Sanoma Corporation
Sanoma
Sanoma is the leading European learning company in the K12 segment.
ID: 712395115155-72
Lobbying Activity
28 May 2025
Sanoma's feedback on EC Implementing Act on labels and transparency notices of political advertisements Sanoma Media Finland Oy (Sanoma) is the leading multi-channel media company in Finland. It offers a wide range of media services, including newspapers, magazines, TV and radio channels an digital marketing in its media channels. Sanoma is thankful of the opportunity to comment on the European Commission's implementing act regarding labels and transparency notices for political advertisements. The political advertising has functioned well in Finland and the local regulation and the local practice has been sufficient to secure the transparency, reliability and fairness of the elections and related advertising. Transparency of Political Advertising Regulation (EU) 2024/900 (Regulation) effects greatly the political advertising in Finland and imposes both costly technical obligations and heavy administrative burden to the effected parties. The new obligations may lead to the publication of election advertising no longer being profitable for media companies. This risk is especially high for smaller and local news papers with small resources as well as radio advertising as the requirements are poorly suited for audio advertising environment. The obligations likely will lead to a decrease of political advertising and, therefore, will jeopardize access to information concerning elections, the political parties and their candidates. If this happens, the regulation has failed, and it may have far-reaching effects on the visibility of elections and democracy. Therefore, the implementing act should only clarify the existing obligations as well as try to make it as easy as possible to comply with the Regulation. The implementing acts should be flexible and allow local media companies to implement the obligations as simply and effortlessly as possible and in accordance with local practices. This means that the acts should not include binding visual or other examples of the transparency notice and there would be room to place the required information on the adverts in accordance with existing practices and also in innovative manner main idea should be that as long as the basic idea of the requirements is respected, the implementation should be compliant. We have also identified certain sections in the draft implementing act that include points without clear references or justifications in the main text. For instance, Part II of the template for audio labels lacks context and rationale, making it challenging to grasp the purpose behind specific requirements and reducing the document's effectiveness. We have listed below some points that should be further considered in the annexes: Annex I (Common Requirements): Clarification needed that transparency notices refer to links/QR codes, not the notice itself. Inconsistencies between audio label requirements in different annexes. The requirement for the announcement in audio should be in higher volume should be removed as unnecessary and non-consumer friendly. in the requirements for TV and radio Point 4 reads In the case of political advertisements made available on television and radio broadcasts, the transparency notice shall be provided separately, in accordance with the technical specifications laid down in Annex 3. However, there is no specific reference in Annex 3 about radio broadcasting so specific guidance is lacking. Specific requirements for print: the guidance with regard to transparency notices that can be found within the label are contradictory in this section and in Annex 3. Specific requirements for digital and online medium: The section does not make any reference to an icon. Further clarifications are needed as to what constitutes a responsive design Annex II (Templates): Visual labels should clearly indicate "Political Advertising" without overcrowding. Part I should only mention that the advertising is Political
Read full responseResponse to Evaluation of the Geo-blocking Regulation
11 Mar 2025
The commercial TV and radio broadcasting industry within the member states is almost exclusively local. The advertising market is local and the content acquisition market is local, and defined by acquiring content rights for a broadcasting certain territory, i.e. country. Geo blocking is ion benefit for a rich and versatile local content offering. Removing geo blocking would disrupt the whole broadcasting industry leading up to a smaller number of very large broadcasters that have the resources and capacity to acquire content right for multipilple, if not all member state markets. This would significantly decrease both to number and versatility of local differentiating AV culture, hence leading to a great number of unemployment in the AV sector.
Read full responseResponse to Interim evaluation of the European Education Area
13 Sept 2023
Sanoma thanks for the opportunity to provide input, and express our views as follows: To decrease share of underachievers in education and to increase equality among students, regardless of socioeconomic background, member states should be encouraged to increase spend/student in professionally produced education materials (methods). Investing more education materials for students, including exercise books and digital learning content, tools & platforms safeguards every childs right to a good and equal education regardless their socioeconomic background, thus decreasing share of students underachieving in their studies. For further information please be in contact with Sanomas Director of Public Affairs, Mr. Marcus Wiklund (marcus.wiklund@sanoma.com, mobile: +358 400 603 147). Background Education is the foundation for personal fulfilment, employability, and active and responsible citizenship, and it is essential to the vitality of European society and economy. The European Education Area aims to bring to the education and training communities the support they need to fulfil their fundamental mission, in challenging and exciting times. The Commission have set 6 KPIs to monitor success and progress in reaching these targets. Good progress have been made in some areas, whereas some areas are still far away from reaching their targets. The share of underachievers is significantly below the set target of max 15% of students. EU did not succeed to reduce the share of 15-year-olds achieving low levels of reading, maths and science to less than 15% by 2020. The EU as a whole is lagging behind in all three domains: more than one in five 15-year-olds cannot complete simple tasks in these subjects, and the results are strongly correlated with socioeconomic status. The path for success in education starts from the basic education in primary and continues throughout secondary education. Attention must be given especially for achieving solid basic skills in primary education. Any lacks in these skills cannot be repaired later during the school years. Strong solid basic skills form the foundation for further success in education. According to the finding of the European Teachers Survey, that cover insight from over 12.000 teachers around Europe in 2023, the use of professionally produced methods is key for reaching good learning outcomes. The European Teacher Survey, measure the impact of methods on learning outcomes, efficiency, and engagement. The survey key findings are: More than 2/3 of the teachers say that methods strongly support reaching these aforesaid targets. Teachers find using methods saving up to 2 days week time in preparing lessons and correcting assignments, leaving more time to focus in teaching Between member states occurs great variations in spend/student on education materials. Primary Secondary spend/student spend/student Poland 25 50 Italy 35 155 Sweden 60 60 Spain 95 80 Belgium 110 n/a Netherlands 120 270 Finland 120 425 Germany 210 305 As the education materials costs typically represents only 1-2 % of the total costs of education, savings to mitigate e.g. inflation should not be made. Quite the opposite, investing more in education materials for students, including exercise books and digital learning content, tools & platforms safeguards every childs right to a good and equal education regardless their socioeconomic background, thus decreasing share of students underachieving in their studies. Sanoma is the leading European learning company in the K12 segment operating in 12 European countries offering full range of digital and printed education materials/paltforms. Sanoma offers its contribution, insight, data and participation to work closely with the Commission to promote and execute a European Education Area. For further information please be in contact with Sanomas Group Director of Public Affairs, Mr. Marcus Wiklund (marcus.wiklund@sanoma.com, mobile: +358 400 603 147).
Read full responseResponse to Improving the provision of digital skills in education and training
16 Sept 2022
Sanoma is the leading European learning company in the K12 segment. We operate in twelve European countries and employ more than 5,000 professionals.
Sanoma support the long term strategic initiative of Improving digital skills as set in this EU consultation.
For best outcome, the topic must be addressed coherently through all education levels from primary to university level with a cross-disciplinary approach covering mathematics and informatics, service design, UX, business administration and research. Success would benefit by setting goals with clear measurable targets and focus.
For primary and secondary education success in an accelerated approach would require:
a) “digital skills” to be included in the curricula as a separate subject
b) investment in teacher education resourcing to ensure good capabilities in teaching this subject
c) investing in education materials and materials supporting the teacher
d) ensuring availability of IT equipment and connectivity for schools and students
As the leading European education company Sanoma is available for further discussions and in providing insight in opportunities and challenges related to enforcing the recommendation in primary and secondary education.
For additional information please contact Mr. Marcus Wiklund, Director of Public Affairs at Sanoma Corporation (marcus.wiklund@sanoma.com).
Read full responseResponse to Enabling factors for digital education
16 Sept 2022
Sanoma is the leading European learning company in the K12 segment.
Sanoma is in favor of the Commission’s initiative for a recommendation to support member states in their digital transformation in digital education.
Digitalization of education calls for a holistic approach covering all necessary fields for success. The enabling factors for a successful digital education are manifold, and include the provision of high-speed connectivity, digital technology solutions, digital / blended content tailored to learning needs and competent teachers.
Public budgets should reflect the importance of professionally published materials, and adequate allocations should be made for the acquisition of digital resources. An open and competitive market, without distortion from governmental “public service education material offerings”, is the best warranty for a continuously developing offering of highest quality education content and services.
1) High quality and well suited professionally produced methods AND materials that support the teachers in their profession, is a key enabler also concerning digital education materials. Publishers provide high quality educational materials, fit for the different national curricula’s, in formats best serving both students and teachers. These materials develop best on a free and fair open market. This market should not be distorted by public offering or by allowing global platform companies to compete on unfair conditions.
Studies clearly show, that high learning outcomes (PISA score) can only be reached by using professionally produced methods aimed to teach the subject in question.
Digital education methods and materials and services supporting teaching bring efficiency, and in according to research, by saving time for the teachers up to 8 hours /week.
2) The core enabler for high learning outcomes is the teacher. Investments must be done and maintained in university level teacher education and teachers must be supported with adequate tools and materials. Teachers abilities to use and benefit from blended solutions require constantly minding the teachers competences and support their professional development with training. The teacher should always be the one to choose the methods (materials) to be used in the class.
Inclusion is fact and the heterogeneity if students in increasing by amore unite Europe but also as a consequence of immigration. The students in a class have different needs and need to be supported by materials best fit för their individual needs. At the same time, students with gifts and capability to proceed faster in their studies, should be offered more demanding exercises. When investing in education materials this need for versatile materials should be taken into consideration and included in the budgets.
3) Devices and connectivity is a necessity for digital education, but investments in education must be balanced with the focus on the learning and teacher supporting materials and solutions.
4) A factor de-accelerating digitalization in education is the definition of digital education solutions, that commonly push these digital platforms into the highest VAT rate, whereas traditional books (printed or PDF) are included in the TAX exception for reduced VAT’s. Many of today’s education materials are already born digital for native digital learning universes. Inequality in tax treatment should be addressed in the recommendation to be given.
5) Education should be supported by purpose minded data governance that as create a basis for success in digital education. Reaching high learning outcomes and utilizing blended learning solutions requires data driven approach, facilitated research and assessment and sharing of best practices.
Sanoma is open to participate and provide expertise in any further work in finalizing this Recommendation.
Marcus Wiklund, Director of Public Affairs at Sanoma Corporation (marcus.wiklund@sanoma.com)
Read full responseMeeting with Jyrki Katainen (Vice-President)
12 Mar 2018 · artificial intelligence
Meeting with Antti Timonen (Cabinet of Vice-President Jyrki Katainen), Filomena Chirico (Cabinet of Vice-President Jyrki Katainen) and European Publishers Council
1 Feb 2017 · Digital Single Market Strategy and Investment Plan for Europe
Meeting with Patricia Reilly (Cabinet of Commissioner Tibor Navracsics)
27 Jan 2015 · Digital education
Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen)
27 Jan 2015 · Education and skills