is supported by the European Broadcasting Union and has the goal of making digital radio the standard and preferred choice of listeners across Europe.


The European Group of Television Advertising (egta) aims to support television and radio sales houses in monetising audio and audiovisual content through advertising solutions, regardless of device or platform.


MTG’s ESL is one of the founding members of the German esports federation called Esport Bund Deutschland (ESBD). ESBD is the central contact point for the sporty design of eSport and the interests of the athletes in the field, both for politics and administration as well as sports and umbrella organisations.


MTG’s ESL and DreamHack are both members of the Esports Integrity Coalition (ESIC), a non-profit association established in 2015 by esports stakeholders to deal with integrity issues, particularly match manipulation and betting fraud.


The Freewheel Council for Premium Video (FWC) is a global advocacy group representing businesses working with premium video content and advertising.


The German Games Industry Association (game) has a mission to make Germany the best games location. game is an expert partner for media, social and political institutions and addresses questions regarding market development, games culture and media literacy.


The Interactive Advertising Bureau (IAB) aims to ensure that Sweden becomes the leading country in online marketing in Europe. IAB works through specialised task forces that define various standards and guidelines.


The International Game Developers Association (IGDA) is a U.S. based non-profit professional association and a global network of collaborative projects and communities of individuals from all fields of game development. IGDA brings together developers to improve their lives and their craft.


Based in the US, the Media & Entertainment Services Alliance (MESA) aims to advance new technologies that enable the digital transformation of media and entertainment.


Nordic Entertainment Group is one of the owners of MMS. MMS measures, but also develops new methods for measuring consumption of moving images in Sweden. They monitor trends and publish reports and surveys.


The Motion Picture Association of America (MPAA) serves as the voice and advocate of the American motion picture, home video and television industries.


Nordic Content Protection (NCP) is a cross-industry Nordic body focused on addressing piracy through engagement and intelligence sharing with enforcement agencies.

Norsk Presseforbund

Norsk Presseforbund (NR), or the Norwegian Press Association, is a joint body for Norwegian mass media that aims to promote ethical standards and professional integrity and to strengthen and protect freedom of speech, media and information.


Reklamombudsmannen (RO), or the Swedish Advertising Ombudsman, is a self-regulatory organisation. RO handles complaints about advertising, assesses whether commercial advertising is following the Consolidated ICC Code, and provides information, guidance and training in the field of ethical marketing.

Responsible Media Forum

The Responsible Media Forum is a partnership between leading global media companies. The forum collaborates on sustainability issues, identifying and acting on social and environmental challenges facing the sector.


In 2016, MTG’s ESL helped found the World Esports Association (WESA). Based on similar traditional sports associations, WESA aims to further professionalise esports by introducing elements of player representation, standardised regulations and revenue shares for teams.


WorldDAB is a global industry forum aiming to facilitate the adoption and implementation of digital radio based on DAB/DAB+ standards.

Our stakeholder engagement

MTG’s stakeholders are selected through stakeholder mapping. We identify them through looking at MTG’s business and corporate responsibility strategy and evaluate their impact. The stakeholders include all the people and organisations that may be affected by our business and those that affect us as a company. Their input guides us in the right direction and they are vital to our success.

We engage with stakeholders as part of our everyday business and involve them in our corporate responsibility activities as well as goal-setting processes as part of our materiality assessment. This engagement aims to achieve shared goals of common interest.

During the split of MTG, Nordic Entertainment Group and MTG carried out new materiality assessments to set our priorities moving forward and maximise our positive impact across each of our markets. We will share the outcome of those in 2019.

Our stakeholders’ input in the materiality assessment of 2016 is the basis of our current corporate responsibility strategy and focus. We use our social media channels, intranet, web and in-person meetings to broaden the conversation around our ongoing corporate responsibility work and to strengthen our feedback pro­cesses even further.


B2C: video streaming and linear TV viewers, users of our digital video networks, radio listeners, esports participants and enthusiasts, game players and game developers; and B2B: media agencies and corporations.

Day-to-day engagement methods:

Free-TV: focus group research, ad hoc content research, surveys, social media, viewing figures and audience appreciation index.

Pay-TV: focus group research, customer support channels, surveys, dialogue programs, social media, newsletters and brochures.

Viaplay & Viafree: focus group research, surveys, campaigns, viewing panels, customer support channels and social media.

Radio: listener hotlines, competitions, web­sites, audience measurements, surveys, interviews, auditory tests, blogs and social media.

Esports: participants, enthusiasts, game players and game developers: events, interviews during events, surveys including post-event customer satisfaction surveys, blogs, forums, websites, social media, newsletters, customer support channels and meetings.

B2B: direct dialogue.

Key issues: Health, safety and security, transparent and credible dialogue and content quality.


Our investors

Day-to-day engagement methods: Annual General Meeting, Annual Report, Corporate Responsibility Report, quarterly reports, press releases, Environmental Social Governance (ESG) roadshows and conferences, Capital Markets Day.

Key issues: Responsible advertising, content quality and accessibility.

The Board

MTG’s Board of Directors.

Day-to-day engagement methods: Board of Directors meetings.

Key issues: Data protection and privacy, equality and diversity, effective anti-corruption management.


Our team members.

Day-to-day engagement methods:

Annual employee survey, intranet, posters, newsletters, policies and guidelines, e-learning, whistle-blower procedures, personal development reviews, training, programs, workshops, one-on-one meetings, daily dialogues, statistic engagement tools and onboarding and offboarding processes.

Key issues: Content quality and accessibility, transparent and credible dialogue, data protection and privacy, valuing creativity, work-life balance, skills management, diversity and equality.


The companies whose products and services we buy.

Day-to-day engagement methods: Daily or weekly phone calls, Skype and face-to-face meetings, including continuous dialogue on diversity, Supplier Code of Conduct, site visits, communication regarding set-up routines on GDPR and Supplier Code of Conduct compliance as well as consumer regulatory standards.

Key issues: Compliance with our requirements.


The non-governmental organizations with which we work.

Day-to-day engagement methods: Continuous dialogue (locally and centrally).

Key issues: Equality and diversity, health, safety and security, community engagement.


Ofcom and other authorities that set the rules for what we do.

Day-to-day engagement methods: Continuous dialogue with the broadcast compliance and legal teams.

Key issues: Product safety and compliance (regulatory and legal), child and minor protection, responsible advertising, content accessibility and impact awareness.


Our peers and colleagues.

Day-to-day engagement methods: Quarterly industry peer meetings through the Responsible Media Forum and continuous dialogue with colleagues and other professionals.

Key issues: Data protection and privacy, human rights and environmental impacts, United Nations Sustainable Development Goals (SDGs).

Trade Associations

Memberships in associations through which we discuss issues relevant to the media and audiovisual sectors, including legislative proposals at EU and national level, as well as issues relevant to the esports sector such as professionalism and integrity.

Day-to-day engagement methods: Face-to-face meetings, Task Force calls, association events with key stakeholders including political institutions and regulators, conferences, webinars, monthly board meetings, weekly email discussions, long-term projects, joining advocacy efforts through conducting interviews, quarterly meetings and commission work at the esport division of game.

Key issues: Digital Single Market initiatives including the revised Audiovisual Media Services Directive, Copyright Directive, Broadcaster’s Regulation, ePrivacy Directive, platform regulation, fake news, child and minors’ protection and advertising.

Value chains

As a global digital entertainer, we offer a wide range of products and services for multiple markets across a broad range of distribution channels. Even though we are many brands, we are one organisation. That means we follow the same processes and work towards the same goal: to create value for our customers, partners, employees and shareholders, as well as for society.

To illustrate and explain the development of our transformation we have divided our business into three value chains: digital entertainment (that includes free-TV, pay-TV and digital video content), esports (DreamHack and ESL) and online gaming (InnoGames and Kongregate).

Buying, licensing and acquisition

We work with many types of suppliers to ensure we have what we need to run our business. Core suppliers include major Hollywood studios (media rights acquisitions and content licensing) and sports rights providers (sports rights licensing), as well as local studios and channels we acquire content from. Set-top-box hardware producers are also included in this category. Our online gaming companies, Kongregate and InnoGames, acquire game IPs from game developers. Non-core suppliers include office equipment and IT vendors.

Creating and developing

Before content or games can be published or distributed, many departments and teams need to be involved. Some play a direct role, while others facilitate. In the process of digital entertainment, this covers everything from content and software development, production and scheduling to compliance, marketing and broadcasting. We also produce content for other broadcasters. In online gaming, the process follows the steps of development, production, soft launch and testing, launch, marketing and further development and production. The life cycle of a game is prolonged through features updates and in-game events (known as live-ops). Our esports companies produce the content at our ESL and DreamHack tournaments and events.


We make our content available to customers via multiple linear and subscription channels and streaming services in the Nordic region and Bulgaria, as well as on radio networks in some of the Nordic countries and Bulgaria. Our subscription streaming service Viaplay and a free on-demand platform Viafree (both available via browser or app) offer original and licensed content through smart TVs, mobile apps and additional access points. Esports enthusiasts can watch our own esports channel, available upon subscription in multiple territories. Our events and LAN festivals are streamed on third-party platforms, as our esports companies own the distribution rights to the original esports content that they license to networks and digital services in multiple languages. Our games are free-to-play, which means that they are available to play free of charge in the browser and via mobile apps with optional in-game purchases. In-game purchases are not vital to advance and succeed in a game.

Brand partnership and advertising

We supply advertising space to media buyers, businesses and charities. We sell advertising space on our owned and operated channels and platforms to media buyers and businesses as well as supplying charities when possible. At esports events and festivals, we supply advertising space and opportunities to brand partners and advertisers. There are a variety of possibilities to promote products at different stages of the value chain.

Event production

Our esports companies, ESL and DreamHack, produce and host leagues, tournaments and LAN festivals that attract pro gamers and esports enthusiasts.


We have an ongoing dialogue with all our stakeholders to improve our products and services. This dialogue includes focus groups, surveys and interviews, and ensures we give our audiences exactly what they want, while offering our business customers opportunities to strengthen their brands. This input is channeled back to our content creation (development and production), marketing, purchasing and events teams to ensure we continue to offer inclusive, accessible and responsible content, games, events and festivals.