Corporate Social andEnvironmental Responsibility
2022 reportMessage fromthe Chairman
and Chief
Executive Officer
DENIS
LADEGAILLERIE

In 2022, Believe, which is now one of the largest global
players in digital music, continued its development andreached new heights. Having made a significant
contribution to reshaping the music industry throughan innovative business model and strong values ofexpertise, respect, fairness and transparency, theGroup is continuing its ascent by positioning itself as a
key player for artists and labels.
Every day, the music market is becoming more digital.
Every day, our digital excellence, our differentiatedpositioning and our combination of technological andmusical expertise are becoming increasingly strong
competitive advantages and better understood byartists and labels, particularly in music genres that arebecoming digitalized. In this way, we are contributing
to the success of a wide variety of local artists in the 50
countries in which the Group operates, at all stages of
their careers.
We continued to apply our profitable growth strategy
throughout the year, as we work on building the Groupfor the coming decades. We continued to invest in our
local teams to strengthen our capabilities in key
markets and seize the increasing numbers ofopportunities offered by the growth of digital music.
We continued to invest in innovation to expand ourrange of innovative audience development andmonetization products and services and thus further
increase our impact.

1

Extract from Universal registration document 2022 - Believewww.believe.com

Message from the Chairman and Chief Executive Officer“We are convinced that the music market is currently experiencing
a paradigm shift and that it has entered the decade of the digitalartist. An era that we believe will be shaped by the ability to create
more value for artists by helping them to reach new audiences
in a targeted way or to engage with their fans.”

These profitable investments have guaranteed strong
growth over recent years, and have resulted in strong
revenue and adjusted EBITDA growth in 2022.
Throughout the year, we demonstrated that we are incontrol of our investment cycle and our profitability.
Finally, we generated sustained positive free cash flow,
thus increasing our capacity to carry out our external
growth strategy. For the second year in a row, weended the year by significantly exceeding thecommitments made during the IPO, both operationallyand financially.
Beyond its commitments, Believe also aims to change
the music industry and engage it in collaborative,
sustainable and responsible practices. The Group
continued to roll out its corporate social responsibility(CSR) strategy – Shaping Music for Good – which is at
the heart of its business model and illustrates thesocial, societal and environmental ambitions shared by
all Believe teams. Our initiatives in favor of a moregender-balanced industry have produced tangible
results for both our artists and our employees. As
such, we are engaging the industry in international
initiatives in favor of diversity, fairness and inclusion
such as the “Be the Change” study. At Believe, we
continue to make progress in terms of gender equality,with women representing 43% of our headcount in
2022, after achieving gender parity on our Board andExecutive Committee. We also continued our efforts to
involve our teams more closely in the creation of value
related to the Group’s development, notably with thelaunch of our first employee shareholding plan

We are convinced that the music market is currently
experiencing a paradigm shift and that it has entered
the decade of the digital artist. An era that we believe
will be shaped by the ability to create more value forartists by helping them to reach new audiences in atargeted way or to engage with their fans. 2023 will see
Believe enter this new era stronger than ever, and justlike the previous decade, we want to play our part insupporting the industry through this phase.
Together with our artists and employees, our twohearts that beat in unison, we wish to continue totransform the digital music sector. Their talents andskills are the drivers and sources of inspiration for acreative and responsible music industry.

Denis Ladegaillerie
Founder, Chairman and Chief Executive Officer

Extract from Universal registration document 2022 - Believe2

2022 KeyfiguresFranceGermany

€129m

€114m

REVENUESREVENUES

16.9%

14.9%

643

254

1

1

OF GROUP REVENUEEMPLOYEESCOUNTRY

OF GROUP REVENUEEMPLOYEESCOUNTRY

Europe(excluding France and Germany),
including Russia and Turkey€210m
REVENUES

27.6%

OF GROUP REVENUE

237

EMPLOYEES

13

COUNTRIES

Americas€109m
REVENUES

14.3%

OF GROUP REVENUE

177

Asia/Pacific/
AfricaEMPLOYEES

8

€199m

COUNTRIESREVENUES

26.2%

OF GROUP REVENUEA TECHNOLOGYCENTRAL PLATFORM
IN FRANCE,A FOOTPRINT
IN

50

3

342

EMPLOYEES27

COUNTRIESCOUNTRIESExtract from Universal registration document 2022 - Believewww.believe.com

Key figures

1.1Md

€

DIGITAL MUSIC SALES

€

761m

REVENUES

94%
PREMIUM
SOLUTIONS

6%AUTOMATEDSOLUTIONS

+

31.8%

REVENUE GROWTH+

32.2% 4.6%

ORGANIC GROWTH

1.3 million

ADJUSTED EBITDA
MARGIN+150

DIGITAL SERVICE PROVIDERSARTISTS DIRECTLY OR TROUGH THEIR LABEL

1,060

1,650

PREMIUM AND AUTOMATED
SOLUTIONS

590

EMPLOYEESCENTRAL PLATFORM

43% 57% 9%

WOMEN

MEN

AMBASSADORS91%

TRAINING RATE** Employees who attended at least one training course during the year.

Extract from Universal registration document 2022 - Believe

4

A CSR Committee within
the Board of Directors

CSR objectives integrated
into the variable
compensationof management teams

Engaging
committed employees

9%of People & Planet ambassadors,
volunteers to support Shaping Musicfor Good called Shapers

1,200

participants inour solidarity program organized in

32

countries

Training and developing
our expertise91%

of our employees trained
Leadership andmanagement program
Advanced training programs
and certiﬁcations in digitalmarketing and tech
Cutting-edge digitalmarketing training

Promoting
Gender Parity

50%

Deploying
good compliance practices
Diversity & Inclusion Charter
Ethics, anti-corruption, conﬂict ofinterest and cybersecurity training
Independentwhistleblowing platform
ESG performance assessed by
the ﬁnancial community
MSCI: AAGaïa Ethiﬁnance: Bronze

Supporting
our teams

97%

of Believers have at least one career
review per year

78%

participation in the internalYour Voice survey
Wellness and mental health programs

Supporting
initiatives

women on the
Executive Committee

Supporting initiatives and organizations
in favor of gender parity KeyChange,
Women In Music, 50'Intech...

of employees are womenParticipation in Spotify’s Equal program
which supports female artists

43%
99/100Gender Equality
Index in France(2nd consecutive year)

Fostering
Diversity & Inclusion

Sharing
the value created
40% of eligible Believers
have subscribed to the shareownership plan b.shares
Fair and transparent
compensation contract
and model for our artists& labels

Supporting
our artists & labels
Local teams anddigital music experts
serve them in morethan 50 countries
Training and masterclasses
to increase their audienceand monetize their content

Developing
local female artists"Songwriting camp"
to support female composers
and songwriters (Italy)
Partner of theRappeuses en Liberté*
program (France)*Female rappers on the loose

Engaging
the music industry

Supporting Musical Heritageand Local Communities

Believe leads the Be The Change
study on discrimination faced
by women and under-represented
communities

BEAMS Projects

Supporting
initiatives for the planet

Implementing
eco-responsible practices

training
for all
Be Fair DEI

98%

of Believers say they can bethemselves at work*95%

of Believers say there is
acceptance of people from diﬀerent
backgrounds and origins at Believe*to educate young aspiring
artists from disadvantaged
backgrounds (India)*Your Voice Internal Survey

Measuring and taking action
to reduce our carbon impact

708 tCO eq

Music Declares Emergency (MDE).

2for our direct activities (scopes 1&2)

80%of electricity consumed coming fromrenewable energies

63,000 km

travelled by 400 employees for a sports
challenge in favor of the planet70%

of our oﬃce buildings applying"eco-gestures" (selective sorting andrecycling, renewable energies, soft
mobility, etc.)

2022 data

Engaging
Leaders

Corporate
SocialResponsibility
Chapter 2 - Extract from Universal registration document 2022

2.1

Shaping Music for Good:a strategy alignedwith Believe’s values

7

2.1.1 Shaping Music for Good, a CSR strategy
at the heart of Believe’s business model
2.1.2 Believe’s values
2.1.3 A structured CSR organization

7
9
10

2.2

Analysis of the risks andopportunities related toGovernance, Social andEnvironmental issues

12

2.2.1 Nurturing the Shaping Music for Goodapproach through dialogue withstakeholders

122.2.2 Policies and actions to address ESG
challenges: risk and opportunities matrix

16

2.3

An ethics and deontologicalsystem as close as possible toemployees, artists and labels

2.3.1 Organizing the governance of ethical issues
2.3.2 Deploying policies and tools to apply ethics
and compliance standards
2.3.3 Setting up and publicizing thewhistleblowing system

2.4

Employees at the heartof Believe’s business modeland Shaping Music for Good

2.4.1 A structured human resources
organization to support
the Group’s growth
2.4.2 Believe employees in key figures
2.4.3 Attracting, recruiting and integrating
employees
2.4.4 Retaining and supporting employees
in their careers
2.4.5 Creating a diverse, inclusive and fairworking environment

22
22
22
23

2.4.6 Developing efficient working conditions,well-being and mental health2.4.7 Deploying a fair compensation systemand sharing value creation with employees
2.4.8 Ensuring continuous dialogue with theteams and measuring the levelof commitment and satisfaction

2.5

A committed player serving
artists and labels, and local
communities

2.5.1 Nurturing relationships of trust andsupporting creativity with our artists
and labels, and our stakeholders
2.5.2 Leading change in the music industry
and developing a culture of engagementwith local communities

2.6

33
36

36

37
37

41

Actions on the ground in favor
45of the environment

2.6.1 Formalizing the environmental approach
2.6.2 Supporting the engagement of employees
and the music and digital industry to theenvironment
2.6.3 Participating in the music industry’s
mobilization around the climate
emergency

45

55

55

2.7

Methodological note andsummary of indicators

56

24
25

2.7.1
2.7.2
2.7.3
2.7.4
2.7.5

Non-financial risk analysis methodology
Scope of the risks covered
Reporting period and frequency
Reporting scope
Non-financial indicators

56
56
57
57
57

26

2.8

Report by one of the Statutory
Auditor, appointed as
independent third party,on the consolidated
65
non-financial statement

24

28
30

Extract from Universal registration document 2022 - Believe

6

2

Corporate social responsibility
Shaping Music for Good: a strategy aligned with Believe’s values

For this second publication of its Non-Financial
Performance Statement (NFPS), Believe has brought
together in Chapter 2 of its Universal registration
document, the relevant information with regard to theGroup’s main non-financial risks, their management andtheir control, as required by the regulatory framework of
the NFPS.
In addition to Believe’s business model and values
published in Chapter 1 of the URD, Believe publishes inthis Chapter 2 (NFPS), useful social, societal andenvironmental information that is important tounderstand its CSR approach, Shaping Music for Good. This
NFPS presents the initiatives already launched and theimprovement focuses to be carried out in the short andmedium term.

Stakeholder expectations and a summary table of nonfinancial issues and risks with regard to policies arepresented in Section 2.
Commitments to employees, addressing the material risks
and opportunities identified, policies, actions andindicators are presented in Section 4.
The commitments to the society, and in particular to theartists and labels, are set out in Section 5.
Section 6 details the environmental initiatives.
Finally, Section 7 describes the methodology andindicators (key and additional indicators) monitored under
this NFPS and the Shaping Music for Good program.

Sections 1 and 3 describe the governance of corporate
responsibility, the materiality analysis and the ethics
system.

2.1 Shaping Music for Good: a strategy alignedwith Believe’s values
The concept of social responsibility is embedded inBelieve’s history and its primary purpose. Since its
creation in 2005, the Group has positioned itself with local
artists and labels in an inclusive way: giving all the means

to access streaming and social media platforms, and tomonetize their creations. Whatever the stage of theircareer, its innovative technological platform allows themto access the power of the digital market.

2.1.1 Shaping Music for Good, a CSR strategy
at the heart of Believe’s business model
The early 2000s marked a major turning point in thehistory of the music industry with the arrival of theInternet, digital tools and social networks.
Very early on, Believe anticipated and prepared for the
rapid evolution of digital uses (streaming, social networks,etc.), from music production to distribution andconsumption. These new practices and tools haveprofoundly changed the role and expectations of thevarious players in the music industry, in particular with:●

the increased number of new digital tools to support
musical creation, enabling artists to produce
themselves;●●a shift in the distribution of market value towards the
middle class of artists, whose promotion anddevelopment are favored by streaming services;
new expectations of artists, wishing to better control
their rights, rebalance value sharing in a moretransparent way and be independent from the record
companies and their partners.

In this highly evolving context, traditional record
companies no longer entirely meet the expectations ofartists. Believe provides an alternative which enables
artists and labels to drive their careers forward more
independently, faster and with enhanced agility, while
respecting their creativity and enhancing their digitalpromotion.

Chapter 2 of this Universal registration document provides a complete and transparent description of Believe’sbusiness model and its contribution to the creation of value, in the short and medium term, for the benefit of all its
stakeholders.

7

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Shaping Music for Good: a strategy aligned with Believe’s values

Believe's mission is to best serve local artists and labels at each stage of their developmentin the digital ecosystem, with fairness, expertise, respect and transparency.

The 4 Shaping Musicfor Good pillars:

Developing diverse & local
talent in local markets

Cultivating talent
for the digital music era

1.3 million artists, directlyor via their labels

ArtistServices

Empowering our community tohave a long-term positive impact

Tailored go-to-market
and audience development
strategies

Labels & Artists
established and top

Building trusting relationships
based on respect, fairness andtransparency

Revenue sharing model
50% tech / 50% music
and digital experts

Labels & Artists
emerging or established

60 to 65% of recording
fees collected by Believe
via the DSPs paid
to artists and labels+150 digital partners

Label and Artists Solutions

Streaming platforms

Distribution, marketing and digital promotion
Revenue sharing model
70% tech / 30% music and digital experts

Technological distribution
platform for music creators

Resources
Human capital° +590 experts in the central platform° 1,200 music and digital experts° Training and monitoring° Compliance practices

Capital tech & innovation° Proprietary and scalable technological platforms (Backstage, TuneCore)° Data collection, processing and analysis capacity° Innovation in functionalities & services adapted to new digital practices° Cybersecurity and data protection

Operating capital° A central platform that develops all solutions and innovations(products, formalization and deployment strategies for oﬀers, etc.)° A local network deployed in 50 countries

Financial capital° Solidary founding shareholder° 303 million in net cash
° Equity° Partnerships with digital service providers (DSP)° Targeted acquisition policy to accelerate growth

On the basis of this historic commitment, in 2021, Believe
formalized a Corporate Social Responsibility (CSR) strategy– Shaping Music for Good – which is at the heart of its
business model and aligned with its values. True to its
ambition of shaping the future of music, Believe has
structured it's CSR program with the aim of having a
positive impact: directly through its activities, with players
in the digital music industry, and by reconciling financial
and non-financial performance.

ED
AT S
M N
TO TIOAU OLUSMusic creators andself-distributed artists

Tunecore

Preferred partner for the top 4

Social media
platforms

Majority ofroyalties paid
to creators

Creating shared value
Artists, labels & business partners° Training & expertise (Artist Resources, TuneCore Rewards
and Master Class solutions)° + 245 billion streams on the 9 main DSPs
° + 892 billion views on YouTube° +1 billion in DMS (Digital Music Sales)° Transparent and fair contracts and compensation° Customer NPS

Employees° 43% of women among employees° 50% women on the Executive Committee° 99/100 on the Professional Equality Index (France)° 90.6% of employees trained° 97% of career reviews completed° 79% response rate to the internal Your Voice survey

Local communities and the music industry° 8.9% of ambassadors° More than 1,000 participants in our solidarity month Believe Tomorrow° 708 TeqCO2 (scopes 1 & 2)
° “Be the Change” study on women and minorities in the music industryate
to the internal Your Voice survey

Financial community° 763.1 million in revenue° +32.7% organic growth° 40% subscription to the share ownership plan by eligible employees° Variable compensation for key executives aligned with CSR issues

Shaping Music for Good illustrates the social, societal andenvironmental ambition that Believe has as a Group andfor the digital music industry. This very committed andlong-term CSR strategy is integrated at the highest level of
the Company. It is based on four pillars described below.

Extract from Universal registration document 2022 - Believe8

2

Corporate social responsibility
Shaping Music for Good: a strategy aligned with Believe’s values

These four pillars illustrate the commitments made by
Believe to its employees, its artists and labels, and thecommunities in which the Group operates. They structure
the Group’s policies, action plans and initiatives in order tomeet the expectations of stakeholders and Believe’ssocial responsibility challenges.

“At Believe, we have two hearts: our employees and ourartists. Together, we are creating opportunities for mutual
development and transforming the music industry in apositive way”.
Denis Ladegaillerie,
Chairman and Chief Executive Officer of Believe

Believe’s CSR ambition: Shaping Music for Good and its four pillars

Shaping Music for Good
Developing diverseand local talent

Cultivating talent
for the digital music era

Support artists and labels
at every stage of their career
through local teams aroundthe world.

Help artists in their transition
to the digital world.

Focus on diversity, inclusionand gender equity, for artists
and employees alike.

Develop and train a newgeneration of experts
in the digital music market.

Building trusting
relationships throughrespect, fairness
and transparency

Empowering
our community to havea long-term positive
impactRespect artists' creative
independence and freedomof expression and protect theirdata and interests.

Making the most of technology
to sustainably develop talent.

Promote Believe’s values
within the Group andthroughout the music industry.
Share value creation with artists,labels and employees.

Deploy a networkof ambassadors within Believe
and by engaging employeeswith local communities.
Reduce the environmental
impact of Believe’s activities.

2.1.2 Believe’s values
Since its creation, Believe has made it its mission to
support local artists and labels at every stage of theircareer in the digital world. It is in this context that Believe
is deploying its CSR strategy, Shaping Music for Good, tomeet the challenges and expectations of its stakeholders,and aligned with its values.

Generating trust for artists and labels, Believe's four
values (Driving Forces) empower them while providingthem the autonomy they need. For employees, they arealso a source of efficiency, openness and proximity.

Believe’s values

Respect
Be respectful to all artists,
all labels, and all employees
at every stage of their careerand in all countries where
the Group operates.

9

Expertise

Fairness

Transparency

Be an expert in developing
the expertise of our teams,
guaranteeing the eﬀectivenessand excellence of the services
we provide to artists & labels.

Be fair in our relations withartists and employees to oﬀer
equal opportunities andfreedom of choice in termsof personal development.

Be transparent in our projects
and contracts, by sharing
the necessary information
with artists, labels, employees
and partners to enable everyone
to make informed decisions.

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Shaping Music for Good: a strategy aligned with Believe’s values

2.1.3 A structured CSR organization
Driven, from the creation of the Group, by the ambition todevelop the music industry and engage it in collaborative,
sustainable and responsible practices, Believe’s CSR
approach had a pivotal year in 2021 with the structuringof the Shaping Music for Good strategy. In 2022, Believe
continued to roll out actions in line with the approach's
priorities.

●●

2.1.3.1 From the CSR strategy tosteering Shaping Music for GoodIn 2021, Believe structured its CSR strategy around thefollowing actions:
●

●

●

●

●

●

strengthening of the governance model, with thecreation of a CSR Committee within the Board of
Directors and the formalization of a CSR Department
reporting directly to the Group Human Resources
Department;
extensive consultation with internal and external
stakeholders to better understand their expectations;structuring of the Shaping Music for Good ambition tomeet the Group's main focuses and priorities;
raising employee awareness of CSR fundamentals anddeveloping the network of internal ambassadors, as
relays for Shaping Music for Good;
creation and diffusion of the Diversity, Equity andInclusion Charter;
an initial measurement of the Group’s carbon footprint
assessment.

In 2022, on the proposal of the CSR Committee, the Boardof Directors confirmed Believe’s CSR priorities with regard
to the expectations expressed by the various stakeholders
and the Group’s main CSR priorities, namely:●●

expertise, with the investment in the recruitment oflocal teams and the development and training of
employees (2022 Target: 77% of employees attended
at least one training course during the year), in order tosupport the Group’s growth and ensure a high level of
employee expertise to serve artists and labels. A
special effort was also made to roll out standardized
human resources management processes throughout
the Group;
gender equity and parity within the Believe teams(2022 Target: 43% of women in the headcount), withthe continuation of the efforts made in all humanresources processes. Gender parity targets areincluded in the variable and long-term compensation
plan for Executive Committee members;●

diversity and inclusion within the music industry, withsupport for local artists and labels, in particular
women, and under-represented communities in themusic industry in order to support them. The objectiveis also to promote the development of diversified
musical production and to showcase local musical
heritage;
employee engagement with local communities, inparticular through the network of internalambassadors(1) (2022 Target: 8.5% of ambassadors
among employees), the Believe Tomorrow(2) solidarity
program and partnerships with civil society players;environmental topics with enhanced monitoring of
the direct carbon impact of Believe’s activities (scopes 1& 2) and the implementation of the first action plans to
reduce energy consumption.

2.1.3.2 CSR governance system
Driven by Believe's values, the CSR governance enables
ownership of the challenges and the involvement of all tobring the Shaping Music for Good approach to life at alllevels of the Company. Built on Believe's two essential
components – Artists and Labels, and Employees – thepillars of Shaping Music for Good are rolled out throughout
the Group. They support employee engagement andoverall performance.
The attachment of the CSR Department to the Group’s
Human Resources Department illustrates Believe’s desire
to include CSR as a structuring element of management
and motivation, involving employees directly. The CSR
Department ensures the operational deployment of theapproach, with the full attention of the Board of Directors.
Within the latter, the CSR Committee is chaired by the
independent director, Kathleen O'Riordan. The presenceof Denis Ladegaillerie on this Committee reflects theimportance given to social, environmental andgovernance issues in the definition of the strategy.
Chapter 4 “Corporate governance” presents the functioningof the Committee and the details of its work during the2022 fiscal year.
It should be noted that three CSR criteria (rate of women,ambassadors and training in the headcount) are includedin the annual and long-term variable compensation of themembers of the Executive Committee and managers of
the Group’s main subsidiaries.

(1) See Section 2.1.3.3 “A global network of committed ambassadors”, page 11.
(2) See Section 2.5.2.4 “Supporting employee engagement with local communities”, page 43.

Extract from Universal registration document 2022 - Believe10

2

Corporate social responsibility
Shaping Music for Good: a strategy aligned with Believe’s values

CSR governance for Shaping Music for Good

Board of Directors
CSR Committee

Executive Comitee° Validates CSR strategic orientations and objectives° Ensures alignment with the Group’s strategy and values° Oversees the deployment of the CSR strategy and theShaping Music for Good ambition° Advises on CSR strategic orientations° Identiﬁes and incorporates CSR issues and risks
within the Group strategy° Validates CSR reporting, the principles of CSR governance,
and the compensation models aligned with the CSR strategy

Sharing and engaging artists & labels, music industries and local communities

Practice & participate

Deploy & engage

Manage & lead

Guide & control

The diagram below details the role of each body in the steering, implementation and control of the Shaping Music for Goodapproach.

CSR Department
Within the Human Resources Department° Builds and manages the CSR strategy, objectives and roadmap in accordance with the Shaping Music for Good ambition° Sets up and deploys CSR processes, tools and training° Leads, coordinates and advises local HR networks and ambassadors, and functional, business and country departments° Consolidates, measures and monitors non-ﬁnancial performance, and publishes the CSR/NFPS report° Coordinates and guides the CSR partnership policy

Ambassador
networkLocal
and central HR

Central platform /Functions° Proposes and contributes
to initiatives in line with
CSR priorities° Raises awareness and promotes
the Shaping Music for GoodambitionsSharesbest practices°° Deploys the CSR roadmap
locally and in HR processes(social and environmental)° Leads the Ambassadors networkand local solidarity actions° Contributes to CSR reportingCountry / Business department° Deﬁnes and implements
the local roadmap° Reports on progress
Raisesspeciﬁc issues°

employees° Puts the Believe values (Respect, Fairness, Transparency, Expertise) and the Shaping Music for Good roadmap into practice° Participates in solidarity action° Monitors Compliance and Diversity & Fairness & Inclusion training and practices

2.1.3.3 A global network of committed
ambassadors
Believe ambassadors are volunteer employees who
propose and contribute to initiatives that have a positive
impact for teams and local communities, in line with thepriorities of Shaping Music for Good. The system operates
on a collaborative basis, in close coordination with
Executive Management, with the support of the Human
Resources and local management teams.
The ambassadors implement concrete actions in areas
such as the promotion of gender equality, diversity,
support for local communities and environmental
protection. The goal is to create and lead a community toshare best practices, disseminate and implement the CSR
strategy locally in line with the Shaping Music for Goodapproach. Examples of the ambassador network's
contributions can be found in Section 2.5.2.4 “Supporting
employee engagement with local communities”, page 84.
To this end, the ambassadors receive information on the
CSR strategy, objectives and resources allocated. They
meet regularly at local and regional level to share bestpractices and define and implement concrete actions on
the ground. The ambassadors also contribute to the
preparation of the NFPS by providing the data andtestimonies necessary for its realization.

Created in 2019, at the initiative of employees and withthe support of human resources, the ambassador
network has gradually been organized and structured into
different communities, addressing Believe’s priority
topics:●●Believe for People/Parity: on the topics of genderequality, diversity and inclusion, well-being at work,
mentoring and support for local communities;
Believe for Planet: on environmental issues.

The Group has set itself the target of increasing thenumber of employees involved in the ambassador
network. In 2022, it had nearly 140 ambassadors in 27
countries, i.e. nearly 8.9% of employees, thus exceeding
the initial target of 8.5% ambassadors for the Group’s total
headcount.
This indicator is one of the non-financial criteria includedin the variable and long-term compensation of the
Executive Committee.(1)Indicator

2022

2021

% of Believe ambassadors
among employees

8.9%

8.4%

(1) See also Section 4.2.1 “Compensation policy”, page 169 in the
Universal registration document.

11

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

2.2

Analysis of the risks and opportunities related
to Governance, Social and Environmental issues

This statement for the 2022 fiscal year is based on a risk
analysis, pursuant to Order 2017-1180 of July 19, 2017, inorder to reflect the expectations of Believe's mainstakeholders regarding the assessment and managementof CSR risks and opportunities. The methodology for
identifying material risks is presented in Section 2.7“Methodological note and summary of indicators of thischapter, on page 96.

2.2.1 Nurturing the Shaping Music for Good approach throughdialogue with stakeholders
2.2.1.1 Believe’s stakeholders
In line with its values and in accordance with the principleof dual materiality, Believe attaches the utmost
importance to the voices of its stakeholders. The
Company has identified six categories of stakeholders toensure that their expectations are taken into accountwhen identifying priority CSR issues:●

Believe’s talents (employees, etc.);●

artists and labels;●

members of governance and financial partners;●

business partners and suppliers;●

the music industry ecosystem;●other key stakeholders.

This mapping also involves ensuring regular dialogue
between Believe and all players in its ecosystem. It will be
gradually refined by analyzing reciprocal interests andpowers.

Mapping of stakeholders
Our talents° Employees° Ambassadors° Consultants° Candidates

Business
Partners° Digital Social
Platforms° Social media° Minority stakes° Datacenter /cloud providerMusic
Industry
Ecosystem° Collective
rights authorities° Professional
associations° Live stakeholders° Music publishers

ShapingMUSICfor goodfor

Governanceand ﬁnancial
partners° Board of Directors° Shareholders° Investors° Banks

Other keystakeholders° Public authorities
and institutions° Media andinﬂuencers° Citizens andgeneral public° Associations
and NGOs

Artists & Labels° Music creators° Emerging or established artists° Top artists° Labels

Extract from Universal registration document 2022 - Believe

12

2

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

2.2.1.2 Consultation with stakeholders
As part of its approach to co-constructing its CSR strategy– Shaping Music for Good – throughout the second quarterof 2021, Believe consulted employees, artists and labels,
as well as partner platforms.

This consultation made it possible to identify the priority
material topics and to reinforce and challenge thestrategic priorities of Shaping Music for Good. This dialogue
also gave respondents the opportunity to express their
expectations and opinions in all their diversity in terms ofsocial responsibility, in an authentic and personal way.

Results of the stakeholder survey on a panel of 320 people in 2021
(employees, artists and labels, platforms, etc.)

On a scale of 1 to 3, stakeholders rated the themes that should be a priority for Believe:

SOCIAL
2.42/3ENVIRONMENT
2.26/3

SOLIDARITY
1.33/3Equal opportunities, diversity
and inclusion, ﬁght against
discrimination, talent development.

Reduction of the buildings carbon
footprint, digital carbon impact,
IT equipment management.

Access to digital technology
and monetization for artists,
support for local communities.

Expression of Believe stakeholders’expectations and main actions implemented
The Group intends to permeate its relationships with its
stakeholders with its values, and thus best meet their
expectations, with concrete actions.
On the social aspect, stakeholders particularly approved
three subjects:●●●

diversity and inclusion within teams;
conscious measures to work towards reducing
inequalities targeting minorities in the music and digitalindustriess;

These issues are addressed via the Group’s humanresources policy(1) and projects carried out in support oflocal communities(2).
On the environmental aspect, the measurement andcontrol of the carbon footprint are considered important,in particular through reductions in energy consumption(3).
The environmental action plans were initiated in 2022
taking these issues into account.
Lastly, Believe’s stakeholders expect the Group to
maintain fair and transparent relations with all artists,labels, employees and partners(4), which is a priority at theheart of its business model.

the physical and mental health and well-being of
employees and artists.

(1) See Section 2.4 “Employees at the heart of Believe’s business model and Shaping Music for Good”, page 24.
(2) See Section 2.5 “A committed player serving artists and labels and local communities”, page 37.
(3) See Section 2.6 “Actions on the ground in favor of the environment”, page 45.
(4) See Section 2.5 “A committed player serving artists and labels and local communities”, page 37.

13

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

United Nations Sustainable Development Goals
Believe has identified the Sustainable Develpment Goals (SDG) defined by the United Nations to which the Group makes asignificant contribution, in particular through its Shaping Music for Good program.
SDGs

Believe's priorities and actions

Good healthand well-being

Believe deploys a social protection floor for all its employees. The Group offers global and local
activities that promote their well-being at work and their physical and mental health.

Quality education

Believe shares its musical and technological expertise with artists, labels and local communities
through employee engagement (mentoring, etc.) and partnerships (masterclasses, etc.).
Numerous solidarity activities are also organized on the theme of education through music.

Gender equality &The Group ensures the fairness and parity of all its HR and management processes. It trains
reduced inequalities teams in inclusive practices (including through training on cultural and gender prejudices), antidiscrimination and anti-harassment practices.
Believe is committed to the issues of diversity, equity and inclusion in the music and digitalindustry (“Be The Change” study, 50InTech partnership), and via the actions of the ambassadors(Believe for People/Parity).
Decent work andeconomic growth

Believe gives its employees, artists and labels the means to develop their careers, ensure theiremployability and monetize their musical talents. Believe provides them with its digital
expertise, innovative technological solutions, as well as a transparent and fair value-sharing
system.

Climate action

Believe measures and manages its direct impacts on the environment through concrete actionsin its offices via the commitment of its ambassadors (Believe for Planet) and employees.
The Group is also beginning to analyze its scope 3, a still complex exercise that will make itpossible to measure the impacts of data centers, the cloud and streaming practices.

Extract from Universal registration document 2022 - Believe

14

2

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

2.2.1.3 Ongoing dialogue with thefinancial community●

Since its IPO in June 2021, Believe regularly communicateson its activities, strategy and outlook to individual andinstitutional shareholders and, more generally, thefinancial community (investors, agencies, rating agencies,etc.).

On the Group’s website, in the Investors Section, thefollowing information is available:
regulated information, of which the effective andcomplete distribution is carried out electronically,
including on the AMF (Autorité des Marchés Financiers Financial Markets Authority) website, by a professional
distributor on the list published by the AMF;

MSCIGaïa Reasearchby Ethifinance15

the financial publications calendar;●

the share price;●

the share capital structure.

The Group’s non-financial performance was assessed byinternationally recognized agencies on the basis ofgovernance, social and environmental criteria. The Groupobtained positive ratings only one year after its IPO in June
2021 and the implementation of the associatedregulations and best market practices. These assessments
demonstrate Believe’s level of maturity and commitment
to CSR and its integration into its business model andvalues.

In 2022, the Group’s Investor Relations met with morethan 250 institutions.

Rating agency●

2.2.1.4 Recognized non-financial
performance

The Group follows the best practices of the profession.
Believe’s management and Investor Relations maintain aregular dialogue on environmental, social and governance(ESG) issues with the financial community. They take partin roadshows, and other individual meetings and thematicconferences, notably on socially responsible investment(SRI) topics.

●

financial press releases, quarterly results presentations
in webcast and their transcription;

Believe's rating in 2022

Description

Believe was rated AA (on a scale from
CCC to AAA) in 2022 and is among the
12% highest-rated companies in its
industry (Media & Entertainment).

MSCI (Morgan Stanley Capital International) provides in-depth
research and analysis on ESG topics on more than 5,800
companies. Its rating system is regularly updated to assess the
ESG performance of organizations with regard to regulatory,
technical and sectoral changes.

Believe obtained the Bronze level,with a score of 53/100 for the 2021
fiscal year, similar to the national andsectoral benchmarks carried out by
the agency.

Gaïa Research assesses the performance and management of
ESG risks and opportunities of small and medium-sizedcompanies listed on European markets. Its rating system isbased on more than 140 ESG criteria linked to stakeholders
updated annually.

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

2.2.2 Policies and actions to address ESG challenges:
risk and opportunities matrix
The table below presents the results of the analysis, aswell as the description of the main ESG risks andopportunities identified with regard to Believe’s activities,
its challenges and those of the music industry. This
analysis was carried out on the basis of the frameworkprovided by the Shaping Music for Good strategy, thepriorities identified by stakeholders in the context of themusic and technology sector, regulatory expectations andbest practices in non-financial reporting, and therecommendations of the CSR Committee and the risks
identified in Chapter 3 to which Believe is exposed.
This matrix of risks and opportunities is organized into
three main themes that cover Believe's main ESG issues:●●●This table presents the main policies and action plans
implemented to reduce these risks and develop
opportunities within the framework of the four main
pillars of the Shaping Music for Good (SMFG) strategy. It
also specifies the Sections of this Chapter 2 – NFPS and of
the Universal registration document that deal in moredetail with these subjects. Finally, it illustrates the United
Nations SDGs to which the Group contributes.
The Group’s main risk factors, as presented in Chapter 3of the Universal registration document, were enhanced in
2022 by the work carried out on the matrix of ESG issues.
Some ESG risks have been added or adjusted, dependingon the Group risk prioritization process.

social, talent development and ethical practices issues;
societal issues, with artists and labels and local
communities;
environmental issues.

The ESG risk analysis covers Believe’s activity and its value
chain. It did not reveal any material risks related torelations with its suppliers and subcontractors(1).

(1) Type of suppliers and subcontractors: mainly related to purchases of real estate and related services, digital equipment and data centers.

Extract from Universal registration document 2022 - Believe16

2

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

BELIEVE’S ESG CHALLENGES, RISKS AND OPPORTUNITIES MATRIXCSR ISSUES AND
CHALLENGESRISKSOPPORTUNITIESPOLICIES AND/OR ACTION PLAN

SMFG PILLARSAND SDGSNFPSAND URDSECTION

SOCIAL ISSUES AND CHALLENGES● Developing the visibility ofDeveloping astrong employer
brand andattracting highlevel candidates

the employer brand on theInternet and social networks
with a new Careers website● Deploying an effective

recruitment policy and tools(deployment of Smart Recruiter,
recruitment training guide,referrals, etc.)

2.4.3,
page 67● Performing regular surveys of

Having the skills
necessary tomaintain ourleadership
position in a
rapidly changing
industry and ina highly stressedlabor market:●●

Recruiting andretaining theright talent
Having anddeveloping
technical
and digitalmarketingskillsall employees to measure thevarious dimensions of theircommitment and satisfaction(Your Voice)

Risk of not being an
attractive employer
and not retaining
the talent needed
for growth

Developing
effective working● Supporting employees in theconditions, wellmanagement of their work
being and mental
and their mental healthhealth and creating(stress management,
the conditions formentoring, external
constructive social
psychological support, etc.)
dialogue in the●
Setting
up local activities todaily lives of thepromote well-being and teamteams
spirit (sports and physicalactivities, catering, etc.)

2.4.6,
page 74● Deploying a social protection

floor to all employees● Supporting their career

Retaining andsupporting
employees intheir careerdevelopment

development and assessing
employee performance● Supporting managers andleaders in their managementrole (training and coaching)

2.4.4,
page 69● Implement strategic talentdevelopment and succession
plans

Continuously
developing the
Risk of not providing highest level ofartists and labels
skills, and training
with the mostemployees in theadvanced technical most recent
and digitalpractices,marketingparticularly intechnology anddigital marketing17● Deploying skills acquisition

methods adapted to thepractices of the digital sector,
with updated shared modules
and a powerful online platform● Implementing the best

Extract from Universal registration document 2022 - Believe

practices and training incybersecurity

2.4.4.1,
page 69
2.4.4.2,
page 69

www.believe.com

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

CSR ISSUES AND
CHALLENGESRISKSOPPORTUNITIESPOLICIES AND/OR ACTION PLAN

Creating an
inclusive
environment andmaking diversity alever for employee
attractiveness,motivation andperformance● Promoting gender equity

SMFG PILLARSAND SDGSNFPSAND URDSECTION

SOCIAL ISSUES AND CHALLENGESManaging theGroup’s rapid
growth andinternationalizati
on:
●

●

Sharing
Believe's
culture andvalues:developing
a company
recognized
as diverse,
inclusiveand fairEnsuring
the local
performanceof the teams

and parity in all HR andmanagement processes● Raising employee awarenessof inclusive, anti-bias,
anti-discrimination andanti-harassment best practices

Risk ofdisengagementof employees andnon-alignment
with Believe’s values
Engaging andand compliancemotivating
practices
employees thanks
to our CSR Shaping
Music for Goodambition and byuniting themaround strong
values

2.4.5,
page 71● Developing an ambassador

network (Believe for Planet,
Believe for People/Parity)● Promotion of Believe's Driving

Forces (Respect, Expertise,
Equity, Transparency)● Deploying policies and tools

to apply ethics andcompliance standards

2.1.3.3,
page 52
2.3.2,
page 63
2.3.3,
page 64● Setting up and publicizing

the whistleblowing system

Involving
employees in the
Company's growth
Risk ofinconsistency andeffectiveness of
HR and talentmanagement
processes● Deploying a fair and attractive

compensation system(job/talent/compensation
framework)

Recognizing talentthroughcompensation● Developing an attractive and

Implementing
structured androbust HR
processes anddeploying themacross all countries
and subsidiaries

fair employee shareholding
program● Define central policies

2.4.1,
page 65
2.4.7,
page 76

applied locally andstandardize human resources
information systems

Extract from Universal registration document 2022 - Believe18

2

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

CSR ISSUES AND
CHALLENGESRISKSOPPORTUNITIESPOLICIES AND/OR ACTION PLAN

SMFG PILLARSAND SDGSNFPSAND URDSECTION

SOCIETAL ISSUES AND CHALLENGES● Understanding andEngaging themusic industry infavor of diversity,
equity andinclusion:●

Being aninclusive
partner for
all diverse
communities
and all typesof music genres

Risk of exclusion forcertain communities
and music genres,
and non-alignment
with Believe’s values

Promotingemerging artists,
women andminorities in themusic industry

measuring the challenges
faced by women andminorities in the musicindustry (Be The Change study)● Building partnerships withthe music industry andtechnology for women andminorities (Key Change, WIM,
50'inTech, etc.)

2.5.2.2,
page 82● Supporting artists committed

in favor of minorities

Engaging
employees andproviding theopportunity andframework toparticipate insolidarity activities● Developing solidarity-based

activities and building musiceducation programs (Believe
Tomorrow)

2.5.2,
page 82● Developing easy-to-use digital

Attracting,revealing andsupporting local
and diverse artists
and labels in thedevelopment of
their musiccareers throughRisk of digital divide,
digitalinvisibility and lacktechnologies andof artist skills toservices●●

19

Providing easy
access to digitalmusic
technologies
Mastering new
digital musicpractices for all
types of artists
and labels(beginners orexperienced)

make the mostof new digitalmarketingtechnologies
and practices

platforms and service
offerings adapted to thedifferent needs of artists andat each stage of their career(TuneCore offer)

Training and● Increasing the level of
supporting artists
expertise of artists andin the development
labels, and training them inof their careersdigital and digital marketingand their digitalpractices (Artist Resources
presence by
program on Backstage,
making the most of
TuneCore Rewards,
the latest
MasterClasses, etc.)
technologies anddigital marketing● Providing access to a broadpractices
portfolio of reliable digital
service providers to ensure alevel of visibility with local
communities (150 DSPs
assessed according to rigorous
criteria, partnerships with DSPs,
etc.)
Developing musiceducation
programs for
disadvantaged
communities andsupporting future
young musicaltalents as well as
the local musical
heritage

2.5.2,
page 82● Developing music education

Extract from Universal registration document 2022 - Believe

programs for disadvantaged
communities and supporting
future young musical talents(BEAMS India, Songwriting
camp, Casa Preta Hub, etc.)

2.5.1,
page 78www.believe.com

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

CSR ISSUES AND
CHALLENGESRISKSOPPORTUNITIESPOLICIES AND/OR ACTION PLAN

SMFG PILLARSAND SDGSNFPSAND URDSECTION

SOCIAL ISSUES AND CHALLENGES

Maintaining
relationships oftrust with artists
and labels to
promote theirartistic creativity
and financial
independence:●●

Being anadvisory
partner while
ensuring theindependence
and creativityof artists andlabelsHelping artists
protect theircontent andmonetize theirmusic● Protecting the creative

Respecting artists'
fundamental rights
and their artistic
choices
Risk of limiting
the freedom of
expression andindependenceof artists and labels,
and of notrespecting
private data

independence of artists andlabels while ensuring
compliance with local
regulations (monitoring andmoderation of content
depending on the country,
advice and educational role forartists in the event ofpotentially sensitive content,
etc.)

2.5.1.5,
page 81● Establishing a contractual andSharing value fairly
and transparently

Respecting thedata privacy ofartists and labels

fair remuneration policy that
respects the sharing of value
with the artist according to thedevelopment of their career(new TuneCore rates, reduced
exclusivity clause)

2.5.1.6,
page 82● Implementing measures andteams in charge of processing
and protecting data of artists
and labels (within Believe andin coordination with the DSPs)

2.5.1.5,
page 81

Extract from Universal registration document 2022 - Believe20

2

Corporate social responsibility
Analysis of the risks and opportunities related to Governance, Social and Environmental issues

CSR ISSUES AND
CHALLENGESRISKSOPPORTUNITIESPOLICIES AND/OR ACTION PLAN

SMFG PILLARSAND SDGSNFPSAND URDSECTIONENVIRONMENTAL ISSUES AND CHALLENGES● Measuring and reducing energy

consumption and GHG
emissions from office buildings● Measuring and reducing theReducing the directenvironmental
impact of ouractivities●

Promoting an ecoresponsible digitalmusic industry:●●

Ultimately
contributing
to carbon
neutrality forour direct
activities
Understanding
and limiting
the impact ofthe digitalmusic industry
on theenvironmentand climate

use of electrical and electronicequipment by promoting
recycling

Encouraging low-carbon
transport practices

2.6.3,
page 96● Training and engaging

Climate andresource-relatedrisks across theentire digital music
and digital value
chain (data center,streaming,
equipment, etc.)

employees in eco-responsible
practices● Assessing the indirect impact

Using our role as aleader in digitalmusic to engage
the various players
to have a positive
impact on theenvironment
throughout thevalue chain(scope 3) and identifying the
key levers for Believe to limit
the physical and transition risks
related to climate change.

● Developing best practices in

2.6.1.1,
page 86

streaming, data centers andmerchandising products andmusic events● Promoting artists who arecommitted to environmental
protection● Training and engaging

employees in eco-responsible
practices (Believe Tomorrow/
Believe for Planet Ambassadors)

21

2.6.2,
page 96

Extract from Universal registration document 2022 - Believe

2.6.3,
page 96www.believe.com

Corporate social responsibility
An ethics and deontological system as close as possible to employees, artists and labels

2.3

An ethics and deontological system as close as
possible to employees, artists and labels

Ethics is one of Believe’s first requirements on a daily basis
in its operations. It is anchored in the Group’s history andvalues: Respect, Expertise, Fairness and Transparency.

Believe has put in place a set of tools and systems
described below to promote and ensure theimplementation of ethics and compliance principles in its
activities. In the Group risk mapping, risks related to fraud,corruption and ethics are classified as medium risks.(1)2.3.1 Organizing the governance of ethical issues
The Compliance Officer reports directly to the Legal
Department. She is responsible for designing andimplementing the Group’s compliance program. This
includes, among other things, ethics, anti-corruption andconflict of interest tools and rules.

The Compliance Officer occasionally participates in the
Risk Committee to report on the progress of work related
to the Sapin II Law and the GDPR. This Committee ispresented in Chapter 3, Section 3.2.1 “General organizationof internal control”, page 132.

The Compliance Officer participates in the Ethics
Committee to ensure the strict application of proceduresby the Group’s employees and partners. The Ethics
Committee is dedicated to handling reports of breaches ofinternal rules and codes.

This organization allows centralized governance, at Grouplevel, of compliance and ethics issues, controls to be
carried out and the management of alerts and risks.

2.3.2 Deploying policies and tools to apply ethics and compliancestandards
The compliance program includes several tools, including
the Code of Ethics and the Anti-Corruption Code (available
in more than ten languages), as well as the conflict ofinterest procedure and control mechanisms. These Codes
are made available on the Group’s website (Compliance &Ethics | Believe), as well as on the Intranet site, which areboth accessible to employees. They set out therecommended ethical behaviors, those that areprohibited, as well as the sanctions incurred for any
reprehensible behavior committed by Believe’s directors,
shareholders or employees.(2)Believe has set up a training and awareness program on
ethics, compliance and respect for human rights to ensure
the permanent application of these rules and proceduresby employees. In particular, all newcomers follow aninteractive training module on the subject, and workshops
are organized for role-play. The program also provides forregular updates and training campaign reminders for
current employees. A major online training campaign was
launched in 2021 (67% of employees trained), and wascompleted in 2022 (44% of employees trained).
The Group also deploys a training course called Be FAIR on
Diversity, Equity and Inclusion, which explains theprinciples of non-discrimination and anti-harassment tobe respected at Believe.(3)Indicator

2022

2021

% of employees having
completed the Code of ethics
and/or anti-corruption and/or
conflict of interest training

44%

67%

(1) See Chapter 3 “Risk factors and risk management”, page 111 in the Universal registration document.
(2) The content and guidelines of the Ethics and Anti-Corruption Codes are detailed in Chapter 3 “Risk factors and risk management”, page 111
in the Universal registration document.
(3) See Section 2.4.5 “Creating a diverse, inclusive and fair working environment”, page 30.

Extract from Universal registration document 2022 - Believe22

2

Corporate social responsibility
An ethics and deontological system as close as possible to employees, artists and labels"The extraordinary growth that Believe is experiencing ispossible because these values are at the heart of ourbusiness. Our ethical standards, supported by strict
regulations, must be imposed on us all, individually andcollectively. Every day we have to make many decisions.
Some of them can sometimes raise complex ethics issues
that deserve special attention. It is in this context thatthe Believe Code of ethics was drawn up. It sets out themain standards of conduct applicable to our businessand sets out the guidelines that we must follow within
Believe when we are required to make decisions. It is theadherence by each one of us to Believe’s values that
contributes to its success”.
Xavier Dumont,
Chief Financial and Strategy Officer.

2.3.3 Setting up and publicizing the whistleblowing system
Since January 2021, the Group has rolled out awhistleblowing system available in five languages,
24/7 and managed by an independent organization. Itshould enable everyone to report online wrongdoing or
inappropriate behavior that does not comply with
Believe’s Code of Ethics, whether proven or suspected.
Believe has also set up training modules for employees toinform and explain how this whistleblowing procedure
works. This makes it possible to detect sensitive situations,in particular fraud, corruption, discrimination orharassment or non-respect of human rights. Employees
are encouraged to express themselves confidentially,anonymously or not, depending on their wishes. This
procedure enables them to report in good faith a serious
breach of the law or of Believe’s internal rules.
This system meets the requirements of the Sapin II Law
and is open to all employees and stakeholders, including
artists, labels, partners and digital service provider
platforms, and suppliers. It is available on the Group’s
website: https://believe.integrityline.org/index.php. It is
supported by a whistleblowing management protocol thathas been rolled out within the Group. Depending on thetype of incident and alert reported, the protocol provides
for the opening of an investigation and their rigorous
handling:●●

alerts relating to labor law, harassment, discrimination,
employee health and the working environment aretransmitted to and analyzed by the Group’s Human
Resources Department. The latter then takes thenecessary measures or appropriate sanctions if need be;other alerts, including fraud, corruption, conflict ofinterest and non-respect of human rights alerts, aresent to the Compliance Officer.

Believe is committed to considering all complaints andtreating them with respect and confidentiality. The mostserious alerts are examined by Believe’s Ethics Committee,
composed of the Compliance Officer, the Chief People
Officer, the Legal Department and the Chairman and Chief
Executive Officer of Believe.
In 2022, we did not receive any alerts through this specificsystem. Alerts of discrimination or inappropriate behavior
towards employees were reported directly to local Human
Resources departments. All these alerts were investigatedand dealt with.
In line with the principles of the Sapin II Law, Believe has
also set up a rigorous process for evaluating and selecting
third parties, in particular its main digital service provider
partners.(1)Lastly, risks related to taxation and changes thereto are
addressed through regular tax monitoring and processes
to ensure compliance with current regulations(2).

(1) See Section 2.5.1.2 “Developing unique and innovative partnerships with local digital service providers”, page 38.
(2) See Section 3.2.1.1 “Definition and objectives of internal control”, page 132 in the Universal registration document.

23

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

2.4

Employees at the heart of Believe’s businessmodel and Shaping Music for GoodAs a fast-growing international Group, Believe must beable to attract, recruit and develop the right talent at thecentral and local levels to ensure the development of its
activities and remain at the forefront of digital musictechnology and practices. Employees are one of thefoundations of Believe’s expertise. The ability to retain its
teams, share the Group’s values and its Shaping Music forGood ambition are also key to Believe’s success. The risk
related to human capital and its development is one of theGroup’s main risk factors.

2.4.1 A structured human resources organization to support
the Group’s growth
Believe has put in place structured and robust humanresources management processes and tools capable ofmeeting the following challenges:
●

●

●

●

recruiting and integrating a significant number of
employees in more than 50 countries, in a context ofpressure on available talent in certain segments,
particularly in the technological, digital and musicindustry profiles;
developing skills and offering career opportunities in a
disruptive and rapidly changing industry;retaining and supporting employees and managers
throughout their careers, in order to meet new
expectations in terms of quality of life at work and“purpose”. Developing best managerial practices, andthus ensuring a high level of commitment;
integrating the resources of the acquired companies,
by sharing and applying the same values and principles
as within the Group.

An organization in central and local
teams

●

CSR & engagement, which steers the Shaping Music forGood approach, non-financial performance and thedeployment of certain employee engagement activities.

The role of the central teams
The main role of the central teams is to define theprinciples, policies and practices. They ensure consistency
and equity in access to Group programs, tools andreporting.
The main role of the local human resources teams, withthe support of the central teams, is to:●implement these policies on the ground;●

adapt practices according to country specificities;●

operationally manage talent development and support
managers in their role of effectively managing theirteams.

The permanent dialogue between the central and local
human resources teams allows the alignment of policies
and practices while having a pragmatic and effective
approach on the ground.

This organization enables the consistent and rapid
deployment of policies and tools in all Group entities. It
also provides local management in the countries.

Group policies and practices

Believe has structured the Human Resources Department
into three central divisions. They serve the humanresources networks in the regions and countries.

●

attractiveness, recruitment and retention of teams;●

skills development and support for managers;●●

People success, which implements talent acquisition anddevelopment policies and strategies.
Operations, which deploys compensation & benefits
policies and tools, as well as human resources
information systems, procedures and dashboards.

They cover the following topics:

●

●
●

●

the promotion of the principles of Diversity, Equity andInclusion, and gender parity;well-being at work and health;
the sharing of value and the search for fair andattractive compensation;social dialogue.

Extract from Universal registration document 2022 - Believe24

2

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

2.4.2 Believe employees in key figures
As at December 31, 2022, the Group had 1,651 employees
in the companies included in its scope of consolidation,
including 643 in France(1).
For the 2022 fiscal year, the Group’s payroll amounted to€135.5 million compared to €104.8 million for the 2021

fiscal year, and €78.6 million for the 2020 fiscal year. The
payroll is the sum of all gross salaries and the employer’ssocial security contributions, as well as employee profitsharing and other personnel costs, paid during eachfinancial year.

Headcount evolution

Geographical breakdown of the 2022 headcount

1,800

1,651

1,600

1,430

39% France

1,270

1,400

15% Germany

1,200
1,000

900

600

14% Europe excludingFrance andGermany

400

11% Americas

200

21% Asia/Oceania/
Paciﬁc

800

0

2019

2020

2021

2022

HeadcountSince 2019, Believe’s headcount has grown by 58.9%. In 2022, the headcount continued to grow with an increase of 13.4%
compared to 2021 to further support the acceleration and structuring of Believe’s growth. New hires represented 24.1% of
the average headcount for the fiscal year ended December 31, 2022. Over the same period, the attrition rate was 16.1%,
down significantly compared to 2021 (19.1%). This result is due to a better ability to retain talent in a labor market thatremains highly stressed.

Headcount breakdown by business segment
in 2022
64% Premium
Solutions& AutomatedSolutions
36% Central
Platform

Breakdown of fixed-term/permanent contracts
in 2022

96% Permanentcontracts
4% Fixed-term
contracts(1) In this Chapter, the Group’s headcount is presented at the end of the period, excluding interns and temporary workers. In addition, the Grouprelies on the services of external consultants in a number of countries where it operates. These consultants are not counted as employees.

25

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

Breakdown of women and men in 2022
Womenamong employees
660 Percentageof headcount51 Of which
managers

Breakdown of women and men in Executive
Committee in 2022

50% Women
Men among employees
872 Percentageof headcount
68 Of which
managers

50% Men2022 age pyramid[>60][56-60][51-55][46-50]

1.0%
2.4%
5.0%
7.1%
11.3%

[41-45][36-40]16.1%[31-35]24.1%[26-30]
[≤25]

23.3%
5.3%

2.4.3 Attracting, recruiting and integrating employees
Believe’s business model is essentially based on theexpertise of its teams in highly competitive businesses.
The ability to attract, recruit and integrate the right talentis an important issue in supporting the Group’s growth.
Every year and on all continents, Believe recruits large
numbers of employees with diverse levels of skills andexperience. These include experts in the music industry, IT
engineering and development, digital and data
management and analysis.
Procedures for each stage of recruitment are deployed ina uniform manner in all countries. The aim is to deal withcompetition and strengthen the Group’s attractiveness, inparticular among “Tech” profiles which are also sought
after by companies with a stronger reputation(1). The job
market in the digital world is characterized by strong andglobal competition.
Believe’s talent acquisition policy is also based on theGroup’s values. The People success team manages andcoordinates the recruitment process in all countries. It
ensures successful recruitment and guarantees atransparent, fair and uniform candidate life cycle.
Dedicated teams are set up in countries where thenumber of hires is particularly high.

(1) See also Section 3.1.3 “Risks related to the Company”, page 125 in the Universal registration document.

Extract from Universal registration document 2022 - Believe26

2

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

2.4.3.1 Developing the visibility
and attractivenessof the employer brandPreparing for recruitment:●

For several years, Believe has been developing thevisibility and attractiveness of its employer brand bypromoting:
●
●

●

●

a diverse and inclusive work environment;
the Group’s
employees;

transparent

relationships

●

●

with

its

the professional opportunities offered throughout theemployee’s career;●

fair compensation in line with market practices.

In 2022, the Group rolled out its employer brand, Set thetone, notably by developing a new website dedicated torecruitment and accessible from the Group’s website(https://careers.believe.com/en/). Promoting the Shaping
Music for Good approach also contributes to Believe’s
attractiveness and pride in belonging, particularly among
young talent. The Group is also very attentive topresenting the values, working conditions andcompensation to potential candidates in complete
transparency and thus ensuring the success ofrecruitment.

●

●

●

●

●

●

●

recruit committed talent in line with Believe’s values;
strengthen Believe’s positioning with technology andmusic industry candidates, by promoting Believe’s
initiatives and opportunities, and by promoting theShaping Music for Good program;engage employees in the recruitment process, inparticular via co-optation and promoting the employer
brand on social networks;
increase the Group’s visibility on the Internet and on
specialized platforms such as Indeed, Welcome to theJungle and Glassdoor. More specific actions are also
carried out on the platforms used by talent and experts
in the technology and music industry.

The Group is increasing its recruitment opportunities bywelcoming interns, apprentices or candidates who have
not yet graduated. To this end, it is strengthening its
relations with schools and universities, and developing its
visibility on the campuses of schools and universities, inaccordance with its diversity policy. In addition, Believe is
continuing its proactive policy of recruiting women(1).

2.4.3.2 Deploying an effective
recruitment policy and tools
Believe has implemented and deployed procedures, tools
and training for the various stages of recruitment in all
countries.

defining the content of the position and the profile
sought by sharing a set of objectives and skills bybusiness line;
calibrating positions with regard to market prices,using internal compensation grids and recognizedexternal benchmarks such as that of Towers Watson;
publishing attractive job offers, that are clear withregard to roles and responsibilities, and faithful to thereality of the position;
generating and selecting a pool of candidates thatmeet the Group's needs.

Interviewing and assessing candidates:

Believe’s employer brand strategy aims to:●training and supporting managers by providing
recruitment guides and training, as well as the value
proposition as an employer brand;●●transparently explaining to the candidate the various
stages of recruitment, as well as the benefits andchallenges of joining Believe;
preparing the interviews in order to effectively andfairly assess candidates;
assessing the candidate in the most objective andunbiased way possible, in particular through the
upstream training of managers and recruiters on the
conscious and unconscious influence of each person’s
biases(2);testing and assessing the suitability of the candidate
with Believe's “culture” and values, in particularthrough a profile test specific to Believe;
identifying and explaining to the candidate careerdevelopment and skills enhancement opportunities.

At each stage, Believe has also set up a monitoring ofsatisfaction with the recruitment process from the point ofview of the candidate-hire and the manager-recruiter. It
will be rolled out more widely at a later date.

2.4.3.3 Offering effective and rapid
onboarding of new employees
The onboarding process is essential to ensure the new
employees have a successful experience at Believe fromthe start and allows them to efficiently integrate within theorganization.
The first onboarding step is offered online and starts
before the employees arrive at Believe. This is followed byadditional online as well as face-to-face onboarding steps.
This process facilitates the integration of new joiners andshares the fundamentals of Believe's culture and values
from the outset.

(1) See Section 2.4.5.1 “Promoting gender equity and parity”, page 30.
(2) See Section 2.4.5.3 “Training employees in the principles of diversity, equity and inclusion (DCI) and anti-discrimination: the Be FAIR program”,
page 33.

27

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for GoodThis onboarding phase includes:●●●

the management of administrative matters (contract,equipment, social benefits, organization, etc.);
the presentation of the Group, its activities and its
values;In addition, the integration of teams from acquiredcompanies is subject to specific management adapted tothe company, the number of people involved and thecommercial strategy, with a dual objective:●

the first mandatory training sessions (Code of Ethics
and conflicts of interest, Be FAIR on diversity, equity andinclusion, IT security, etc.).

These shared Group training modules are supplemented
by “business line” training. Interviews at 30 days and 90
days, carried out with local HR, make it possible tomeasure the level of employee satisfaction and tocomplete the onboarding process if necessary (reinforce a
subject, facilitate internal contacts, etc.).

●

share Believe’s common values and deploy key
processes (technology, operations, product, finance,compliance, human resources, etc.). On this occasion,
the b.shares shareholding plan launched in 2022 wasopen to all acquired companies in eligible countries.
19% of employee subscribers were from thesecompanies;
maintain the necessary autonomy and agility that are
the strength of the brand, while sharing expertise.

2.4.4 Retaining and supporting employees in their careers
In a constantly changing industry, it is essential for Believe
to develop and train the next generation of digital music
leaders and experts who will offer a high level of service toartists and labels. The Group’s ability to meet the new
expectations of employees, to retain and develop them isa major asset in supporting its growth and its innovation
policy. It is also a lever to differentiate itself from otherplayers in the “Tech” and digital music industry, that are
Believe’s competitors in the talent market.

2.4.4.1 Supporting career development
and employee performance
In the technology and digital music industries, and moregenerally in fast-growing companies, employees have highexpectations in terms of career development andmobility. Believe, therefore, deploys precise managementof employee performance. Robust tools to support
employees throughout their career Believe also offers
them mobility and development opportunities in order toretain its talents.
Since 2020, Believe has implemented a career review
process that is structured and common to the entire
Group. This is a key stage in the employee's career
management and development. Across all countries, each
employee receives at least one career review per year, via
a global digital platform. This review allows the employee
and the manager to take stock of past activities and theachievement of the objectives set. Employees also identify
their needs for individual support and training, and share
their wishes for professional development. On thisoccasion, the manager may propose development or
support plans, the results of which will be shared at thenext career review.

Indicator

2022

2021

% of employees who
conducted at least one career
review during the year

97%

95%

Among the development actions, the practice of
mentoring is popular. It was, therefore, continued in 2022.
Launched in 2021, the Believe for Parity ambassador
network continues to deploy it in France with the supportof the human resources team. In two years, more than 60
mentors and mentees have enrolled in this program tosupport new hires, enable the discovery of digital music
professions, or share business or management expertise.
This practice facilitates the assumption of duties and therapid increase in skills. It also facilitates professional
mobility by expanding the employee’s network.

2.4.4.2 Offering training anddevelopment programs adapted
to employees and our businesssectorBelieve offers a wide range of training programs to all
employees, so that they can remain or become experts on
topics specific to their field. The aim of these training
courses is to strengthen or acquire skills, in particularmanagerial and personal development skills, or on highly
evolving or disruptive subjects (IT development, data
analysis, digital marketing, etc.).
Each employee is encouraged to follow the training
courses that best meet their needs and the changes inBelieve’s activities. The content offer, the methods ofacquiring skills and their results are managed within theBelieve Academy and Business Campus online platforms.
Digitization enables each employee to follow their training
path and to know the mandatory and recommended
modules adapted to their profile.

Extract from Universal registration document 2022 - Believe28

2

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

Believe has partnered with recognized training platforms
to offer a catalog adapted to the Company’s business lines
and selected for their quality. The development of short,educational and varied online modules offers great
flexibility and facilitates self-learning. The content formats
are multiple (tutorials, videos, webinars, personalized
training, e-books and podcasts) on a wide range of topics.
Some training courses can also provide certification,
particularly for the “technology” professions. From 2023,
content from the largest institutions and enabling theacquisition of high-level skills (MIT, Harvard Business
School, ESSEC, HEC, Singapore University, AWS
certification, etc.) will also be offered.
Online training programs, supplemented by face-to-facetraining more specific to a department or business, cover
the following areas:

The Executive Committee and managers are supported ona daily basis by the central and local Human Resources
teams. Together, they monitor recruitment, carry out
biannual interviews, salary reviews, the reviews ofobjectives and support measures for the development of
their teams.
All managers and leaders benefit from two specificprograms, Managers@Believe and Leadership practices.
They include quarterly seminars, online modules, group
work, practice sessions, podcasts, coaching andmentoring, etc., to reinforce managerial practices. These
cover:●

conflict management;●

career and salary reviews;●

the definition of performance objectives;●

people development;●

the culture of feedback;●support for managers;●change management, etc.

●

business line expertise;●

the fundamentals of Believe.

The People success team manages the quality of training
and verifies that the content and teaching methods are inline with market expectations and new practices. It
conducts regular surveys to collect the satisfaction rate,
and measures it with indicators such as the Net Promoter
Score (NPS). The aim is to ensure the relevance andquality of the training provided.
All of these training courses and tools demonstrate
Believe’s intense investment in the development of its
employees. This training policy is part of the careerdevelopment plan for each employee, which is drawn up
during career review sessions.
The Group indicator “% of employees who attended atleast one training course during the year” is included in
the variable and long-term compensation criteria for
executives.(1)Indicator

2022

2021

% of employees who attended
at least one training course
during the year

90.6%

77%

2.4.4.3 Supporting managers
and preparing a talent pool
Believe is very committed to supporting its managers, who
are often young or junior in their roles, and who assume
their responsibilities in a fast-paced and fast-growing
environment. The objective is to:●prepare them for taking up their duties;●

support them in their day-to-day management role;●and build a career plan with them.

To anticipate and support skills development, some ofthese training courses take place before the manager
takes office. Believe measures the satisfaction rate ofthese training courses.
In 2022, Believe defined a strategic talent development
planning process that will be gradually rolled out
throughout the Group.
This structured process aims to:
●

●

●

●

identify critical positions and key experts for theGroup’s activities today and tomorrow;support the individuals identified to retain and develop
them;define succession plans in the event of departure orabsence in order to ensure business continuity;
prepare potential future leaders.

As part of this strategic talent development plan, Believebegan to formalize a methodology for developing a
succession plan in 2022. It will be applied in 2023 for themembers of the Executive Committee and the main
leaders. This work focused on the organization of acontinuity plan in the event of an unexpected absence ordeparture among executive corporate officers andexecutives in each country and department. It consists of:
●

●

●
●

anticipating the intentions of employees identified as
key people;
identifying future potential leaders for each key
position;
confirming their ambitions within the Group;and preparing them for their future responsibilities
and duties.

(1) See Chapter 4 “Corporate governance”, page 139 in Universal registration document.

29

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

2.4.5 Creating a diverse, inclusive and fair working environment
Operating in over 50 countries and with more than one
million artists served directly or via their labels, diversity ispart of the daily life of Believe's employees. The Group
promotes and supports diversity in all its forms – gender,
ethnicity, nationality, religious beliefs, sexual orientation,
disability, age – as a source of creativity, innovation, andindividual and collective development.
“Being surrounded by people who think differently
constantly challenges you and makes you grow. Diversity
is critical to providing the best solutions to our artists
and labels in a constantly changing environment.
Fairness and inclusion are key drivers of the well-being
and engagement of our employees. Believe’s goal is to be
an inclusive, responsible and example-setting player inorder to be one of the top employers in the musicindustry”.
Denis Ladegaillerie,
Chairman and Chief Executive Officer
and Founder of Believe
The Group thus attaches particular importance topromoting Diversity, Equity and Inclusion (DEI), both
among artists and labels and among employees. Believe isparticularly committed to gender equity and also actively
fights against sexism, racism and all forms of
discrimination and harassment. Aligned with the Group’s
values, these DEI principles are deployed in all humanresources processes and among managers. The Believe for
People/Parity ambassadors also help to put theseprinciples into practice(1).

2.4.5.1 Promoting gender equity
and parity
Believe attaches particular importance to gender equity
and parity, in particular through the recruitment andpromotion of women within the Executive Committee,
among managers and for all employees.

Building increasingly gender-balanced
teams
Largely exceeding the provisions of French law underpreparation, at end 2022, 50% of Executive Committee
members are women. In addition, in 2022, 57% of themembers of the Board were women(2). Three independent
women directors chaired the three Audit, Nomination &Compensation and CSR Committees.

indicator of the percentage of women among all
employees as a non-financial criterion included in thevariable and long-term compensation of executives. At
end 2022, Believe had 43.1% women among all
employees, exceeding its target. The proportion of womenin the Group’s headcount increased by three points
compared to 2021. This significant improvement is theresult of the commitment of the entire Executive
Committee, a proactive policy to attract female talent andthe creation of a more equitable and inclusive working
environment.
The Group is working on its attractiveness, its recruitment
processes and the retention of female employees. For
example, gender terms in job offers are deleted and the listof selected candidates must contain female profiles. The
results are convincing: in 2022, women accounted for 51%
of hires, a very significant increase compared to the last two
years (45%).
The Group is also focusing its efforts on the “tech-IT”
population, where the number of women in the businesslines is still limited.
In France, since 2021 Believe has partnered with 50inTech,a global organization fighting for gender equality inscience, technology, engineering and mathematics (STEM),
sectors where women are still underrepresented and do
not receive sufficient support. The organization highlights
on its website the robustness of Believe’s inclusion anddiversity system, in all its dimensions. In 2021, Believe
obtained a score of 85/100 in 50inTech's Gender score,
which is one of the best scores.

Implementing equity practices
on a daily basis
In France, Believe also monitors the professional genderequality index according to the criteria provided by French
legislation.
The continuous and remarkable improvement of thisindex in France between 2019 and 2023 demonstrates theGroup’s commitment to fairness (from 56 in 2019 to 99/
100 for the 2021 and 2022 data). Believe obtained thisscore for the second consecutive year. It is due, inparticular, to better monitoring of equity practices in all
human resources processes: recruitment, compensation,
development, promotion, return from maternity leave. The
Group also applies this indicator in the main countries
where it operates (UK, Germany, India, China and theUnited States) and monitors the progress made and theactions implemented since.

In addition to the management bodies, the Group has set
itself an ambitious target of gender parity with an(1) See Section 2.1.3.3 “A global network of committed ambassadors”, page 11.
(2) See Chapter 4 “Corporate governance” , page 139 in the Universal registration document.

Extract from Universal registration document 2022 - Believe30

2

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

Other activities, at Group level or locally, support thisgender equity and parity approach:●●the fight against sexism and sexual harassment, inparticular through training and the Be FAIR(1) program, areminder of the “zero tolerance” policy, as well as theimplementation of the whistleblowing procedure(2);●free and inspiring exchanges with the women
members of the Executive Committee, as well as thementoring program(3);the promotion of career paths and their expertise, withprofiles published on the Careers website (https://careers.believe.com/en/), the Believe blog (https://www.believe.com/blog) and the Believe site.
2022

Indicator

2021

43%
% of women among employees(Target: 42%)% of women among managers(1)

37.6%

41%
34%

% of women in management teams(2)

42.9%

41.8%

% of women on the Executive Committee

50%

54%

% of women recruited

51%

45%

(1) The population of managers corresponds to internal categories from levels 5 to 12 (including management teams, for “Executive” and “Leaders” Career
Paths).
(2) The population of management teams corresponds to internal categories from levels 9 to 12 (including “Executive” and “Leaders” Career Paths) andrepresents 7.3% of positions with the highest responsibilities (see Section 4.1.3.2 “Diversity and gender equality policy” on page 158).

Indicator
Gender equality index(3)2023-2022

2022-2021

2021-20202019-20182018-201799/10099/10097/10090/10056/100(3) The French gender equality index (Law of September 5, 2018) comprises five indicators including gender pay gaps, differences in individual salary
increases, promotion differences, the percentage of women who benefited from a salary increase after their maternity leave and the representation of
women among the ten top salaries.

(1) See Section 2.4.5.3 “Training employees in the principles of diversity, equity and inclusion (DEI) and anti-discrimination: the Be FAIR program”,
page 33.
(2) See Section 2.3.3 “Setting up and publicizing the whistleblowing system”, page 23.
(3) See Section 2.4.6.3 “Implementing local activities promoting well-being and team spirit”, page 34.

31

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

2.4.5.2 Formalizing our commitment with the Diversity, Equity and Inclusion Charter
Believe has adopted a Diversity, Equity and Inclusion Charter for its employees. This charter was widely distributed to all
employees throughout 2021 via a dedicated communication campaign and the “Be FAIR” training program.
BELIEVE’S DIVERSITY & INCLUSION CHARTER IS BASED ON SIX MAJOR COMMITMENTS.

The principles of Believe'sDiversity & Inclusion Charter

Believe's DEI practices and actions

Ensuring equal opportunity within the recruitment, The recruitment process, career development and training
development and promotion processes.
systems have been designed to be objective, fair, and thus
avoid any discrimination.
Ensure fair compensation for equal work, performance Pay equity is guaranteed by a guide for the various positions
and skills.
and levels of responsibility with internal and external
compensation guidelines. In addition, compensation isreviewed at least once a year.
Raisingawarenessofunconscious
bias
anddiscrimination and educating employees about legal
implications to promote inclusive behavior in everyday
life.

Dedicated diversity and inclusion workshops were rolled out
in all countries in 2021 and 2022, supplemented by the Be
FAIR online training course (mandatory in the onboarding
program for newcomers since mid-2022).

Creating an environment where people can express A whistleblowing protocol to manage discrimination
themselves safely.
complaints has been implemented in 50 countries. For
Believe, it is essential that everyone feels safe, heard and,above all, accepted.
Encouraging employees to join ambassador communities 8.9% of employees around the world have formed local
in order to propose, promote and implement concrete ambassador groups organized around diversity andinitiatives in favor of Diversity, Equity and Inclusion.
inclusion topics and in favor of the planet.
Proposing, promoting and implementing concrete These actions have been rolled out for all employees, artists
initiatives for diversity and inclusion in the workplace and and partners regardless of their gender, ethnicity, religious
in the music industry.
beliefs, sexual orientation, disability, age and in all countries
where Believe operates.

Extract from Universal registration document 2022 - Believe32

2

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

Since 2021, Believe has set up an annual internal survey,Your Voice, with a significant module of questions on
employees' experience in terms of Diversity, Equity andInclusion and well-being at work.
The results obtained in December 2022 (with a response
rate of 78%) are a good illustration of the Group’s ability tocreate a diverse and inclusive environment.
●●

97.6% of respondents said: “I feel comfortablebeing myself at work”.
95.1% of respondents consider that: “Believe
facilitates the acceptance of people from different
origins and backgrounds”.

2.4.5.3 Training employees in theprinciples of diversity, equity
and inclusion, and antidiscrimination: the Be FAIR
program
Be FAIR is a specific Believe program in favor of diversity,
fairness and inclusion, deployed in all countries where theGroup operates.
This program was designed internally to help employees
develop more inclusive behaviors and inform them about
applicable legislation. From 2021, training was also
provided to recruitment teams and managers on theseprinciples of Diversity, Equity and Inclusion and possible
bias in recruitment. Available on Believe Academy, the Be
FAIR program is one of the mandatory training modules in
the onboarding process.
The main contents of the Be FAIR training modules are:●●●the principles of Diversity, Equity and Inclusion at
Believe and their implementation;
conscious or unconscious cultural biases, learning to
identify them and adapting your behavior to thesituation;
the fight against discrimination and harassment, andthe means to report any inappropriate behavior.

Group monitors all sensitive situations thanks to thewhistleblowing protocol and local human resources
teams. Believe also uses the results of the annual internalYour Voice survey to identify sensitive situations of
discrimination, harassment or inappropriate behavior, inorder to implement the necessary measures.

2.4.5.4 Employment and integrationof people with disabilities
The Group strives to contribute to the integration andmaintain the employability of people with disabilities.
However, it should be noted that the number of
employees with disabilities remains limited, in particular
due to the following challenges:●●●

a limited pool of candidates with the necessary skills
for the digital music industry;
specific regulations depending on the country, which
do not allow the implementation of a global indicator;
a reluctance of employees to report their disability. In
2022, only 0.33% of employees in France shared theirdisability with the HR department.

In France, a three-year disability plan was launched in
2020.
In November 2022, Believe made a strong commitment to
the European Week for the Employment of People with
Disabilities. The teams also took part in the Duo Day,
initiative to welcome people with disabilities for a day sothat they can discover Believe’s business lines. Awarenessraising activities were also offered to employees in France:
sign language courses, a conference on cognitive
disorders and the role of music, a tasting of food products
produced by specialized organizations, etc.
Whenever possible, the General Services Department alsofavors the use of companies in the protected worker
sector. This is notably the case for the maintenance ofgreen spaces on the terrace, and waste management in
the offices.

Believe regularly reiterates its desire to fight against all
forms of discrimination, sexism and harassment. The

2.4.6 Developing efficient working conditions, well-being
and mental healthBelieve intends to offer working conditions favorable to
the well-being of its employees in all countries. The
approach focuses, in particular, on the organization andworkingenvironment,
personalized
supportfor33

Extract from Universal registration document 2022 - Believe

employees, work-life balance and a social protection floor.
These elements are important for retaining employees
and attracting candidates.

www.believe.com

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

2.4.6.1 Ensuring a social protection
floor for all employees
Believe aims to offer its employees safety and protection,
so that they can work with confidence. The Group iscommitted to providing everyone with a good level ofprotection against health, disability and disability risks, inaddition to legal obligations and taking into account thesocio-economic environment of each country. For this, theGroup operates with the assistance of an external firm, toimplement the necessary measures in a harmonizedmanner adapted to the legal and socio-economic market
context.
Depending on the country, the Group may also
supplement certain employee benefit measures. For
example, in France, 100% of employees benefit fromadditional legal risk coverage in 2022, in line with market
practices. This practice has been gradually rolled out inother countries (Italy, Luxembourg, United States,
Germany, Singapore, etc.). In addition, Believe had offered– even before the entry into force of the French
regulations in July 2021 – one month of paid leave to all
second parents, regardless of their gender, for the birth or
adoption of a child.

2.4.6.2 Supporting employees in
the management of their workand their mental healthBelieve is attentive to the well-being and mental health of
its employees, to risky situations and to their work-lifebalance.
During the Covid-19 health crisis in 2020, Believe
partnered with the international care and quality of life atwork operator Eutelmed to provide psychological support
to employees. The Group has continued this partnershipto prevent psychosocial risks and support employees insituations of stress or workload.
Through this collaboration, employees benefit from online
conferences and workshops, documentation and advice
on stress and psychosocial risk management. Employees
can also self-assess their level of stress and anxiety
through an online test. Psychological help is available freeof charge 24/7. Finally, Believe finances consultations witha dedicated psychologist (3 to 5 hours per year) for
employees who feel the need. These measures arecovered financially by Believe and are managed by
Eutelmed in order to guarantee total confidentiality to theemployee.
On a daily basis, the local Human Resources teams
provide local support and personalized monitoring of
employees and managers. High-risk situations, such as
periods of more intense work or the taking on of new
functions, are supported by managers and humanresources teams in a proactive manner in most situations.

Since 2016, Believe has set up a program dedicated towell-being in France with a Shiatsu expert. Employees canbenefit from individualized 30-minute sessions, enablingthem to apply best practices in stress management andprevention, and physical and mental recovery.
In all countries, Believe offers a flexible work organization,
which promotes the commitment and performance ofteams, in compliance with local regulations. Given thestrong digital component of the Group’s activities,
teleworking is a tool popular with teams, who are used toworking remotely. The work tools available to employees
are designed for the organization of meetings and forcollaborative online work.
In this spirit, the agreement on teleworking signed in
December 2021 in France was renewed with thepossibility of two days of remote working per week.
Depending on the personal situation, Believe can offer aneven more flexible work organization.
In 2022, the absenteeism rate was 3%. This rate reflects
the relevance of the actions implemented to promote thewell-being and mental health of employees. In addition,
tertiary sector activities are less prone to absences related
to workplace accidents.
Indicator
Absenteeism rate

(1)

2022

2021

3%

2.04%

(1) Absence due to an accident or occupational illness, any other illness,or a family event during the period.

2.4.6.3 Implementing local activities
promoting well-being
and team spirit
Numerous initiatives are implemented locally to create an
inclusive, collaborative working environment conducive towell-being. These actions also contribute to developing ateam spirit, a sense of belonging to the Group andemployee satisfaction.
The local human resources, CSR and communication
teams organize these initiatives, in coordination with theambassadors network, which is a source of proposals.
For example, they initiated the “Pause” program at
Believe’s head office in France. Employees can take part insocial events (afterworks, artist showcases), discussions
and conferences on Believe’s various business lines,
atypical workshops (maintenance of plants on the terrace,nutrition courses, creation of bouquets of flowers, etc.).
The company canteen was also involved. It now offers
more varied (including vegetarian), balanced and seasonal
meals.
On the proposal of the Believe for People/Parity
ambassador network, a breastfeeding room and genderneutral toilets have been set up, as well as menstrual
protection provided free of charge.

Extract from Universal registration document 2022 - Believe34

2

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

Believe also promotes sports and solidarity practices, both
locally and globally.
In France, for example, a gym has been available since2022 and the Social and Economic Committee (SEC) offers
subscriptions to gyms and online training platforms at
negotiated prices.
Globally, Believe rolled out the SquadEasy app in 2022,
promoting walking, running and cycling as part of asolidarity and environmental challenge organized for all
Believe employees. Over one month, 440 employees
divided into 56 teams in 32 countries covered nearly
63,000 km on foot or by bicycle. They also took quizzes on

best environmental practices. The sharing of photos andcomments fostered a strong team spirit. The fun, sportingand solidarity dimension of the challenge was acclaimed,
and 92% of participants want to repeat the experience. At
the end of this operation, the Group undertook toparticipate in the financing of environmental andsolidarity projects at the global level and in the countriesof the first five winning teams.
Lastly, the activities as part of the solidarity month ofBelieve Tomorrow and the ambassadors program help tocreate moments of conviviality, team spirit and pride inbelonging to the Group(1).

2.4.7 Deploying a fair compensation system and sharing value
creation with employees
Believe pays particular attention to the overall
coordination of its compensation policy, based on internal
equity, performance and attractiveness. To this end, theGroup relies on structured and robust processes deployedin all countries.

2.4.7.1 Applying a fair, consistent andattractive compensation policy
Since 2020, the Group has used an internal business line
framework to structure compensation in a consistentmanner according to the position, level of responsibility
and skills. The guidelines establish a minimum, medianand maximum level of compensation for each job levelbased on Believe's and local market practices.
When a position is created, the process includes anassessment to determine its level of contribution.
Believe’s compensation policy is, therefore, based on thelevel of skills and contribution expected for a position. No
discrimination of any kind is applied.
Compensation is reviewed annually to recognize theperformance and contribution of each person while
ensuring that compensation is competitive with themarket. Each year, the Group participates incompensation surveys relevant to its sector of activity.
These benchmark data are used to update the internal
compensation grids. Where appropriate, “catch-up”
increases are applied, in particular to ensure equal
compensation for men and women.
The level of employee satisfaction on compensation ismonitored during career reviews (dedicated question) andthrough the internal Your Voice survey.

2.4.7.2 Setting up a first attractive andfair employee shareholding plan
Believe wants to involve its employees in the Group’s
development and value creation. In 2022, the Group set
up its first global employee shareholding plan, calledb.shares. Deployed in its six main countries (France,
Germany, United States, India, UK, China), it covers 80% of
the Group’s employees.
Believe offered a very advantageous scheme. This plan
was built according to its equity principles, in order tooffer as many employees as possible the possibility of
subscribing to it, for all income levels:●●●a maximum investment to ensure the consistency of
personal investment amounts and thus guarantee
equity between employees;
a matching incentive and threshold to promote accessto all eligible employees;
a 20% share price discount applied to the entire
investment.

The results were very satisfactory, with a subscription rateof 40% of eligible employees, including nearly 60% forFrance. These results demonstrate the commitment andinvolvement of employees as employee investors in theGroup’s future development.
From this first edition, the b.shares offering has made it
possible to achieve a Group-wide employee shareholding
rate of 31%. At end November 2022, employees held
directly or through the company mutual fund (FCPE)
Believe shares, 0.35% of the Company’s share capital, i.e. a
total of 334,999 shares(2).
The company savings plan was extended to the Groupand internationally as part of the b.shares shareholding
plan.

(1) See Section 2.5.2.4 “Supporting employee engagement with local communities”, page 43.
(2) See Section 7.3 “Shareholding”, page 317 in the Universal registration document.

35

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Employees at the heart of Believe’s business model and Shaping Music for Good

2.4.7.3 Sharing value creation with
employees: the commitmentof the Chairman and Chief
Executive Officer
In line with the Group’s values, Denis Ladegaillerie,
Chairman and Chief Executive Officer and founder ofBelieve, wished to implement a mechanism for sharing
the capital gains on the sale of his Believe shares with
employees in addition to employee shareholding.
This mechanism, provided for by the Pacte Law of May 22,
2019 on company growth and transformation, offers
Believe, under the leadership of Denis Ladegaillerie, theopportunity to strengthen the long-term commitment of
its employees and recognize everyone’s contribution to
the Company’s success. It offers the possibility of sharing
part of the value created collectively.

The sharing of capital gains takes the form of a contract
between Denis Ladegaillerie and Believe SA and is the
subject of a related-party agreement published on
December 7, 2022(1).
This agreement allows Denis Ladegaillerie, in the event ofa future sale of his Believe shares, over a long-termhorizon beyond three years, to share up to 10% of thecapital gains realized with the employees with over 2 years
of presence.
This system supports the deployment of employee
shareholding within the Group: the amounts paid will be
invested in the Group Company Savings plan and directed
as a priority to the Company Mutual Fund (Believe Shares)
invested in Believe shares.

2.4.8 Ensuring continuous dialogue with the teams and measuring
the level of commitment and satisfaction
High-quality social dialogue is an essential component ofBelieve’s model. It illustrates the Group’s desire to involve
employees in its development and fully reflects its valuesof respect, expertise, fairness and transparency. In eachcountry, the proximity and accessibility of managers andhuman resources teams enable employees to express any
concerns. The annual internal Your Voice survey also
makes it possible to collect expectations, feed into
discussions and adjust the Group’s actions (see below).
In addition, Believe has put in place a strategy, tools andinternal communication means, in order to share andmake accessible the necessary information for all
employees, in particular via global webcasts. During these
events, the Chairman and Chief Executive Officer andmembers of the Executive Committee present the Group’s
strategy and performance to all employees. They also
communicate via regular newsletters and an online
information platform called Believe Insider.
In France, Believe SA has a Social and Economic
Committee (SEC) since 2019, which replaces the Unique
Staff Representative Body (délégation unique du personnel –DUP). Regular and transparent dialogue allows for very
constructive discussions on all subjects affecting the life of
the Group and its employees.
Since the creation of the SEC, two collective agreements
have been signed in France, on employee profit-sharing
and teleworking.
A staff representative body is also in place in Luxembourg.

The Group gives all employees the opportunity to give
their opinion and their feelings during the annualinternal Your Voice survey. This social barometer iscarried out on a voluntary, anonymous and confidential
basis. The detailed questionnaire measures the various
dimensions of employee engagement and satisfaction
worldwide. Set up in 2021, these surveys are an important
steering and management tool for measuring progress
and implementing action plans specific to the various
departments and countries.
Renewed in December 2022, the Your Voice questionnaire
covers the following topics in particular:
●

●

●

●

●

●

●

●

employee satisfaction and development, working
conditions;relationship with their manager, putting the Group’s
values into practice;employees’ understanding of the strategy and a senseof contributing to the Group’s success;careerdevelopment
opportunities;

andskillsdevelopment

Diversity, Equity and Inclusion, experience
discrimination or inappropriate behavior;ofrecognition of work carried out, satisfaction withcompensation;knowledge and implementation of the Shaping Musicfor Good ambition;
Believe’s level of recommendation as an employer.

(1) See Section 4.1.4.6 “Related-party agreements and valuation procedure for current agreements” on page 159 in the Universal registration document.

Extract from Universal registration document 2022 - Believe36

2

Corporate social responsibility
A committed player serving artists and labels, and local communities

The response rate in December 2022 increased
significantly, which makes it possible to obtain relevant
and representative results. The results are then sharedwith managers and all employees. Action plans will bedefined and implemented in 2023 within each entity andcountry in cooperation with the teams.

2.5

Indicator
Internal Your voice survey
response rate

2022

2021
60% inMarch 2021

78%

63% inDecember2021

A committed player serving artists andlabels, and local communities

Aligned with its Shaping Music for Good ambition, Believe’s
mission is to best serve local artists and labels at all stagesof their development in the digital ecosystem with
fairness, expertise, respect and transparency.They
assessed their talent, their market potential and their way
of interacting with local communities.
The Group is driven by strong convictions about the futureof the music industry and its role in serving artists andlabels. In more than 50 countries, Believe offers local
teams who are experts in their field. They share its visionof a more diverse and inclusive music industry andcontribute to the life of local communities.

Its policies and action plans aim to:
●
●

●

●
●

consider each artist as different and unique;serve as a priority local and independent artists andlabels;put all the opportunities of digital development at theservice of artists;build relationships of trust by sharing our values;
build unique partnerships with digital service providers
for artists and labels.

2.5.1 Nurturing relationships of trust and supporting creativity
with our artists and labels, and our stakeholders
Thanks to its local teams and its digital solutions, Believe
now supports more than one million artists around theworld directly or via their labels, with an offering adapted
to the needs of each artist and label, according to theirstage of development. The Group offers them a wide
range of services based on cutting-edge technologies,
local experts and unique partnerships with digital service
providers.
The objective is to:●●enable each artist to learn and master all the
specificities of the digital music market;

artists from different communities and representing
diverse music styles to make their voices heard andcontribute to a diverse and inclusive world. With thisconviction, Believe is committed to promoting access tothe digital music market for all types of local artists,
especially female artists and under-represented styles,
and to helping them develop their talents.
Believe’s commitment to a responsible, diverse andinclusive music industry is reflected in:●create new opportunities for the emergence of local
artists and all music genres.
●2.5.1.1 Promoting diverse and local
music through access to thedigital market
Music reflects the changes in societies and contributes tothe richness and cultural heritage of the world. It enables●

an effective, targeted dissemination policy whichenables artists and labels to step up their exposureand monetize their creation, whatever the stage of
their career development;a fair compensation policy that respects the sharing ofvalue with the artist according to the levels of careerdevelopment and services used by the artists andlabels(1);local teams, that are experts in their area, serving
artists located directly in the main cities and regions formusic production;(1) See Section 2.5.1.6 “Distributing value fairly and transparently with artists and labels” on page 41 in this extract, as well as Section 1.2.4.2“Believe provides digital go-to-market solutions for all music artists, from music creators to top artists” on page 21 in the Universal registration
document.

37

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
A committed player serving artists and labels, and local communities●

a local recruitment program for artists and training
initiatives for artists and labels to support them in theirdevelopment.

The Group invests in markets where the penetration rateof streaming is still low. Through digitization, Believe
makes new music catalogs available on platforms, which
would otherwise risk disappearing in the long term. It thus
promotes the preservation and transmission of the local
musical heritage.
“When we expand into a new market in Asia, forexample, we set up a local team, recruiting local experts
in the music industry. Through this proximity, theseexperts understand the culture, local specificities andtrends, and ensure a better approach with artists andlabels."Sylvain Delange, Chief Executive Officer Asia-Pacific.
“In Africa, many artists did not have the means to
distribute their music on the Internet. Today, thanks tosocial networks, such as TikTok, the musical works ofthese artists can go viral overnight. Believe offers them asupport solution, in order to give them all the keys tounderstanding the various digital diffusion platforms.
Thus, many artists from the African continent have been
supported by Believe”.

2.5.1.2 Developing unique partnerships
with local digital service
providers
Believe strengthens its relationships with major local andglobal music, social media and entertainment platforms
every day. The ability to develop partnership relationships
with these platforms is key to ensuring the distribution,
promotion and visibility of local artists. Today, Believe hasover 150 partners from global and local platforms, and ispresent in 50 countries. These platforms cover a fairly
broad spectrum, from the largest industry-players to small
start-ups.
The quality and reliability of the partnerships establishedwith the platforms are at the heart of the Group’s
development model. They are a guarantee of innovation,
responsible risk management and protection of artists.
Believe has implemented a rigorous process to assess andselect digital service providers based on three main
criteria:●●

Andreea Gleeson, Chief Executive Officer of TuneCore

Examples of local initiatives serving musical
heritage
●

●

●

●

In 2022, TuneCore funded a grant in India to support
the career of an up-and-coming Indian artist. This artist
was selected by a jury made up of 8 local musicindustry experts. They assessed their talent, theirmarket potential and their way of interacting with local
communities. The event showcased the 160 Indian
artists who took part in the competition.
In 2021 and 2022, Believe's Indian subsidiary partneredwith the Snehadhara Foundation and the Vasu Dixit
musical Collective to develop the PaDa project, a 5 partmusic docu-series to support India's folk music
traditions.
Believe has co-created the BEAMS (Believe for
Educational Advancement through Music Scholarship)program in India to support young talents fromdisadvantaged backgrounds. Since the launch of the
program two years ago, more than 4,000 young people
in 25 institutions have received financial support andbenefited from certifying training and advice to launch
their careers in music.
In Thailand, The Youth Music Incubator program aims
to educate young people about digital music industry.
The program was initally launched during Believe
Tomorrow 2021 and an album of 8 songs was released.
The same initiative was carried forward during Believe
Tomorrow 2022, during which the 6 beneficiaries of the
program performed live.

●

interest for the artist: potential audience, potential
revenue and competitive advantage;
the reliability of the platform: financial robustness,seniority, potential for development, profile ofmanagers, corruption risks, illicit activities or financial
irregularities;
digital security: digital quality relating to content
security processes and protection against fraudulent
content (streaming). The contracts include content
protection clauses against fraudulent distribution andserver attacks, as well as clauses on technical quality
standards in line with Believe’s requirements.

The Group assesses the level and progress made by themain platforms with regard to these three criteria,
through quarterly and/or half-yearly reviews. A dashboard
summarizes these assessments.
Believe is also developing highly innovative partnerships
with the most recognized platforms, such as Spotify, AppleMusic, YouTube, TikTok, etc. The Group thus enables its
artists and labels to benefit from its capacity forpartnership and innovation to increase their visibility,
audience and monetization.

2.5.1.3 Being at the cutting-edge oftechnology and innovations
for artists and labels
Digital technology and practices on social networks andplatforms are constantly evolving. As a result, Believe isparticularly attentive to the latest innovations andtechnical and regulatory developments in the market. This
ongoing monitoring work enables it to:●●

anticipate opportunities and threats;
and adapt its range of services and technologicalsolutions.

Extract from Universal registration document 2022 - Believe38

2

Corporate social responsibility
A committed player serving artists and labels, and local communities

Innovation and the deployment of the most current andrelevant technologies are carried out in partnership withleading platforms. They contribute to the sustainability ofBelieve’s activities, as well as those of artists and labels.
The Group’s ability to maintain an attractive anddifferentiating technological offer for artists and labels is
one of the Group’s main risk factors(1).
In 2022, Believe continued to develop its offerings thanks
to the partnerships set up in 2021 with globally recognized
platforms – such as Spotify, Apple Music TikTok andYouTube. They allow artists to better exploit digitalmarketing capabilities in order to be more visible. This
increases their ability to monetize their music, including
for emerging creators and artists(2).

In 2010, Believe developed Backstage, a global distribution
software for artists and labels available as part ofPremium Solutions.
Via the Backstage platform, Believe provides artists andlabels with functionalities, content and services to help
them manage their digital careers:●●

Some examples of innovations:●●●

Believe has invested in a data platform and digitalmarketing solutions specifically for the titles included in
Discovery Mode. This allows independent artists tobroaden their audience and find their next fans by
optimizing the discovery of their titles, particularly on
Spotify;
the Believe teams have developed an algorithm topredict the virality of a piece of music on the TikTokplatform. Believe uses this data to inform artists andlabels of existing and emerging opportunities, and to
implement optimal digital strategies to develop theiraudience;●

Believe has always put the development of artists at thecenter of its missions through personalized support andtraining. This is what makes the Group so unique: it offers
training, information and support programs that enableartists to learn, understand and reinforce their autonomy
to use their digital environment and their talents to theirbest advantage.

tools for promoting their content on social platforms
and networks (visuals for social networks, notifications,direct alerts to fans, etc.). Artists and labels can manage
communication campaigns on social networks directlyfrom the Promotion Section of Backstage;
unique educational content and training programs
aimed at increasing artists’ expertise in digitalmarketing and making them increasingly autonomousand independent. New certifying training courses andcontent have been added to the Backstage Certification
Program in 2022 such as: Growing audience on streaming
platforms, or Produce stylish creative assets to promote
your releases on all social media platforms.

Believe offers two main training programs for artists,labels, and music creators:●

as part of the launch of the YouTube Shorts platform in
2021, Believe invested and developed functionalities tooffer new monetization opportunities to artists. This
allows artists to share short videos made with a mobile
phone with their communities. In 2022, thispartnership was strengthened as part of the Creator
Music initiative, which makes it easier to monetize themusic of creators, and to position Believe as one ofYouTube’s leading partners.

2.5.1.4 Training artists and labels indigital technology and career
management

statistics and analysis of the performance of online
songs and revenues generated by listening. For
example, Backstage is the only platform for artists totrack the performance of their songs on TikTok;●

Artist Resources is a training program for artists andlabels as part of Premium Solutions. Launched in 2021
and enriched in 2022, it includes more than 250 articles
written by Believe experts. These articles, in the formof tutorials, provide an understanding of the use ofsocial networks and video platforms, streaming,
optimization of sales processes, etc. The training
provided may be validated by certifications. 36% ofartists with a Backstage account use Artist Resources,
and more than a third of them obtained one of the twocertifications available (Social Networks and Streaming
Platforms) since the launch of the offer;
TuneCore Rewards is a training program for music
creators. Launched in 2021, it covers a wide range ofthemes, such as social media, release planning andmusic promotion on the Internet. Structured into
several levels, it offers, inter alia, educational videos
produced by experts in the sector allowing artists to
get familiar with best industry practices. At the end ofeach level of training, artists receive bonuses anddiscounts, before obtaining a VIP status, allowing them
to become increasingly expert and independent.

(1) See Section 3.1.2 “Risks related to the Group's business”, page 116 in the Universal registration document.
(2) See Section 1.2.4.3 “Believe provides artists and labels with the tools and expertise they need to grow”, page 23 in the Universal registration
document.

39

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
A committed player serving artists and labels, and local communities"Believe's tools and training help artists to better
manage their development and their fans. Whether on
advertising optimization platforms or social networks,
the approach is to constantly develop the profile ofartists to enable them to set up a complete digitalpresence. At the local level, promotion mainly takes
place through social networks. Then, the work topromote artists on advertising optimization platforms
ensures the migration of subscribers to musicalstreaming platforms”.
Céline Hitti, Head of Editorial Partnerships
and marketing for the MENA region.

2.5.1.5 Respecting the creative
independence and data
privacy of artists
Believe is committed every day to defending thefundamental rights of its artists and labels. The Groupencourages and protects the creative independence andfreedom of expression of its artists. It ensures that theirdata is respected and protected.

Respecting the data privacy of artists
and labels, and employees
Respecting the data privacy of artists and labels is a crucial
issue for Believe.(1) The Group has implemented
measures to protect the data privacy of artists, labels andmusic creators, as well as that of employees.
The main data protection measures deployed at Believe
are as follows:
●

●

●

●

Respecting creative independence
and freedom of expression
Believe is convinced that artists must own their art andremain free to make their artistic choices, in total
independence. The Group also ensures the delicate
balance between freedom of expression and compliancewith applicable laws.
In the event of controversy over content produced and/or
distributed by Believe, the Group investigates and ensuresthat local laws and platform guidelines have been
complied with. If the content has violated a law, it isimmediately removed from the platforms in the relevant
territory(ies); this withdrawal may be the result of theplatforms themselves or Believe.
If the infringement of the law is not obvious, or if thecontent is sensitive without violating an applicable law,discussions with the artist may be necessary. They make itpossible to clarify the artist's intentions, explain the legal
texts and adjust the communication concerning thissensitive content.
The Group’s primary approach is not to remove or modify
the texts or music, but to educate and engage in dialogues
with artists and the general public.
“We place a special focus on compliance with theregulations of the various sales platforms. We explain to
our artists the importance of following the rules, and therisks and consequences for their careers. We maintaindialogue with our artists to empower them.”●●a privacy policy and a policy on the management ofcookies are available in 15 languages and are updated
on a regular basis;a team within the Technology Department ensures theprotection of personal data processed by Believe. The
Group has organized a network of data protection
officers;
the Group has set up a register of personal dataprocessing. It makes it possible to identify when a dataprotection impact assessment (PIA or Privacy Impact
Assessment) is necessary. This register is based on asolution published by a specialized third party;
This PIA impact assessment tool ensures that data isprocessed in accordance with the General Data
Protection Regulation (GDPR) and respectful of privacy.
Particular attention is paid to the processing ofsensitive data (origin, nationality, religion, biometricdata, etc.) and in the case of high risk for the rights andfreedoms of the persons concerned. This tool is
included in the data processing register. It makes it
possible to complete a questionnaire for sensitive dataand proposes remediation recommendations if
necessary;an intranet module dedicated to compliance andincluding a “personal data protection” Section withpress articles, procedures and templates, is madeavailable to employees;
the onboarding program includes compliance,
cybersecurity and data protection training modules.
These modules are reviewed throughout theemployee’s career.

Believe also works closely with some of the mostimportant global platforms to protect artists data. With
them, the Group develops solutions that offer artists theoption of sharing their information or not. Believe has
established due diligence procedures and quarterly
reviews to assess platforms on a set of criteria, including
data security(2).

Claire Weill, Chief Legal Officer Deputy(1) See Section 1.3.2.5 “Personal data regulation” on page 32 and Section 3.1.2 “Risks related to the Group's business”, page 116 in the Universal
registration document.
(2) See Section 2.5.1.2 “Developing unique and innovative partnerships with local digital platforms”, page 38.

Extract from Universal registration document 2022 - Believe40

2

Corporate social responsibility
A committed player serving artists and labels, and local communities

2.5.1.6 Distributing value fairly andtransparently with artists
and labels
Since its creation, Believe has aimed to build and develop
relationships of trust with artists and labels. This calls for afair distribution of value with artists and labels undersimple and clear contracts.(1)These values of fairness and transparency form the basisof the remuneration system for artists proposed by theGroup as part of its Premium Solutions. The contracts that
Believe signs with its artists and labels are consistent withmarket standards or superior to these practices. The
Group offers more favorable clauses, such as the absenceof rebates, much shorter periods of exclusivity for new
albums at the end of the contract, or non-exclusivity on
featuring(2).
Almost all artists can thus access information concerning
their remuneration, their content as well as all data
relating to their relationship with Believe, via theinterfaces offered by the Group. These simple andeducational interfaces are a differentiating element ofBelieve. Artists can consult their data and analyze it
independently.
With TuneCore, Believe provides music creators withsolutions tailored to the level of their career development.
They choose the level of service they wish, withtransparent pricing.

2.5.2 Leading change in the music industry and developinga culture of engagement with local communities
Believe is committed to using its technology and expertiseto serve a diverse, inclusive and responsible musicindustry. This ambition has been integrated into its
business model since its creation and in line with its
Shaping Music for Good ambition. The Group engages thevarious players in this industry, artists and labels and its
employees, on themes that are close to its heart, such as
diversity, equity and inclusion, the promotion of women,
education through music and respect for theenvironment.

2.5.2.1 Sharing its expertise with theartistic community and themusic industry
Believe is very active in the music community. The Groupparticipates in or creates events and conferences to shareits know-how and its commitment to a more diverse andinclusive music industry.
Some initiatives and events illustrate the “educational”
role of Believe with artists and labels:●

Since 2019, the Group has organized Believe Days.
These “educational” days are dedicated to a digital
theme. Believe invites artists, labels, competitors anddigital platforms. They were initially held in Asia andare now expanding in Eastern Europe and Latin
America. These days are an opportunity to help artists
better master digital technology;●●

In 2021 and 2022, Believe took part in the Music Matters
Academy event in Singapore. Various Group experts
took part in training sessions, particularly on thesubject of diversity (Diversity matters). This online
academy recorded more than 750 registrations. The
videos of these sessions, made available online free ofcharge, totaled more than 20,000 views during the firstweek of their publication;
at Midem Digital 2021 (international music industry
event), Denis Ladegaillerie, Chairman and Chief
Executive Officer and Founder of Believe, shared his
vision for an innovative, fair and inclusive musicindustry. He also commented on the role andcontribution of artists and labels to the new economy
of creativity.

2.5.2.2 Spotlighting and promoting
women and under-represented
communities in the musicindustry
As part of its commitment to Diversity, Equity andInclusion and gender parity, Believe pays particularattention to the promotion of women and underrepresented communities, as artists and more broadly
within the music industry.
Believe supports globally recognized initiatives – such as
Be the Change, Keychange, Women in Music and more
local actions to support and train women artists in theirmusical careers.

(1) See Section 1.2 “Overview of the Group’s activities” on page 11 in the Universal registration document, and Section 2.3 “An ethics anddeontological system as close as possible to employees, artists and labels”, page 22 in this extract.
(2) Featuring consists of singing a song in duet with another singer. This practice revives the general public’s interest in the title.

41

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
A committed player serving artists and labels, and local communities

Believe supports major international
initiatives in favor of Diversity, Equity
and Inclusion●

Be the Change study: Since 2020, Believe and its
subsidiary TuneCore have partnered with recognizedpartners to conduct the global Be the Change study.
This annual survey helps to understand thediscrimination and obstacles faced by women andunder-represented communities in the music industry.
Believe strives to engage the various players in theindustry to implement the action levers identified to
attract and promote women artists. The challenge is to
manage to generate access to composition and music
production. To that end, Believe widely disseminates
the findings of the study.

●●

Keychange: Since 2021, Believe has also been asignatory of the Keychange initiative, a globalorganization working for equity in the music industry
and talent development. Andreea Gleeson, Chief
Executive Officer of TuneCore, is an ambassador for
Keychange and actively contributes to its developmentin the United States.
Women in Music: Believe, through its subsidiary
TuneCore, is a partner of Women in Music. This
organization supports women artists through numerous
initiatives and events organized in the United States andaround the world. Believe and TuneCore employees are
members of this organization.

Be the change survey: women and minorities making music
The study carried out in 2021 conducted on the independent artist sector by Believe/TuneCore and MIDiA Researchhighlighted the challenges and experiences of 486 women creators worldwide. The results of this 2nd edition illustrate
the immense room for improvement:●

61% of the women in this panel were subject to harassment or inappropriate behavior, and 45% felt pressure to
give up their music careers;●

68% doubt their own capabilities, are victims of the “impostor syndrome” and lack confidence;●

35% have experienced criticism or abuse on social networks;●

on the other hand, 40% of the women questioned noted an improvement in the presence of women at events orconferences.

The entire Be The Change: Women Making Music 2022 study is available on the MIDiA website: https://www.believe.com/sites/believe/files/2022-05/Be-The-Change-x-2022-Women-in-Music.pdf.
For the third Be the Change study in 2023, Believe and TuneCore have partnered with Luminate(1) to understandgender inequality and the experiences of women and under-represented communities in the music industry. The
survey was completed at the end of 2022 in 13 languages (English, French, Spanish, Dutch, Turkish, Indonesian,Portuguese, Japanese, German, Swahili, Mandarin, Korean and Thai).
The results were published in March 2023 and are available here.
Some figures illustrating some of the challenges facing the music industry:●●●

53% of music industry professionals in this panel say that men are better paid than people in other genres;
66% of respondents said they would like to see more women and people from under-represented communities inpositions of responsibility in the industry;
70% of artists from under-represented communities in this panel say they are subject to harassment on social
media.

Believe’s local teams are also committed
to female or minority artists●

Some examples in 2022:●

Believe and TuneCore Italy organized a music
composition
andsong-writing camp in an exceptional site near
Florence, in partnership with Spotify and Equaly(2). The“Believe ME” experience enabled nine Italian female
artists to be surrounded by experts to better exploit
their talent as songwriters;●

Believe and TuneCore supported Keychange Europe
for the organization of master classes, training sessions
and workshops on the topic of gender equality, as partof the Reeperbahn music festival in Germany;in France, Believe and TuneCore renewed theirpartnership with “Rappeuses en Liberté”, a support andtraining program for the 10 finalists and 3 winners.
Believe experts give personalized advice to increase thedigital visibility of these artists and their positioning onsocial networks. TuneCore also offers a one-year
subscription for the distribution of their music;(1) Luminate is an organization recognized worldwide for its commitment to under-represented communities. It works to strengthen theirinformation, rights and powers over the factors that affect their lives.
(2) Equaly is a community of Italian music professionals who share the ambition to develop a fair and inclusive industry.

Extract from Universal registration document 2022 - Believe

42

2
●

Corporate social responsibility
A committed player serving artists and labels, and local communities

to celebrate International Women's Day in March 2022,
Believe showcased female employees and artists on its
Instagram site. These new content and videos
garnered a significant level of engagement (up to
13,000 impressions per video).

Andreea Gleeson, Chief Executive Officer
of TuneCore, actively contributes
to the development and emergenceof female creators
Thanks to the continued commitment of Andreea
Gleeson, Chief Executive Officer of TuneCore, and herteams, the number of women artists at TuneCore has
increased significantly since 2020 to reach 42% in 2021.
On average, women artists represent only 12% worldwide.
The use of TuneCore enables women artists, especially
young women, to produce and distribute their music
without being confronted with a discriminatory or
disrespectful environment, such as recording studios orconcerts.
In 2022, Andreea Gleeson received the International
Woman of the Year award as part of the Women In MusicAwards 2022.
“Women do not want to be treated differently. They wantto have access to the same resources and opportunities
as their male counterparts. In the music industry, it is an
ongoing fight to give confidence to women artists, givethem access to resources and make them visible andrespected throughout their careers”.
Andreea Gleeson, Chief Executive Officer of TuneCore

2.5.2.3 Promoting music as a vehicle
for committed messages andresponsible practices
Music is both a reflection of its time and a powerful toolfor conveying committed messages reaching a very large
audience. This is why the Group intends to take advantage
of its role in the music and digital industry to amplify thesocial and environmental commitment of its artists andlabels.
In France, Believe supports committed artists and labels,
sharing the same desire to promote diversity and fightagainst discrimination:●●in 2022 Believe committed itself alongside the Frenchartist Jeanne Added to the fight against all forms of
discrimination, by including a bilateral clause on ethicalbehavior in its contract. This clause, which engages
both the artist and Believe, is unprecedented in themusic industry in France. It formalizes the joint fight ofJeanne Added and Believe against all forms of
discrimination;
Believe also actively supports the singer Yseult in her
fight against racism and body shaming. Believe’s teams
support and advise her on her image, promotion andmarketing strategy;●

since 2021, Believe and its naïve label have supported
the Listen & Donate initiative carried by the hip hop
artist Pone, founder of the group Fonky Family, to raise
funds for the Trakadom association. Suffering from
Charcot’s disease, Pone mixed the music for the closing
ceremony of the Olympic Games in 2020 using eyetracking software. With Believe, this artist fights against
prejudice related to disability.

2.5.2.4 Supporting employee
engagement with local
communities
As part of the deployment of Shaping Music for Good,
Believe asks its employees to propose and lead initiatives
in two areas:●●

make a positive impact on local communities;
and promote the Group’s values, both internally andwith the music industry.

Since 2021, Believe has set up the Believe Tomorrowprogram. This brings together employees around civic andsolidarity activities that are close to their heart and in linewith the priorities of Shaping Music for Good. On a
voluntary basis, employees can contribute and participate
in activities organized by the Human Resources and CSR
teams and the ambassador network(1). The aim is to raise
employee awareness on Believe’s CSR commitments andencourage their implementation through concrete
actions, notably serving local communities.
Following the first edition of Believe Tomorrow Day
launched in 2021, the Group decided to extend theprogram to one month in 2022 with local activities and a
global solidarity challenge. In 2022, nearly 1,200
participants in 32 countries contributed to the success ofBelieve Tomorrow, in cooperation with external
stakeholders, charities, local partners, and through the
SquadEasy app.
Nearly 60 local activities took place supporting the threemajor dimensions of Shaping Music for Good:●

Diversity, Equity and Inclusion;●education through music;●

respect for the environment.

A global solidarity challenge, carried out via the SquadEasy
app brought together 56 teams, i.e. 440 participants,
committed to walking, running and cycling in order toreach the target of 50,000 km in one month. Believecommitted to financing solidarity and environmental
projects at Group and local level for the five winningteams.
Beyond the civic and solidarity commitment that Believe
Tomorrow represents, this month of sharing also creates astrong sense of pride in the teams, cohesion and a senseof belonging to the Group, thus contributing to employee
commitment and loyalty.

(1) See Section 2.1.3.3 “A global network of committed ambassadors”, page 11.

43

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
A committed player serving artists and labels, and local communities

Examples of initiatives in 2022
These examples illustrate the strong commitment of theGroup and its employees to the Shaping Music for Goodambition. The Believe for People/Parity and Believe forPlanet ambassadors as well as the participants in Believe
Tomorrow contributed to initiatives in favor of local
communities in many countries where the Group
operates.

●●●

Promoting diversity, inclusion andeducation through music●●●

In Brazil, the Afro lab, an intensive three-day seminarfor black artists from disadvantaged neighborhoods
was organized in collaboration with the Casa Preta
association in Sao Paolo and Bahia. Believe and
TuneCore experts trained and advised 60 artists on
their music projects. The Group has also undertaken to
distribute them and provide them with the Believe and
TuneCore platforms and tools.
In the United States, TuneCore gives the Notes for
Notes association free access to the master classes
available on the platform. TuneCore employees also
shared their expertise with disadvantaged young
artists supported by this association, which provides
them with musical instruments and recording studios.
In Canada, on the proposal of the ambassadors,
Believe funds a scholarship as part of the Accelerate
Scholarship program at MusiCounts, a charity dedicatedto music education. The beneficiary receives ascholarship and mentorship to support their musicalcareer. During Believe Tomorrow, Believe experts also
supported seven high school students selected by
MusiCounts on the topics of digital music distribution.

In India, Luxembourg and Turkey, 26 employees took
part in the recording of an educational audio book forvisually impaired students from disadvantaged
backgrounds, in collaboration with the WE4YOU
association, based in India.
In Germany, Believe is involved in the Hanseatic Helpproject to provide assistance to people in need and to
refugees.
In France, a week was dedicated to disability issues atwork. Events and activities highlighted the employees
concerned and partnerships with associations (ESAT).
Employees organized a visit to the Cité de la Musiquewith a group of disadvantaged young people. A
mentoring program has been set up for young people
from disadvantaged neighborhoods.

In favor of the environment
●

●

●

●

In France, a Tech Talk on the digital footprint wasorganized with a digital sobriety expert. Employees also
took part in climate and digital fresco workshops. They
reflected on very practical solutions to be
implemented within the Group to reduce theenvironmental impact.
In Mexico, the ambassadors organized a garbage
collection and tree plantation at a historic site in
Mexico City, contributing to the restoration andprotection of the site’s biodiversity.
In China, employees' cardboard waste was collected
and reused by Chinese sculptor ZHANG Xiangxi. His
work will raise awareness of recycling among thegeneral public.
In several countries around the world, Believe hasorganized beach clean-up days (in Australia, Taiwan
and China) and natural site clean-up days (in Germany,
China).

Extract from Universal registration document 2022 - Believe44

2

Corporate social responsibility
Actions on the ground in favor of the environment

2.6

Actions on the ground in favorof the environment

Believe is aware of the role it must play in the fight against
climate change and the protection of the environment.
As a player in the digital and music sectors, Believe’s
impacts on the planet take on several dimensions. In linewith its Shaping Music for Good ambition, the Group intends
to play its role as a responsible company by gradually
approaching them using two complementary approaches:●●measuring the direct and indirect impact of activities,
defining and managing a long-term environmental
policy;using the influential power of music, in particularthrough artists and labels, to change the behavior of
employees and various players in the industry.

2.6.1 Formalizing the environmental approach
Believe’s environmental approach is managed by the CSR
Department and reviewed by the Board of Directors' CSR
Committee. It defines the policies and action plans to berolled out within the Group.
The approach is based on Group indicators, which are
structured and enhanced each year. The measurement
scope is also broadened in order to match the financial
scope as closely as possible. It gradually takes into
account the more recently acquired entities.
Environmental reporting aims to:●●report to management and stakeholders on Believe’s
environmental performance;
manage the policies and action plans implemented anddefine objectives.

The CSR teams work closely with the human resourcesand general services teams to monitor buildings. The IT,
merchandising and distribution teams contribute to theother dimensions. The Believe for Planet ambassadors are

45

Extract from Universal registration document 2022 - Believealso called upon and involved to make progress in thecommitment to the environment.

2.6.1.1 Measuring to better understandBelieve’s carbon andenvironmental impact
In 2021, the Group carried out an initial carbon footprint
assessement based on 2020 data of its direct (scopes 1
and 2) and indirect (scope 3) activities. This assessment
was carried out by EcoAct (Atos Group) according to the
GHG
Protocolinternational
carbonaccounting
methodology. It assesses the sources of greenhouse gas
emissions in the various scopes. This first stage made it
possible to better understand the various carbon impacts
and levers available to Believe in the short and long term,
both directly and indirectly.

www.believe.com

Corporate social responsibility
Actions on the ground in favor of the environment

FIRST MAPPING OF THE CARBON IMPACT OF BELIEVE’S ACTIVITIES ACROSS THE THREE SCOPES (SCOPE 1, 2 AND 3)●

Scopes1 and 2●●●

Scope 3●●●

Offices and buildings: energy used for electricity, heating and air conditioning, and the operation of IT
equipment, as well as refrigerants. Buildings are the main source of greenhouse gas emissions forBelieve’s direct activities.
Company vehicles, in limited numbers. Believe does not have a vehicle fleet, and has 51 company
vehicles.
Transport: employee commuting, business trips for employees and artists, transport of merchandisingproducts or equipment for events.
Waste from the use of cardboard, paper, packaging, etc., in offices or for activities with artists (events,
promotional campaigns).
IT equipment (computers, screens, printers, etc.).
Data centers and cloud services. They host the technological platforms of Backstage and TuneCore, andthe data of Believe and the artists and labels used for Premium Solutions & Automated Solutions.
Streaming: the distribution of audio and video files on digital platforms and the use by the end-user ofmusic.

The annual reporting set up in 2021 and enhanced in 2022
extended the scope on which the Group’s scopes 1 and 2
GHG emissions are assessed, notably with the inclusion oflegal entities based in Turkey (DMC and NetD), in Japan(TuneCore Japan), and in France (6&7 and Jo&Co). New
indicators and data collection procedures were also added
in 2022.
This environmental reporting will make it possible to carryout a more detailed analysis of emission factors and to
define an action plan and reduction targets for scopes
1 and 2.
Within the indirect scope (scope 3), the activities of data
centers and streaming significantly represent the largest
share of the indirect carbon impact of Believe’s activities.
Nevertheless, the quantification and analysis of scope 3
Indicator

still need to be refined. The collection of data in this scopeis very complex, particularly for streaming. In addition,
Believe has no direct leverage on these emission sources.
In 2023, Believe will continue to analyze this indirectscope, in particular for emissions related to data centers,
IT equipment and transport.
GHG emissions on scopes 1 and 2 decreased by nearly
19% between 2021 and 2022. This improvement is due tothe use of renewable energy not recorded in 2021 for thehead office located in France, Believe’s main site. In
addition, the more precise reporting made it possible tobetter record the actual consumption of energy andrefrigerants, which in some cases had to be overestimatedin 2021.

2022

2021

Emissions in tons of CO2 equivalent for scope 1

306.18448.95Emissions in tons of CO2 equivalent for scope 2

401.86422.12Emissions in tons of CO2 equivalent for scopes 1 and 2

708.04871.07

Emissions in tons of CO2 equivalent for scope 3 – Transport

235.50-All the environmental indicators monitored by Believe are available in Section 2.7 “Methodological note and summary ofindicators”, page 55.

Extract from Universal registration document 2022 - Believe46

2

Corporate social responsibility
Actions on the ground in favor of the environment

2.6.1.2 Applying the principles of the“green taxonomy” to measureits contribution to the European
Union’s climate objectives
In 2021, Believe carried out a first assessment of theeligibility of its activities for the climate objectives
according to the criteria defined by the European green
taxonomy standard. This aims to identify and promoteeconomic activities that contribute significantly toadaptation and the fight against climate change.
In 2022, the Group reviewed this eligibility assessment interms of revenue, investments and operating expenses.
The analysis was completed to reflect the alignment ofactivities with the climate objectives of this framework.
In addition to the production of taxonomy indicators, theGroup’s commitment to the fight against climate change
and the preservation of resources is reflected in theimplementation of actions to reduce the carbon impact ofits direct activities.
Drawing on its environmental, social and societal
commitments, Believe fully supports the European
Commission in its work to guide the investments of public
and private players in projects contributing to thetransition towards a sustainable and low-carbon
economy. This is notably the case in the context of theimplementation of the Shaping Music for Good strategy
and the Believe for Planet ambassador program. Targeted
actions are gradually being rolled out to achieve theGroup’s sustainable development and environmental
objectives (see Section 2.6 “Actions on the ground in favor of
the environment” on page 86).
The Group also applies the principles of the “green
taxonomy” to measure its contribution to theenvironmental objectives of the European Union. Indeed,
the Taxonomy requires companies to publish the sharesof their revenues, capital expenditure and operating
expenses that contribute substantially to one of thefollowing six environmental objectives: climate change
mitigation, adaptation to climate change, protection andsustainable use of water and marine resources, transition
to a circular economy, pollution prevention and control,
and protection and restoration of biodiversity andecosystems. To date, the technical assessment criteria
address the substantial contribution for the first two
objectives only.

Methodology for the technical assessmentof activities
A detailed analysis of all of Believe’s activities within thevarious consolidated entities was carried out jointly by the

Finance and CSR Departments, as well as with theoperational teams. The identification of eligible activities
and the qualification of their level of alignment with theTaxonomy were carried out in accordance with the
instructions and criteria of the Taxonomy Regulation(1), itsdelegated acts(2) (3) and additional information(4) (5) provided
by the European Commission. In accordance with theseregulations, Believe has published key performanceindicators (KPIs) since 2021 highlighting the share of its
net revenue, capital expenditure (CapEx) and operating
expenses (OpEx) associated with the activities described in
the Taxonomy framework: the portion “eligible” for theTaxonomy. From fiscal year 2022, Believe publishes KPIs
indicating the share of its net revenue, its CapEx and OpEx
resulting from products and/or services consideredsustainable within the meaning of the Taxonomy: theportion “aligned” with the Taxonomy.
The calculation of these ratios involves the analysis of theeligibility of the underlying activities as well as thecompliance by these activities with the technicalassessment criteria used to qualify their alignment with
the Taxonomy.

Status of eligibility.
For fiscal year 2022, activities can be assessed solely withregard to the objectives of climate change mitigation andadaptation to climate change.
A large portion of Believe’s distribution and artist
promotion activities, representing more than 90% of theGroup’s consolidated revenue, could be considered ascovered by economic activity 13.3. “Production of motion
pictures, videos and television programs; sound recording
and music publishing” of the Delegated Act of Objective 2– “Adaptation to Climate Change". However, as for fiscal
year 2021, and pending clarification on the criteria
applicable to its sector of activity, Believe has decided, aspart of a “prudent” approach, not to consider its main
activity as being eligible for the Taxonomy for fiscal year
2022. As a result, the share of revenue eligible for theTaxonomy remains zero.
Nevertheless, an analysis of the eligibility (and thenalignment) was carried out on capital expenditure (CapEx)
and focused on the identification of “individual measures”– i.e. those that are linked the purchase of the output of
economic activities aligned with the Taxonomy andindividual measures enabling targeted activities tobecome low-carbon. For Believe, these include
acquisitions or long-term leases of buildings, vehicles andIT equipment associated with servers that could offer
energy efficiency and greenhouse gas emissions reduction
potential.

(1) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32020R0852&from=EN(2) https://eur-lex.europa.eu/resource.html ?uri=cellar:d84ec73c-c773-11eb-a925-01aa75ed71a1.0003.02/DOC_2&format=PDF(3) https://eur-lex.europa.eu/resource.html ?uri=cellar:d84ec73c-c773-11eb-a925-01aa75ed71a1.0003.02/DOC_3&format=PDF(4) https://ec.europa.eu/finance/docs/law/221219-draft-commission-notice-disclosures-delegated-act-article-8.pdf(5) https://ec.europa.eu/finance/docs/law/221219-draft-commission-notice-eu-taxonomy-climate.pdf

47

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Actions on the ground in favor of the environment

TABLE 1: BREAKDOWN OF BELIEVE’S ELIGIBLE ACTIVITIES

Taxonomy activity (according to the Climate
Delegated Act: “climate change mitigation” objective)

Types of Believe CapEx valued

6.5 Transport by motorcycles, passenger cars
and light commercial vehicles

Purchase or long-term leasing of vehicles for staff travel

7.7 Acquisition and ownership of buildings

Long-term leasing of buildings

8.1 Data processing, hosting and related activities

Purchase or lease of equipment associated with data
management

The methodology used to identify the aligned investments– among the eligible activities – is presented below.

the assessment consisted of confirming the energy
performance diagnosis (DPE) A or not of the buildings, orthe comparison of the primary energy demand with thethresholds of the 15% most energy-efficient buildings
published by the Green Building Observatory (OID). The
assessment of substantial contribution was made on thebasis of the buildings' energy consumption data.

Assessment of the substantial contribution
and the DNSH of eligible activities
6.5 Transport by motorcycles, passenger cars
and light commercial vehicles
Believe leases a fleet of service vehicles on a long-termbasis. The granularity of the information available in theGroup’s management system does not make it possible toidentify whether these activities strictly comply with thecriteria in terms of substantial contribution to climatechange mitigation.
7.7 Acquisition and ownership of buildings
Method of analysis

Allocation to the numerator: the Finance Departmentcollected information to determine the Taxonomy activityof each real estate CapEx and then conclude on itsalignment or not with the criteria of substantial
contribution to the objective of climate change mitigationand the Do No Significant Harm (DNSH) criteria, in otherwords, does not cause significant harm to any of the otherspecific environmental objectives. As such, the officebuildings in France, Germany, Luxembourg and outside ofEurope are classified under activity 7.7 due to the right-ofuse assets under IFRS 16, which was subject to a change
during the year. For all other items, a search for proof ofalignment with the criteria of substantial contribution or
the non-enforceability of a DNSH criterion was carried out.
If a proof lacks consistency or does not exist, the item isdeemed not aligned.
Calculation of the denominator: the total sum ofinvestments in 2022 is obtained from the table of changes
in non-current assets. This work was audited as part ofthe preparation of the Universal registration document(URD).
Substantial contribution to climate change mitigation

As these are exclusively buildings for which the building
permit application was filed before December 31, 2020,

Following the assessment of substantial contribution, fivebuildings, representing an amount of €1.16 million of
CapEx in 2022, meet the criteria of substantial
contribution to climate change mitigation.
DNSH: Adaptation to climate change

As the scope of Believe’s eligible activities is focused on
the real estate activities in Section 7 of the climate change
mitigation appendix, the Group is required to comply withthe generic DSNH related to climate change adaptation.
Among the buildings meeting the substantial contribution
criteria, two buildings meet the DNSH Adaptation
criterion.
8.1 Data processing, hosting and related activities
Believe has invested in the long-term leasing of a set of
equipment related to the management and massprocessing of data as part of its artist promotion andproduction activities.
The information available did enable compliance with thesubstantial contribution criteria to be established.

Assessment of minimum guarantees
Believe followed the recommendations of the European
Platform on Sustainable Finance report dated October
2022 concerning the study of minimum guarantees (Finalreport on Minimum Safeguards)(1). The Group conducted
an in-depth analysis of its practices with regard to the four
themes described in the report (human rights, corruption,
taxation and competition law), as well as an analysis ofcontroversies with regard to the criteria for non-alignment
described in the report. The results of these analyses
show that Believe complies with the minimum guarantee
requirements for this first alignment exercise.

(1) https://finance.ec.europa.eu/system/files/2022-10/221011-sustainable-finance-platform-finance-report-minimum-safeguards_en.pdf.

Extract from Universal registration document 2022 - Believe48

2

Corporate social responsibility
Actions on the ground in favor of the environment

TABLE 2: DOCUMENTS AND PROCEDURES ASSOCIATED WITH MINIMUM GUARANTEES

Criteria

Detailed criteria

Believe policies and procedures

Due Diligence on
Human Rights

The company has put in place an adequate human A Code of Ethics
rights due diligence process, as outlined in the United Alert mechanism to combat all forms of
Nations Guiding Principles and the OECD Guidelines for discrimination
Multinational Enterprises.
Diversity and Inclusion Policy
The company has implemented anti-corruption processes. Policy on conflicts of interest

Anti-corruption
procedures

Anti-corruption policy
Procedures for compliance with the
Sapin II law

Tax governanceTax governance and compliance are considered Existence of a tax policy
important elements of supervision, and adequate tax
risk management strategies and processes are in place.

Fair competition
procedures

The company educates its employees on the Group Code of Ethics
importance of complying with all applicable competition
laws and regulations.

These policies and procedures, supplemented by theGroup tax policy, are in line with the requirements of theEuropean Platform on Sustainable Finance report relating
to the implementation of procedures specific to the four
themes of minimum guarantees.

Qualification of indicators and presentationof results
Definition of indicators

CapEx KPI result
The Group analyzed its acquisitions of property, plant andequipment and intangible assets (IAS 16 and 38), right-ofuse assets (IFRS 16) and business combinations (IFRS 3)
constituting the Taxonomy CapEx denominator. This
amounted to €42.81 million for 2022.
The eligibility and alignment of the Group’s activities were
only analyzed for the climate change mitigation objective.
The risk of double-counting between objectives istherefore non-existent.

The KPIs (revenue, CapEx and OpEx) have been calculated
in strict compliance with the regulatory definitions of thedelegated act of Article 8 of the Taxonomy(1).

The CapEx eligibility ratio stands at 14.11%, with €6.04
million of eligible investments out of a total of €42.81
million in 2022. Right-of-use assets represent all eligible
investments.

Calculation and results of Believe indicators

The CapEx KPIs (alignment) in 2022 amounted to 0.62% of
total investments, i.e. €0.265 million of CapEx aligned with
the Taxonomy.

Revenue KPI result
As Believe’s business lines are focused on artistic
production activities, no eligible revenue has been
identified for the climate change mitigation andadaptation to climate change objectives, as the Group's
activities do not meet the activity criteria for theseobjectives.
Believe’s consolidated revenue amounted to €760.81
million in 2022, constituting the Taxonomy denominator
for this indicator. The revenue KPI is 0%.

OpEx KPI result
In 2022 – as in 2021 – this Taxonomy OpEx denominator,
which stands at €1.37 million, represented 0.2% (less than5%) of total consolidated OpEx (amounting to €725.8
million). On the basis of the analysis of OpEx, the amountanalyzed is considered not material with regard to theGroup’s materiality thresholds. On the basis of thisobservation, combined with the fact that the Group’s
activities are not eligible to date, Believe has applied theexemption provided and not calculated the Taxonomy
OpEx indicator in more detail(1) https://www.amf-france.org/fr/actualites-publications/dossiers-themérales/taxinomie.

49

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Actions on the ground in favor of the environment(In € million)

Substantial contribution

DNSH
Category (transitory activity) (21)Category (enabling activity) (20)

Proportion of revenue aligned
in year N-1 (19)

Proportion of revenue aligned
in year N (18)Minimum guarantees (17)Biodiversity and ecosystems (16)

Pollution (15)

Circular economy (14)Water and marine resources (13)Adaptation to climate change (12)Climate change mitigation (11)Biodiversity and ecosystems (10)Pollution (9)Circular economy (8)Water and marine resources (7)Adaptation to climate change (6)Climate change mitigation (5)% of revenue (4)Total revenue (3)Code(s) (2)Economic
activities (1)A. ACTIVITIES ELIGIBLE FOR THE TAXONOMY
A.1. Environmentally sustainable activities (aligned with the Taxonomy)
Revenue fromenvironmentally
sustainable
activities(aligned) (A.1.)

0,00

0,0%

0,0%

A.2. Activities eligible for the taxonomy but not environmentally sustainable (not aligned)
Revenue from
activities eligible
for theTaxonomy
but not
environmentally
sustainable (notaligned) (A.2.)

0,00

0,0%

TOTAL (A.1. + A.2.)
B. ACTIVITIES NOT ELIGIBLE
FOR THE TAXONOMY
Revenue from
activities not
eligible for theTaxonomy (B.)

0,00

0,0%

TOTAL (A. + B.)

760.81100.0%

Extract from Universal registration document 2022 - Believe50

2

Corporate social responsibility
Actions on the ground in favor of the environment(In € million)

Substantial contribution

DNSH
Biodiversity and ecosystems (16)NA

NA

NA Yes 0,6%

Category (transitory activity) (21)

Pollution (15)NA

Category (enabling activity) (20)

Circular economy (14)Yes

Proportion of capital expenditure aligned
in year N-1 (19)Water and marine resources (13)Proportion of capital expenditure aligned
in year N (18)Adaptation to climate change (12)Minimum guarantees (17)

Climate change mitigation (11)Biodiversity and ecosystems (10)Pollution (9)Circular economy (8)Water and marine resources (7)Adaptation to climate change (6)Climate change mitigation (5)% of capital expenditure (4)Total capital expenditure (3)Code (2)NA

Economic
activities (1)A. ACTIVITIES ELIGIBLE FOR THE TAXONOMY
A.1. Environmentally sustainable activities (aligned with the Taxonomy)
7.7. Acquisitionand ownershipof buildings

7.7

Capitalexpenditure forenvironmentally
sustainable
activities(aligned) (A.1.)

0,26

0,6% Yes

-

-

-

-

-

A.2. Activities eligible for the taxonomy but not environmentally sustainable (not aligned)
6.5. Transport
by motorcycles,
passenger cars
and light
commercial
vehicles

6,5

0,25

0,6%

7.7. Acquisitionand ownershipof buildings

7.7

2,59

6,0%

8.1. Data
processing,hosting andrelated activities

8.1

3,20

7,5%

6,04

14,1%

Capitalexpenditure foractivities eligible
for theTaxonomy
but not
environmentally
sustainable (notaligned) (A.2.)
TOTAL (A.1. + A.2.)
B. ACTIVITIES NOT ELIGIBLE
FOR THE TAXONOMY

51

Capitalexpenditure foractivities not
eligible for theTaxonomy (B.)

36,77

85,9%

TOTAL (A. + B.)

42,81

100,0%

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Actions on the ground in favor of the environment(In € million)

Substantial contribution

DNSH
Category (transitory activity) (21)Category (enabling activity) (20)

Proportion of operating expenses aligned
in year N-1 (19)

Proportion of operating expenses aligned
in year N (18)Minimum guarantees (17)Biodiversity and ecosystems (16)

Pollution (15)

Circular economy (14)Water and marine resources (13)Adaptation to climate change (12)Climate change mitigation (11)Biodiversity and ecosystems (10)Pollution (9)Circular economy (8)Water and marine resources (7)Adaptation to climate change (6)Climate change mitigation (5)% of operating expenses (4)Total operating expenses (3)Code(s) (2)Economic
activities (1)A. ACTIVITIES ELIGIBLE FOR THE TAXONOMY
A.1. Environmentally sustainable activities (aligned with the Taxonomy)
Operatingexpenses forenvironmentally
sustainable
activities(aligned) (A.1.)

0,00

0,0%

0,0%

A.2. Activities eligible for the taxonomy but not environmentally sustainable (not aligned)
Operatingexpenses for
activities eligible
for theTaxonomy
but not
environmentally
sustainable (notaligned) (A.2.)

0,00

0,0%

TOTAL (A.1. + A.2.)
B. ACTIVITIES NOT ELIGIBLE
FOR THE TAXONOMY
Operatingexpenses for
activities not
eligible for theTaxonomy (B.)

725,80100,0%TOTAL (A. + B.)

725,80100,0%

Change compared to the previous fiscal year
Change in eligibility results
In 2021, this eligibility ratio was 9.06% for Group
consolidated CapEx, compared to 14.11% in 2022. The
main changes compared to 2021 are partly due to a slightincrease in the proportion of IFRS 16 right-of-use assets
compared to total investment flows.
Methodological changes
No methodological changes were made between the two
fiscal years.

Outlook
Improved Taxonomy KPIs
As indicated in the Ssecection “Status of eligibility”, Believe’s
artistic production and distribution activities are notconsidered eligible for the Taxonomy. Consequently, nochange in Believe’s revenue KPI is expected in the coming
fiscal years. A possible revision of the delegated acts in themedium term, or clarification from the relevant
authorities, could enable this sector to assess andcommunicate its performance in terms of the fight against
climate change under the terms of the Taxonomy. The
adoption of the delegated acts relating to the otherobjectives of the European Green Taxonomy, or thoserelating to a possible social taxonomy, could be better
applied to Believe’s activities. Similarly, the OpEx KPI
should remain non-material with regard to the Group’sbusiness model. With regard to the CapEx KPI, better
integration of energy performance criteria in future
investments as well as improvement of the processes forcollecting technical information should make it possible toimprove the potential level of this indicator.

Extract from Universal registration document 2022 - Believe52

2

Corporate social responsibility
Actions on the ground in favor of the environment

2.6.1.3 Prioritizing action on Believe’s
direct carbon andenvironmental impact
As part of its Shaping Music for Good ambition and withregard to the analysis of its carbon impact, Believe
prioritizes actions for which the Group and its employees
have a direct leverage on reducing their environmental
impact. Several projects were launched in 2022 and will be
more widely deployed in 2023.
The main initiatives for 2022 and 2023 concern officesenergy consumption, transport and resources:●

reducing energy consumption
environmentally-friendly gestures;

andspreading●review the adaptation and maintenance of systems
with building managers;
adapt the temperature control in the server rooms, incompliance with the conditions necessary for theproper functioning of the equipment.

Examine the level of environmental certifications(BREEAM, LEED, HQE, etc.) of the premises in coordination
with the lessor.
These measures aim to limit energy consumption in
offices, while teams are gradually moving away fromremote working following the health crisis. This, coupledwith the extension of the reporting scope, explains theincrease in energy consumption between 2021 and 2022.

●

the study for the use of renewable energies;

Indicator

2022

2021

●

business travel management.;

Energy consumption in kWh
per m2 for offices

118.7

96.8

●

the reasonable use of disposable products and therecycling or recovery of waste.

2.6.1.4 Reducing energy consumption
and the carbon impact of offices
Reducing the energy used in offices
A first action plan in favor of energy savings and the
reduction of GHG emissions is being rolled out in the main
countries where the Group operates.
The CSR Department has distributed an action guide topromote energy efficiency in offices to all subsidiaries. The
aim is to help General Services identify possible actions
locally to reduce energy consumption, by involving
building owners and managers, as well as employees.
This guide proposes a very pragmatic approach with:●measures that are quick and easy to implement;●

and more complex and long-term initiatives.

For each action, the General Services and Human
Resources teams can identify the necessary investments
and the potential impact in terms of energy savings and
GHG emissions reduction.
The aim is to encourage local teams to:
●

●

53

●

determine target temperatures for heating and cooling,
and limit their use to office hours;
disseminate best practices and environmentallyfriendly gestures to employees such as opening
windows and turning off electrical appliances;

Extract from Universal registration document 2022 - Believe

Encouraging the use of renewable energies
Believe has begun its transition on a few buildings byincreasing the share of its electricity consumption fromrenewable sources, via purchasing green electricity
contracts from suppliers and using certificates ofguarantee of origin. At the end of 2022, four sites
worldwide, in France, Germany (in Donzdorf and
Hamburg) and the United Kingdom, were using 100%
renewable electricity. These sites represent 80% of theGroup’s electricity consumption. The ability to deploy the“renewable energy” policy depends on several factors
independent from Believe: technical equipment of thebuilding, the will of the owner and lessor and the country’s
energy mix.
Indicator

2022

2021

% of renewable energy in total
electricity consumption

80.3%

-

Outlook
Environmental indicators will be increasingly detailed aspart of the CSR reporting and the technical sobriety guide.
Believe will then have more robust data to identify andmanage the most relevant actions to be implemented in
the premises.
On this basis, the Group wants to set short- and mediumterm targets for reducing energy consumption andgreenhouse gas emissions for its main sites.

www.believe.com

Corporate social responsibility
Actions on the ground in favor of the environment

2.6.1.5 Adapting the transport policy
and promoting low-carbon
travelBelieve also wants to promote best practices to reducegreenhouse gas emissions in its scope 3, when the Groupcan use levers. In the short term, this concerns, inparticular, transport emissions related to business travel
and home-work commuting.
As part of the 2022 environmental reporting, Believe
asked travel agencies and local teams to start measuring
the carbon impact of business travel. Data collection wasquite uneven across countries. In 2023, the Group will
strengthen this reporting to identify the main sources ofemissions by country and type of transport. In the longterm, the challenges are to:●●

set targets for reducing emissions from business
transport;
formalize and roll out a low-carbon transport policy. It
will aim to limit the number of trips and reduce the useof airplanes which is a high-carbon mode of transport.

The teleworking policy and the use of efficient
communication tools already make it possible to organize
meetings and work remotely. This reduces business travel
and commuting.
Local human resources teams are also implementing
initiatives to limit or optimize employee trips. They thus
reduce the carbon impact of daily transport.
Some examples of low-carbon mobility actions for
employees, deployed according to the site situation andthe country’s regulations:
●

●
●

●

●
●

internal survey to identify employees interested in lowcarbon mobility and the actions to be implemented(public transport and/or bicycle package, bicycle
parking, solicitation of public authorities to install abicycle station, etc.);
shared bicycle system (Germany);hybrid and electric company vehicles (Turkey, France,etc.);
payment of part of the public transport subscription(France, Japan, etc.);
participation in the purchase of bicycles (France, etc.);
global sporting challenge SquadEasy, which largely
motivated employees to replace the use of the car bysoft mobility.

2.6.1.6 Controlling the need forresources and reducing waste
In addition to climate actions, Believe is also developing
initiatives to promote the circular economy and thepreservation of resources, mainly in three areas:●●●for IT equipment: measuring the recycling rate of waste
electrical and electronic equipment in France;
in offices: limiting the use of single-use products anddeveloping selective sorting and recycling practices;
for merchandising products for artists: offering ecodesigned and recyclable products.

Indicator

2022

2021

Recycling rate of electrical andelectronic equipment in France(WEEE)

100%

95%% of sites that have
implemented eco-responsible
practices (selective sorting,recycling, reuse, etc.)

70%-

With regard to waste of electrical and electronicequipment (WEEE), data collection, monitoring ofequipment, as well as the implementation of recycling andreuse practices, are complex to deploy in all countries. In
2023, the Group will initiate discussions with the teams
concerned to further develop the WEEE reporting anddefine eco-responsible practices, identify reliable partners
and ensure the recycling of this waste locally if possible.
At the same time, some committed artists wish to offer
their listeners and fans eco-designed CDs, vinyls, oraccessories (packaging, mugs, t-shirts, tote bags, etc.).
Believe then identifies specialized suppliers and defines
specifications as part of its merchandising activities onbehalf of its customers.
In Germany, for example, Believe’s subsidiaries propose toartists who so wish to work with manufacturers of vinyls
produced from recycled records.
In the offices, the local human resources teams, with thesupport of the Believe for Planet ambassador network raise
employee awareness in order to apply eco-responsible
practices and gestures on a daily basis: on-site recycling ofwaste products, clothing drives, etc. (1).

(1) Numerous examples in Section 2.5.2.4 “Supporting employee engagement with local communities”, page 43.

Extract from Universal registration document 2022 - Believe54

2

Corporate social responsibility
Actions on the ground in favor of the environment

2.6.2 Supporting the engagement of employees and the music
and digital industry to the environment
Within the Shaping Music for Good framework, Believe
wants to raise awareness and involve its employees andthe various players in the music industry in climate andenvironmental issues through global and local initiatives.
These actions also help to strengthen the pride of
belonging to the Group and the level of employee
engagement, with employees being very committed tothese issues.

Some examples of activities and initiatives that promote
eco-responsible
practices
andawarenessofenvironmental issues:●●●

2.6.2.1 Promoting employee awarenessof the environment
Actions implemented by the local CSR and humanresources teams and by the Believe for Planet
ambassadors aim to raise awareness and train
employees. The challenge is to promote eco-responsible
practices and actions on a daily basis, as a employee andas a citizen.

●

●

●

●

replacement of disposable cups with reusable cups
and water bottles;
waste sorting;workshops as part of the Believe Tomorrow month ofsolidarity: climate fresco, digital fresco, conference on“Green IT”, manufacture of cleaning products andnatural cosmetics, cleaning of beaches and public
places, tree planting, etc.;
soft mobility: SquadEasy challenge to replace the car bywalking or cycling with quizzes on the environment;
financial aid
purchases(1);forpublictransport

andbicyclemeasuring the personal carbon impact with the Good
Planet Carbon calculator;
coordination of the Believe for Planet(2) ambassador
network.

2.6.3 Participating in the music industry’s mobilization aroundthe climate emergency
Drawing on its leadership in its sector, Believe is convincedof the importance of taking action in concert with all
players in the music industry. This is why it joined theMusic Declares Emergency (MDE) group in 2021. Born in
England in 2019, this movement aims to unite the musicindustry around climate emergency and help reduce its
environmental impact. It relies on the ability of music
through its cultural influence to change the public opinion
and rally support for its cause.

Since 2022, Believe has been contributing skills to theinitiative of the Mangroove Music label, in cooperation
with the Albert II of Monaco Foundation. The Mangrove
Music label is the first music label with a positive socialand environmental impact. It finances projects in the fieldwith the support of committed artists.
Believe provides advice and distributes the One Song One
Forest title created by one of Believe's artists, Youssoupha,
withthesinger
Oumou
Sangare(https://www.mangroovemusic.org/). This project will raise funds
to restore and protect mangroves in West Africa.

(1) See Section 2.6.1.5 “Adapting the transport policy and promoting low-carbon travel”, page 54.
(2) See Section 2.1.3.3 “A global network of committed ambassadors”, page 11.

55

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Methodological note and summary of indicators

2.7 Methodological note and summary of indicators
Believe has built its Non-Financial Performance Statement(NFPS) with the aim of ensuring uncompromising
standards in terms of non-financial reporting through thestrict application of regulatory obligations and theconvergence with existing standards. This method makes
it possible to anticipate future European regulatory
requirements. It meets the obligations set out in Articles
R. 225-105-2 et seq. and L. 225-102-1 of the French
Commercial Code, by presenting information on the way
in which Believe takes into account the social andenvironmental consequences of its activity. A detailed
cross-reference table is presented in Section 8.5.3“Management Report”, page 339.
In line with regulatory guidelines, the reporting of Believe’s
non-financial indicators is based on an internalframework specific to its activities, and on the Global
Reporting Initiative (GRI) for its areas of application, its
performance indicator recommendations and its “GRI GA”
guidelines. This is a voluntary framework recognizedworldwide.

2.7.1 Non-financial risk analysis methodology
The methodology for identifying material risks is based on
several stages:●●●

identification of a scope of CSR risks based on thespecificities of the music and technology/digital sector;
a comparison of these specific CSR risks with Believe’s“classic” risks as identified by the French Financial
Markets Authority (Autorité des marchés financiers –AMF), identified in particular in Chapter 3 of this
Universal registration document;●

an analysis of these CSR risks cross-referencing
regulatory expectations, a sector watch, the Global
Reporting Initiative framework and the Shaping Musicfor Good strategy;
a comparison of these CSR risks with the results of the
stakeholder survey conducted in July 2021 (see Section
2.2.1.2 “Consultation with stakeholders” on page 54).

The table summarizing the pillars of the CSR strategy, nonfinancial risks, policies, indicators and actions is presented
in Section 2.2.2 “Policies and actions to address ESG
challenges: matrix of risks and opportunities”, page 63.

2.7.2 Scope of the risks covered
This statement for the 2022 fiscal year is based on a risk
analysis, in accordance with regulatory obligations, andreflects the expectations of the main stakeholders
regarding the assessment and management of CSR risks
and opportunities. The description of this analysis isdetailed in Section 2 of this Chapter 2, page 48.
In the context of the risk mapping task, the following
topics were not considered relevant or material withregard to the Group’s activities.

Due to its activity, the Believe group is not directly affectedby issues related to:●the fight against food waste;●

the fight against food insecurity;●

respect for animal welfare;●respect for responsible, fair and sustainable food;●the prevention, reduction or remediation of emissions
into the air, water and soil that seriously affect theenvironment;●

land use;●the protection of biodiversity.

Extract from Universal registration document 2022 - Believe56

2

Corporate social responsibility
Methodological note and summary of indicators

2.7.3 Reporting period and frequency
The data collected covers the period from 01/01/2022 to 12/31/2022, corresponding to Believe's fiscal year. Unlessotherwise stated, societal, social and environmental indicators refer to consolidated data as of December 31, 2022.

2.7.4 Reporting scope
The scope of non-financial reporting is based on thefinancial scope of consolidation. Social data represents
100% of the Group’s total workforce, with the exception of
the following indicators:
●

●

●

●

number and percentage of ambassadors among
employees;
percentage of employees who completed at least one
training course during the period;
percentage of employees who have completed at least
one training module on ethics, the fight against
corruption or conflicts of interest;
percentage of employees who validated at least one
career review during the period.

These data exclude the 6&7, Jo&Co, DMC, NetD and
TuneCore Japan subsidiaries. This is due to the fact thatthese entities have not yet adopted all the HR data
management tools and still use different processes for thecollection of indicators. They represent 6% of the Group’s
total workforce, and €22.26 million in revenue, i.e. 2.3% of
the Group’s revenue.

Environmental data excludes the Taipei, Chennai,
Hyberabad, Mohali, Syracuse, Montreal and Toronto sites,
which are co-working spaces and correspond to 3.2% of
the Group’s workforce. The reporting of WEEE collected
and recycled, is limited to France, which represents 39% of
employees and €129 million in revenue, i.e. 16.9% of theGroup’s revenue.
A very limited number of indicators was therefore
assessed on scopes that were significantly different fromthe 2021 scope of CSR reporting:
Note:
●

●

headcount is calculated in terms of number of
employees (natural persons present at the end of theperiod) and not in “full-time equivalent”;
estimation methods have been applied for the energy
consumption of sites in Germany, the United States(Atlanta, Brooklyn, Culver City, Nashville), India(Mumbai) and Russia. Energy consumption for thesesites was estimated using the data available for 2022
and the 2021 data for periods for which 2022 data wasunavailable.

2.7.5 Non-financial indicators
2.7.5.1 Consolidation and internal
controlSocial data are reported and consolidated at the local andcentral levels using the Human Resources information
system tools and Excel.

The protocol of CSR reporting for Believe Group's
subsidiaries was implemented in 2021 when the CSR
approach was formalized by the Shaping Music for Good
strategy. It was updated in 2022 to better meet the
expectations of the Group’s stakeholders.

Other data is collected directly from local and central
contributors.

This protocol enables the application of unified
definitions, data collection, validation and consolidation
rules within the Group’s entities. To this end, it defines indetail the methodology for calculating and collecting
indicators and qualitative information concerning CSR, as
well as the scope concerned by the reporting.
Environmental data are reported and consolidated using adata collection system, the Tennaxia Reporting tool.
Automatic consistency checks are performed by the tool
during data entry.

57

Extract from Universal registration document 2022 - Believe

For each indicator, an initial check is carried out by eachsubsidiary. These indicators are then aggregated andmonitored by the Group’s head office. A second validation
is carried out at the time of consolidation. Lastly, ananalytical review and general control ensure the overall
consistency of environmental and social data.

2.7.5.2 External control
Believe’s Independent Third-party Body for 2022 is KPMG,
which performs the audit mission as defined by Articles
L. 225-102-1 and R. 225-105-2 of the French Commercial
Code, consisting of the audit of the compliance andsincerity of the NFPS.

www.believe.com

Corporate social responsibility
Methodological note and summary of indicators

2.7.5.3 Definition of non-financial
indicators
In order to better manage its CSR strategy andperformance, Believe has identified key non-financial
performance indicators. They make it possible to monitor
the implementation of the four pillars of Shaping Music forGood and policies and actions to address the Group’s nonfinancial risks.
These indicators are rolled out across the 2022 CSR scopeof reporting, which is almost identical to the Group’s
financial scope of consolidation(1).
Three of them are included in the variable and long-termcompensation of the members of the Executive
Committee (% of women among employees, % of

Performanceindicator

ambassadors among employees and % of employees
having attended at least one training course during theperiod) and 13 are considered “priority” because they
provide information on key topics for Believe: genderequality, talent attraction and retention, training,
reduction of greenhouse gas emissions related tobuildings and management of IT equipment.
Certain definitions and methodologies for calculating
indicators have evolved during the period (01/01/2022 –12/31/2022) in order to allow a more accurate and robust
measurement.
As part of its active external growth policy, Believe is also
committed to gradually integrating new subsidiaries andactivities into non-financial reporting.

2022

2021

Definition

Scope

1,651

1,430

Number of Group employees on
permanent contracts, fixed-term
contracts, work-study andapprenticeship contracts at theend of the reporting period.

2022 CSR scopeof reporting.

Number of employees working for
the Central Platform at the end of
the period/total headcount.

2022 CSR scopeof reporting.

Number of employees working forPremium Solutions and AutomatedSolutions at the end of the period/
total headcount.

2022 CSR scopeof reporting.

Number of employees in France atthe end of the period/total
headcount.

2022 CSR scopeof reporting.

Headcount
Total workforce

2022 Financial scope.

% of employees
36%
working for the Central
Platform among all
employees

34.3%% of employees
working for Premium
Solutions andAutomated Solutions
among all employees

64%

65.7%

% of employees inFrance among all
employees

39%% of employees inGermany among all
employees

15%

17.2%

Number of employees in Germany
at the end of the period/total
headcount.

2022 CSR scopeof reporting.

14%% of employees in
Europe, Russia and the
Middle East (excludingFrance and Germany)
among all employees

15.4%

Number of employees in Europe,
Russia and the Middle East
(excluding France and Germany) at
the end of the period/total
headcount.

2022 CSR scopeof reporting.

% of employees inNorth and SouthAmerica among all
employees

10.9%

Number of employees in Northand South America at the end of
the period/total headcount.

2022 CSR scopeof reporting.

11%

39.1%

2022 Financial scope.

2022 Financial scope.

2022 Financial scope.

2022 Financial scope.

2022 Financial scope.

2022 Financial scope.

(1) The 2022 CSR reporting does not take into account the subsidiaries acquired in the last quarter of 2022, unlike the Group’s financial scope of
consolidation. These subsidiaries have no significant and material impact on the 2022 CSR reporting.

Extract from Universal registration document 2022 - Believe58

2

Corporate social responsibility
Methodological note and summary of indicators

Performanceindicator

2022

2021

Definition

Scope% of employees in
Asia, Oceania, Africa
among all employees

21%

17.4%

Number of employees in Asia,
Oceania, Africa at the end of theperiod/total headcount.

2022 CSR scopeof reporting.

% of permanentcontracts

95.6%

91.5%

% of employees on permanentcontracts among the Group’s
employees on permanent andfixed-term contracts.

2022 CSR scopeof reporting.

% of employees on fixed-term
contracts among the Group’s
employees on permanent andfixed-term contracts.

2022 CSR scopeof reporting.

2022 CSR scopeof reporting.

2022 CSR scopeof reporting.

2022 Financial scope.% male
employees among all Group
employees.

2022 Financial scope.

% female employees among all
Group employees.

2022 CSR scopeof reporting.

% of fixed-term
contracts% men% women

4.4%

56.9%

43.1%

8.5%

60%

40%

CSR objective includedin the variable andlong-termcompensation of themembers of the
Executive Committee% employees among
management teams

2022 Financial scope.

2022 Financial scope.

2022 Financial scope.

7.2%

8.4%

Number of employees among
management teams at the end of
the period/Total headcount.
The population of management
teams corresponds to internal
categories from levels 9 to 12(“Executive” and “Leaders” Career
Paths). It represents 7.3% of themost senior positions.

% women in
management teams

2022 Financial scope.

42.9%

41.8%

Number of female employees inmanagement teams at the end of
the period/Number of employees
in management teams.

2022 CSR scopeof reporting (excluding
TuneCore Japan, 6&7,
JoandCo, DMC & NetD).

2022 CSR scopeof reporting (excluding
TuneCore Japan, 6&7,
JoandCo, DMC & NetD).

The population of management
teams corresponds to internal
categories from levels 9 to 12(“Executive” and “Leaders” Career
Paths). It represents 7.3% of themost senior positions.
% men inmanagement teams

57.1%

58.2%

Number of male employees among
management teams at the end of
the period/Number of employees
in management teams.

2022 CSR scopeof reporting (excluding
TuneCore Japan, 6&7,
JoandCo, DMC & NetD).

The population of management
teams corresponds to internal
categories from levels 9 to 12(“Executive” and “Leaders” Career
Paths). It represents 7.3% of themost senior positions.

59

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Methodological note and summary of indicators

Performanceindicator

2022

2021

Definition

Scope% of employees at
23.2%“Manager” level among
all employees

20.6%

Number of “Manager” level
employees at the end of theperiod/Total headcount.

2022 CSR scopeof reporting (excluding
TuneCore Japan, 6&7,
JoandCo, DMC & NetD).

The population of managers
corresponds to internal categories
from levels 5 to 12 (including
management teams, for“Executive” and “Leaders” Career
Paths).
% of women among“Manager” level
employees

37.6%

34%

Number of female “Manager” level
employees at the end of theperiod/“Manager” level employees
The population of managers
corresponds to internal categories
from levels 5 to 12 (including
management teams, for“Executive” and “Leaders” Career
Paths).

% of men among“Manager” level
employees

62.4%

66%

Number of male employees at“Manager” level at the end of theperiod/“Manager” level employees.
The population of managers
corresponds to internal categories
from levels 5 to 12 (including
management teams, for“Executive” and “Leaders” Career
Paths).

2022 CSR scopeof reporting (excluding
TuneCore Japan, 6&7,
JoandCo, DMC & NetD).

2022 CSR scopeof reporting (excluding
TuneCore Japan, 6&7,
JoandCo, DMC & NetD).

ParityGender equality index(France)99/10099/100

Pay gap: 39/
40

Pay gap: 39/
40

Pay increase
gap: 20/20

Pay increase
gap: 20/20

Promotion
gap: 15/15

Promotion
gap: 15/15

Maternity
leave: 10/10

Maternity
leave: 10/10

10 highest
paid
employees:
10/10

10 highest
paid
employees:
10/10

50%

54%

Methodology recommended by the Believe SA (France)
French government based on four
indicators: equal opportunities, faircompensation, prevention andprotection, and commitment.

Executive Committee% of women on the
Executive Committee% of male on the
Executive Committee

50%

46%

Number of female employees thatare members of the Executive
Committee at the end of theperiod/number of Executive
Committee members.

2022 CSR scopeof reporting.

Number of male employees thatare member of the Executive
Committee at the end of theperiod/number of Executive
Committee members.

2022 CSR scopeof reporting.

2022 Financial scope.

2022 Financial scope.

Extract from Universal registration document 2022 - Believe60

2

Corporate social responsibility
Methodological note and summary of indicators

Performanceindicator

2022

2021

Definition

Scope

257

251

Total number of employees hired
during the period regardless of
their type of contract: permanent,
fixed-term, work-study,
apprenticeship.

2022 CSR scopeof reporting.

Hires and departures
Number of employees
hired during theperiod2022 Financial scope.

A candidate becomes an employee
and is considered hired after
signing his employment contractand having actually joined theCompany.
% of women among
employees hired
during the period

16.1%

19%

Total number of female employees 2022 CSR scope
hired during the period regardless of reporting.
of their type of contract/Number of 2022 Financial scope.
employees hired during theperiod.

% of men among
employees hired
during the period

56.3%

37.8%

Total number of male employees
2022 CSR scope
hired during the period regardless of reporting.
of their type of contract/Number of 2022 Financial scope.
employees hired during theperiod.

Number of layoffs
and job losses

257

251

This includes departures due tolayoffs, end of probationary period
at the initiative of the employer.

2022 CSR scopeof reporting.
2022 Financial scope.

Attrition rate

16.1%

19%

Total number of departures overthe last 12 months/Average
headcount.

2022 CSR scopeof reporting.

Turnover rate

26%

28%

The turnover rate measures therate at which employees leave thecompany and are replaced.

2022 CSR scopeof reporting.

It is calculated by taking into
account the total headcount at the
beginning of the period (01/01/
2022).

2022 Financial scope.

2022 Financial scope.

((Number of voluntary departuresduring the period + number oflayoffs and job losses over theperiod)/2)/total headcount at
01/01/2022.

61

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Methodological note and summary of indicators

Performanceindicator

2022

2021

Definition

Scope

3%

2.06%

Absence due to an accident or
occupational illness, any otherillness, or a family event during theperiod.

2022 CSR scopeof reporting.

Number of employees who started
at least one of the online training
modules on ethics, anti-corruption
and conflicts of interest during theperiod/total headcount.

2022 CSR scopeof reporting.

Absenteeism
Absenteeism rate2022 Financial scope.

Training% of employees having 44%
followed at least one
training module on
ethics, anti-corruption
and conflicts ofinterest

67%% of employees whocompleted at least one
training course during
the period

77%

90.6%

2022 Financial scope.

Employees still under contract at
the end of the period are taken
into account.

CSR target included in
the variable and longterm compensation of
the members of the
Executive Committee

Number of employees whocompleted at least one online
training module during the period/
Total headcount.

2022 CSR scopeof reporting.
2022 Financial scope.

Employees still under contract at
the end of the period are taken
into account.

Ambassadors% of ambassadors

8.9%

8.4%

Total number of ambassadors
among all employees/Total
headcount.

2022 scope of CSR
reporting (excluding
TuneCore Japan, 6&7,
Jo&Co, DMC & NetD).

97%

95%

Number of employees who
validated at least one career review
during the period/Total
headcount.

2022 scope of CSR
reporting (excluding
TuneCore Japan, 6&7,
Jo&Co, DMC & NetD).

CSR target included in
the variable and longterm compensation of
the members of the
Executive Committee
Career reviews% of employees who
validated at least one
career review during
the period

A career review is considered“validated” when a report has beendrafted and signed by theemployee and their assessor (their
manager or one of their
managers).

Extract from Universal registration document 2022 - Believe62

2

Corporate social responsibility
Methodological note and summary of indicators

Environmental indicators
Performanceindicator

2022

2021

Definition

Total surface area ofsites in m2

24,351.6

25,875.2

Total surface area of sites where 2022 CSR scopeGroup employees work (excluding of reporting.
co-working spaces).
2022 Financial scope.

Number of company
vehicles51-

Number of vehicles allocated to 2022 CSR scope of
employees as part of their duties, reporting.
regardless of their type of contract 2022 Financial scope.
(permanent,
fixed-term,workstudy, apprenticeship) during or
before the period.

1,586,136.95

1,642,170.85

Sum of electricity consumption at 2022 CSR scope ofall sites where Group employees reporting.
operate(excluding
co-working 2022 Financial scope.
spaces) during the period.

65.13

63.46

Scope

Site description

Energy consumption
Total electricity
consumption in kWh
Scope 1
Total electricity
consumption/m2

2022 scope of CSR
reporting.

Scope 1% of renewable energy
in total electricity
consumption

2022 Financial scope.
80%-2022 scope of CSR
reporting.
2022 Financial scope.

Scope 11,304,373.05

863,379.15

Urban heating, domestic fuel oil 2022 CSR scope ofand natural gas consumption in reporting.
kWh are taken into account 2022 Financial scope.
(excluding
co-working
spaces)during the period.

Total consumptionof other energy
sources/m2

53.56

33.36

Sum of electricity consumption at 2022 CSR scope ofall sites where Group employees reporting.
operate(excluding
co-working 2022 Financial scope.
spaces) during the period/total
surface area of the sites where theGroup’s employees work (excluding
co-working spaces).

Total energy
consumption in kWh

2,890,510

2,505,550

Total consumptionof other energy
sources in kWh
Scope 2

Scopes 1 and 2
Total energy
consumption
in kWh/m2

2022 Financial scope.
0.12

96.80

Scopes 1 and 2

632022 CSR scope ofreporting.

Extract from Universal registration document 2022 - Believe2022 CSR scope ofreporting.
2022 Financial scope.

www.believe.com

Corporate social responsibility
Methodological note and summary of indicators

Performanceindicator

2022

2021

Definition

GHG emissions –scope 1306.18448.95

GHG emitted by the Group’s 2022 CSR scope ofactivities under scope 1 (offices reporting.
and buildings) (in TeqCO2).
2022 Financial scope.

GHG emissions –scope 2401.86422.12

GHG emitted by the Group’s 2022 CSR scope ofactivities under scope 2 (indirect reporting.
emissions related to energy 2022 Financial scope.
consumption
andcompany
vehicles) (in TeqCO2).

GHG emissions –scopes 1 and 2

708.04871.07

GHGs emitted by the Group’s 2022 scope of CSR
activities under scopes 1 & 2.
reporting.

GHG emissions –scope 3 – Transport

235.50-GHG emitted by the Group’s 2022 scope of CSR
activities as part of employee reporting.
business travel (in TeqCO2).
2022 Financial scope.

Scope

GHG emissions

2022 Financial scope.

Waste Electrical and Electronic Equipment (WEEE)% of WEEE recycled(France)

100%

95%

Quantity of WEEE recycled by the France.
sites in kilograms/Quantity of WEEE
produced by the sites in kilograms.

Extract from Universal registration document 2022 - Believe64

2

Corporate social responsibility
Report by one of the Statutory Auditor, appointed as independent third party, on the consolidated non-financial statement

2.8 Report by one of the Statutory Auditor,
appointed as independent third party,on the consolidated non-financial statement
For the year ended 31 December 2022
This is a free English translation of the Statutory Auditor’s report issued in French and is provided solely for the convenience ofEnglish-speaking readers. This report should be read in conjunction with, and construed in accordance with, French law andprofessional standards applicable in France.
To the Annual General Meeting,In our capacity as Statutory Auditor of your company (hereinafter the “entity”) appointed as independent third party, andaccredited by the French Accreditation Committee (COFRAC) under number 3-1884(1), we have undertaken a limited
assurance engagement on the historical financial information (observed or extrapolated) in the consolidated non-financial
statement, prepared in accordance with the entity’s procedures (hereinafter the "Guidelines"), for the year ended…
(hereinafter, the "Information" and the "Statement" respectively), presented in the Group’s management report pursuant to
the legal and regulatory provisions of Articles L. 225102-1, R. 225-105 and R. 225-105-1 of the French Commercial Code (Codede commerce).

Conclusion
Based on the procedures we have performed, as described under the "Nature and scope of procedures" and the evidence
we have obtained, nothing has come to our attention that cause us to believe that the consolidated non-financial statement
is not prepared in accordance with the applicable regulatory provisions and that the Information, taken as a whole, is notpresented fairly in accordance with the Guidelines, in all material respects.

Preparation of the non-financial performance Statement
The absence of a commonly used generally accepted reporting framework or a significant body of established practices on
which to draw to evaluate and measure the Information allows for different, but acceptable, measurement techniques that
can affect comparability between entities and over time.
Consequently, the Information needs to be read and understood together with the Guidelines, summarized in theStatement and available on the Entity’s website or on request from its headquarters.

Inherent limitations in preparing the Information
As stated in the Statement, the Information may be subject to uncertainty inherent to the state of scientific and economic
knowledge and the quality of external data used. Some information is sensitive to the choice of methodology and theassumptions or estimates used for its preparation and presented in the Statement.

Responsibility of the entity
Management of the Entity is responsible for:
●
●

●
●

selecting or establishing suitable criteria for preparing the Information;
preparing a Statement pursuant to legal and regulatory provisions, including a presentation of the business model, adescription of the main non-financial risks, a presentation of the policies implemented considering those risks and theoutcomes of said policies, including key performance indicators, and the information set out in Article 8 of Regulation(EU) 2020/852 (Green Taxonomy);
preparing the Statement by applying the Entity’s “Guidelines” as referred above; anddesigning, implementing and maintaining internal control over information relevant to the preparation of theInformation that is free from material misstatement, whether due to fraud or error.

The Statement has been prepared by the Board of Directors.
(1) Accreditation Cofrac Inspection, number 3-1884, scope available at www.cofrac.fr

65

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Report by one of the Statutory Auditor, appointed as independent third party, on the consolidated non-financial statement

Responsibility of the Statutory Auditor, appointed as independent third party/
independent third party
Based on our work, our responsibility is to provide a report expressing a limited assurance conclusion on:●●

the compliance of the Statement with the requirements of Article R. 225-105 of the French Commercial Code;the fairness of the information provided pursuant to part 3 of Sections I and II of Article R. 225-105 of the French
Commercial Code, i.e., the outcomes of policies, including key performance indicators, and measures relating to the mainrisks, hereinafter the “Information”.

As we are engaged to form an independent conclusion on the Information as prepared by management, we are notpermitted to be involved in the preparation of the Information as doing so may compromise our independence.
It is not our responsibility to report on:●

the entity’s compliance with other applicable legal and regulatory provisions (particularly with regard to the information
set-out in Article 8 of Regulation (EU) 2020/852 (Green taxonomy) and provisions against corruption and tax evasion);●

the fairness of information set-out in Article 8 of Regulation (EU) 2020/852 (GreenTaxonomy);●

the compliance of products and services with the applicable regulations.

Applicable regulatory provisions and professional guidance
We performed the work described below in accordance with Articles A. 225-1 et seq. of the French Commercial Code, theprofessional guidance issued by the French Institute of Statutory Auditors (Compagnie Nationale des Commissaires aux
Comptes) applicable to such engagement, in particular the professional guidance issued by the Compagnie Nationale desCommissaires aux Comptes, “Intervention du commissaire aux comptes - Intervention de l’OTI - Déclaration de performance
extra-financière”, acting as the verification program, and with the International Standard on Assurance Engagements 3000
(revised)(1).

Our independence and quality control
Our independence is defined by the provisions of Article L. 822-11 of the French Commercial Code and the French Code of
Ethics for Statutory Auditors (Code de déontologie) of our profession. In addition, we have implemented a system of quality
control including documented policies and procedures aimed at ensuring compliance with applicable legal and regulatory
requirements, ethical requirements and the professional guidance issued by the French Institute of Statutory Auditors(Compagnie Nationale des Commissaires aux Comptes) relating to this engagement.

Means and resources
Our work engaged the skills of five people between November 2022 and March 2023 and took a total of three weeks.
We were assisted in our work by our specialists in sustainable development and corporate social responsibility. We
conducted about a dozen interviews with the people responsible for preparing the Statement.

Nature and scope of procedures
We are required to plan and perform our work to address the areas where we have identified that a material misstatementof the Information is likely to arise.
The procedures we performed were based on our professional judgment. In carrying out our limited assurance engagementon the Information:●●●

we obtained an understanding of all the consolidated entities’ activities, and the description of the principal risks
associated;
we assessed the suitability of the criteria of the Guidelines with respect to their relevance, completeness, reliability,
neutrality and understandability, taking into account, where appropriate, best practices within the sector;
we verified that the Statement includes each category of social and environmental information set out in article L. 225102-1 III as well as information regarding compliance with human rights and anti-corruption and tax avoidance
legislation;(1) ISAE 3000 (Revised) - Assurance Engagements Other Than Audits or Reviews of Historical Financial Information

Extract from Universal registration document 2022 - Believe

66

2
●

●

●

Corporate social responsibility
Report by one of the Statutory Auditor, appointed as independent third party, on the consolidated non-financial statement

we verified that the Statement provides the information required under article R. 225-105 II of the French Commercial
Code, where relevant with respect to the main risks, and includes, where applicable, an explanation for the absence of
the information required under article L. 225-102-1 III, paragraph 2 of the French Commercial Code;we verified that the Statement presents the business model and a description of principal risks associated with all the
consolidated entities’ activities, including where relevant and proportionate, the risks associated with their business
relationships, their products or services, as well as their policies, measures and the outcomes thereof, including key
performance indicators associated to the principal risks;
we referred to documentary sources and conducted interviews to:
●

●

●

●

we obtained an understanding of internal control and risk management procedures the Entity has implemented andassessed the data collection process aimed at ensuring the completeness and fairness of the Information;●●

corroborate the qualitative information (measures and outcomes) that we considered to be the most importantpresented in Appendix. Concerning certain risks(1), our work was carried out on the consolidating entity, for the otherrisks, our work was carried out on the consolidating entity and on a selection of entities(2);we verified that the Statement covers the scope of consolidation, i.e. all the consolidated entities in accordance witharticle L. 233-16 of the French Commercial Code within the limitations set out in the Statement;●●

assess the process used to identify and confirm the main risks as well as the consistency of the outcomes, including
the key performance indicators used, with respect to the main risks and the policies presented,

for the key performance indicators and other quantitative outcomes that we considered to be the most importantpresented in Appendix, we implemented,
analytical procedures to verify the proper consolidation of the data collected and the consistency of any changes inthose data;

tests of details, using sampling techniques, in order to verify the proper application of definitions and procedures andreconcile the data with supporting documents. This work was carried out on a selection of contributing entities4 andcovers between 22% and 100% of the consolidated data relating to the key performance indicators and outcomesselected for these tests;
we assessed the overall consistency of the Statement based on our knowledge of all the consolidated entities.

The procedures performed in a limited assurance review are less in extent than for a reasonable assurance opinion inaccordance with the professional guidance of the French Institute of Statutory Auditors (Compagnie Nationale desCommissaires aux Comptes); a higher level of assurance would have required us to carry out more extensive procedures.

Paris-La Défense, on 15 March 2023
KPMG S.A.
Jean-Pierre Valensi
Partner

Anne Garans
ESG Expert(1) Risk of lack of consistency and efficiency in HR and talent management processes; Risk of exclusion of certain communities and musicalgenres, and of non-alignment with Believe's values; Risk of digital divide, invisibility and lack of skills of artists to make the best use of newtechnologies and digital marketing practices; Risk of limiting the freedom of expression and independence of artists and labels, and of notrespecting private data; Risks in terms of respect for human rights and the fight against corruption and tax evasion(2) Believe S.A.

67

Extract from Universal registration document 2022 - Believewww.believe.com

Corporate social responsibility
Report by one of the Statutory Auditor, appointed as independent third party, on the consolidated non-financial statement

Appendix
Qualitative information (actions and results) considered most important
Employee well-being assessment systems
Talent attraction and retention schemes
Programmes for training and career development of artists
Actions to raise employee awareness of environmental protection
Initiatives to support women artists and under-represented communities in the music industry
Personal data protection measures in place
Human rights measures in place
Business conduct and anti-corruption procedures in place

Key performance indicators and other quantitative results considered most important
Total number of employees at the end of the year
Share of women among managers
Percentage of employees who attended at least one training course during the year
Percentage of employees who have followed the training Code of ethics and/or anti-corruption and/or conflict of interest
Absenteeism rate
Turnover rate
Percentage of employees who have had at least one career development interview during the year
Percentage of Believe ambassadors among employees
Share of participation in the 2022 employee share ownership programme
Energy consumption per m2 for offices (kWh/m2)
Greenhouse gas emissions (scope 1 and 2) in tonnes of CO2 equivalent
WEEE recycling rate

Extract from Universal registration document 2022 - Believe

68