MATERIALITY ASSESSMENT IMPACT REPORT 2014
Bloomberg Process for Determining Materiality Version 1.0
Revision History Date Version Description Authors Document to detail process by which Bloomberg 5/13/08 1.0 external sustainability reporting. identifies those issues deemed to be material to the Andrew Park, Curtis Ravenel, Jason organization and its stakeholders, and to be included in Shulman
Contents 1. Introduction... 2 1.1 Purpose... 2 1.2 Process Owners... 2 2. Overview and Methodology... 3 2.1 Bloomberg s Categories of Impact... 4 2.2 Materiality Process... 5 2.3 Bloomberg Stakeholder Group Reviews... 5 2.3.1 Internal/Operational/Business Review... 5 2.3.2 Internal Stakeholder Review... 5 2.3.3 Ceres External Stakeholder Review... 6 2.3.4 Internal Employee Review... 6 2.3.5 Cross-Functional Sustainability Industry Review... 6 3. APPENDICES... 7 3.1 Appendix 1 SASB Materiality Matrix... 7 3.2 Appendix 2 GRI G4 Materiality Index... 8 Appendix 2 GRI G4 Materiality Index (cont )... 9 Appendix 2 GRI G4 Materiality Index (cont )... 10 3.3 Appendix 3 Bloomberg Additional Materiality... 11 Page 1 of 11
1. Introduction 1.1 Purpose The purpose of this document is to detail the processes Bloomberg has utilized, and will continue to utilize, to identify those issues deemed to be material to the organization and its stakeholders, as well as those issues Bloomberg will report externally via its annual Sustainability Report. 1.2 Process Owners The owner of this process is the Sustainable Business Operations team. The team is responsible for the content of this document, and all updates/future versions. Page 2 of 11
2. Overview and Methodology Bloomberg s sustainability program began in 2007. From the beginning, we recognized the importance of identifying areas of impact relevant to our business. While this initial assessment was focused primarily on environmental mitigation, our continuing revision and stakeholder engagement processes, along with guidance from the Global Reporting Initiative (GRI), led us to expand the scope of sustainability to reflect a much broader array of material issues. For our 2014 Sustainability Report, as in prior years, Bloomberg is following the GRI guidelines. After utilizing G3 since our initial GRI- compliant report in 2010, this year we are moving to the G4 framework and incorporating the Media Sector supplement. Also noteworthy in 2014 is the integration of sector- specific reporting standards from the Sustainability Accounting Standards Board (SASB). Under SASB s industry classification system, Bloomberg s business offerings can be categorized into three distinct industries: Internet Media & Services, Media Production & Distribution, and Professional Services. SASB standards are designed for use within a public company s annual 10- K filing to the SEC, and the complementary nature of utilizing multiple reporting frameworks here, namely GRI and SASB is most evident in the context of a public company s reporting activities. While Bloomberg, as a private company, is not subject to those reporting requirements, we have nevertheless embarked on what we believe to be an important integrative exercise given the rapid evolution of the corporate reporting field. Bloomberg is utilizing these frameworks in an integrative fashion for the purposes of this reporting exercise and has produced what is essentially a sample MD&A (Management Discussion & Analysis) for Bloomberg s three applicable SASB industries alongside the full GRI G4 index. It is an opportunity for Bloomberg to show that the GRI and SASB reporting frameworks, geared toward different audiences, can be complementary pieces in a comprehensive sustainability reporting effort. At the heart of this exercise lies the concept of materiality, which is defined in different ways under various reporting frameworks. We do not attempt to formally reconcile divergent uses of the term as between SASB and GRI. Rather, we have developed an implementation methodology that enables the use of both definitions in the context of a single report by a private company. Materiality understood within the GRI framework first leads us to consider a spectrum of issues that are deemed salient in reflecting the company s environmental and social impacts on a wide array of stakeholders. Accordingly, we begin with the larger universe of potentially relevant issues and metrics as delineated under G4. However, as to one specific stakeholder group the investor community we turn to SASB s standards, which reflect the application of a U.S. legal/regulatory definition of materiality as derived from the reasonable investor standard. In utilizing SASB s standards for each of the applicable sectors, we rely on its evidence- based research process to have surfaced those sustainability issues most likely to be salient for Bloomberg LP s financial and operational performance. This report leads with a high- level Issue table of both SASB s potentially material issues for the applicable sectors set within the context of GRI s broader array of Aspects. While we have conducted an exercise of determining what is actually material to Bloomberg LP (since under both frameworks, the ultimate determination of materiality is left to the corporate entity), we acknowledge that this is but a first- step in the direction of a truly streamlined report. For 2014, Bloomberg continues to report on the full complement of applicable GRI indicators. As we look to reporting for 2015, we will embark on an even more extensive stakeholder engagement process to conduct a more targeted materiality exercise, determining the most relevant, substantively material indicators culled from both GRI and SASB, thereby continuing to rationalize and improve our reporting process. Page 3 of 11
Bloomberg s aforementioned stakeholder engagement conducted annually for the purpose of determining materiality and soliciting feedback on all facets of our sustainability program, reflects a comprehensive process requiring input from a number of strategic partners including customers, vendors, employees, non- profits, and other experts. Bloomberg s categories of impact and details of stakeholder engagement follow below. 2.1 Bloomberg s Categories of Impact Based on the process outlined above, we have grouped issues into three (3) categories of impact: Issues that impact our company and our employees from a business, environmental and/or social perspective. Issues that do not impact our company directly but impact our strategic partners. Issues that may not have a significant, direct impact for our company or strategic partners, but those for which we recognize our organization has a unique opportunity to make a positive impact. Page 4 of 11
2.2 Materiality Process Bloomberg identified the issues material to its organization and/or stakeholders across these categories by: Reviewing the guidelines for those reporting frameworks (GRI G4 and SASB) that we incorporate into our sustainability reporting. Analyzing our business activity and internal operations for environmental and social impact. Holding multiple stakeholder engagements and reviewing specific issues/concerns identified by these groups throughout this process. Benchmarking issues covered in sustainability reporting of both peer companies and sustainability leaders across sectors and regions. In utilizing both GRI and SASB, the above materiality process identifies salient issues for the business and across multiple other stakeholders against which we seek to report. To the extent that the investor and issuer communities specifically are relevant stakeholders (particularly as clients), we look to SASB s applicable standards to narrow the scope of issues within which we determine those that are ultimately material to Bloomberg. 2.3 Bloomberg Stakeholder Group Reviews The materiality process is driven primarily by the various components of our stakeholder engagement process. A description of the stakeholder groups and the process for engaging them are included below. 2.3.1 Internal/Operational/Business Review An ongoing component of our process, the Sustainable Business & Finance department collaborates with department heads and key personnel from all operations and business departments to: Continuously review our operations for environmental and social impact. This includes identification of potential risks to operations, as well as opportunities for mitigation of these risks. Review with representatives from our various businesses (e.g. Terminal, Markets and Bloomberg Businessweek Magazines, Television, Radio, Bloomberg.com) what sustainability issues are of concern to our customers, and then determine how to translate those concerns into opportunities to incorporate sustainable content into our products, which in turn, helps our customers make better business decisions. 2.3.2 Internal Stakeholder Review At the outset of Bloomberg Sustainability in 2008, an executive steering committee was formed, comprising senior executives representing all business and operations groups in the organization, with bi- annual meetings held to address numerous issues, including materiality. In 2011, those steering committee meetings evolved into individual meetings with the same senior executives, within which Sustainability engaged them on issues relevant to their areas of responsibility. We continue to employ this mode of engagement with key decision- makers, with meetings held with each group leader at least twice per year, if not more frequently. This exercise complements the internal operational/business review, since we meet with senior executives who have close knowledge of the sustainable issues present in their respective groups. Page 5 of 11
2.3.3 Ceres External Stakeholder Review In 3Q of each year, Bloomberg convenes an external stakeholder meeting, organized and moderated by Ceres, with representation from the sustainable business and NGO communities. These stakeholders are joined by key internal stakeholders (Sustainability department, Operations and Business department heads, senior executives), as well as at least one member of the Management Committee. The goal of each meeting is to solicit critical feedback on numerous issues in the format of: A review of our most recently published sustainability report, specifically whether we are adequately reporting on issues material to our company and the broader sustainability community. An evaluation of our short- term and long- term sustainability strategies, from an environmental, social and governance perspective. Where can we improve? Where are we lagging? What else should we be doing? A discussion of global trends in sustainability and how Bloomberg can utilize its resources and unique reach in the business community to support aligned objectives. This exercise provides the candid feedback from external parties needed to maintain a broader understanding of material issues inside and outside of Bloomberg s boundaries. 2.3.4 Internal Employee Review Since the beginning of sustainability at Bloomberg, a very valuable source of input for our determination of materiality has been our employees. We recognize the vested interest our employees have in our sustainability efforts, and through employee surveys they have conveyed the value they derive from working for a company perceived as being at the forefront of the sustainability movement. It is important to provide opportunities for our employees to give feedback on our efforts, and alert us to issues not being considered that otherwise should be. There are multiple methods for soliciting this feedback: The Sustainability department conducts numerous employee engagement events globally throughout the year, at which there are always opportunities for discussion, questions and suggestions. An internal ticket system is available for all employees to submit questions and suggestions directly to the Sustainability department. Direct contact: Bloomberg s internal directory, fully transparent to all employees, enables all employees to reach out to the Sustainability department members directly. 2.3.5 Cross-Functional Sustainability Industry Review At this point, sustainability is woven into the fabric of our organization. Across all operating and business departments, Bloomberg employees proactively attend industry meetings and conferences, as well as moderate and speak on panels at which sustainability issues are prominently featured. From these engagements, we are collectively able to procure formal and informal input on sustainability trends, monitor best practices across industries, identify emerging technologies, and learn from other organizations successes and failures. These valuable inputs inform our understanding of what different constituencies deem to be material, which helps Bloomberg be more comprehensive in its ongoing materiality assessment. Page 6 of 11
3. APPENDICES 3.1 Appendix 1 SASB Materiality Matrix Page 7 of 11
3.2 Appendix 2 GRI G4 Materiality Index Page 8 of 11
Appendix 2 GRI G4 Materiality Index (cont ) Page 9 of 11
Appendix 2 GRI G4 Materiality Index (cont ) Page 10 of 11
3.3 Appendix 3 Bloomberg Additional Materiality Based on our materiality assessment described above, the below is a partial list of specific material issues on which we report, beyond what is otherwise covered under either GRI s G4 or SASB s frameworks: Ability of our products and services to raise awareness about sustainability issues Integrating meaningful data, news and analysis about sustainability across all products and services Ability to continue to innovate Ability to remain competitive Ability to provide superior customer service and support Creating standards for sustainability data Expanding the base of customers we serve with sustainability information More effectively aligning our environmental and social investment strategies Addressing continued growth in employee travel Implementing a global sustainability program with aggressive and comprehensive targets that accounts for local issues Page 11 of 11