Ahead of her exclusive presentation at the Sustainability Reporting Summit, we interviewed Gundula Ullah, Chief Sustainability Officer at FUNKE, one of Germany’s leading media groups. Operating across regional media, national brands, and digital platforms, FUNKE employs more than 1,700 journalists and 3,000 other media professionals, generating annual revenue of around EUR 1 billion. As an industry leader, its scale and influence make it a fascinating case study in how complex organisations adapt to new sustainability mandates.

In our conversation, Gundula shared how the EU’s sustainability reporting rules forced real, operational change within a legacy media company; from rethinking data systems and supply chain expectations to embedding new accountability structures across the business.

Australian organisations now face a parallel challenge under the upcoming Australian Sustainability Reporting Standards (ASRS). The experience of European companies like FUNKE shows that success depends on treating sustainability reporting as a catalyst for transformation, not a box-ticking exercise.

When regulation stops being a policy discussion and starts shaping contracts, supplier relationships, and governance structures, organisations must decide whether to comply minimally or use the change to strengthen operations. FUNKE chose the latter. Their experience navigating the EU’s evolving reporting and due-diligence requirements offers clear, practical lessons for Australian finance, procurement, and sustainability teams preparing for the same shift.

Why FUNKE’s story matters now

The EU’s Corporate Sustainability Reporting Directive (CSRD) came into force for the first cohort in the 2024 financial year, with reports published in 2025, a watershed moment for European disclosure. In Australia, the AASB finalised the first Australian Sustainability Reporting Standards (AASB S1 and mandatory AASB S2) in September 2024, creating a national baseline for sustainability-related financial disclosure. At the same time, national due-diligence laws such as Germany’s Supply Chain Act (LkSG), effective 1 January 2023, pushed companies to interrogate supplier practices in new detail.

Those regulatory inflections matter because they change what stakeholders expect, and they change what organisations need to produce: standardised, verifiable, activity-linked data that connects sustainability performance to business decisions and financial statements.

What changed first at FUNKE

As Gundula Ullah summarised it plainly: “At FUNKE, the EU Corporate Sustainability Reporting Directive (CSRD) became more than a compliance exercise – it was a strategic lever to strengthen transparency and governance across the Group.”

In practice, the shift had a clear trigger beyond CSRD itself: German due-diligence rules required deeper supplier scrutiny. FUNKE “screened around 400 suppliers, (re-)establishing dialogue and assessing compliance levels in detail,” which revealed fragmented and inconsistent data across business units. That experience reframed reporting as an operational data challenge rather than a communications task.

The lesson is practical: when external rules change, the first organisational casualty is often data. That’s why FUNKE pushed reporting upstream, embedding it in supplier contracts and procurement processes to secure accuracy at the source.

Surprising operational findings

Two technical discoveries shaped FUNKE’s response.

First, “spend-based calculations only provide a very rough picture of emissions. Once we moved to activity-based data – measuring actual paper tonnage, print runs, and transport distances – we could finally see where our impact really lay.” Working at activity level exposed material hotspots, and the company now monitors “around 60 emission factors in detail across the Group.” These are not academic distinctions: they change procurement choices and the levers that reduce real emissions.

Second, the energy source used in paper and printing was decisive. FUNKE’s “WAZ Climate Pilot” switched paper production and print operations to green energy, cutting that title’s emissions by more than 70%, and led to the operational rule: “We must include the ‘green’ factor in the tonnage allocation of our paper suppliers, i.e. those partners receive more quantities that make the most use of green energy in their production processes.”

For Australian organisations, the equivalent might be mapping activity-level emissions in high-impact areas (manufacturing, logistics, energy use in campuses, etc) and then using procurement levers to shift demand to lower-impact suppliers.

How reporting reshaped conversations

Reporting didn’t just create paperwork, it reframed relationships. Gundula describes the change across FUNKE’s value chain: procurement had to be educated and brought into the reporting process; advertisers and agencies began using their own sustainability metrics; and readers looked for “trust” more than marketing spin. FUNKE’s experience highlights a practical tension many companies face: stakeholders are demanding data, but the data landscape is fragmented, advertisers and partners often use inconsistent metrics, creating friction for publishers and suppliers alike.

There’s also a reputational tightrope. Gundula warned about the rising tendency for silence: “This new trend of ‘greenhushing,’ staying silent about sustainability, is just as dangerous. It risks losing trust among employees, partners, and future consumers who expect authenticity and courage, not silence.” Recent industry analysis and reporting confirm greenhushing is an observable trend as companies navigate political backlash and regulatory scrutiny globally.

What FUNKE prioritised next

FUNKE’s view is forward-looking and procedural. They declined to wait for Brussels to finish its regulatory debates: “If we paused every time an EU directive or ‘Omnibus package’ was still in political negotiation, we’d lose another 12 to 18 months of real progress.” That philosophy drives three practical priorities: tighten activity-level measurement, bake sustainability into procurement levers, and invest in the organisational capabilities needed for repeated, auditable disclosures.

Five practical lessons from FUNKE for Australian organisations preparing to report

1. Start with activity, not spend. Map tonnages, run lengths, transport distances and other activity metrics for the categories that drive emissions. FUNKE’s jump from spend-based to activity-based data revealed the true hotspots.
2. Mobilise procurement early. Embed reporting needs into contracts and supplier onboarding so data flows upstream rather than being collected ad hoc. FUNKE’s supplier screenings and contract changes made data collection possible.
3. Budget for assurance and controls. Treat sustainability numbers like financial data: nominate owners, define controls and budget for external assurance as standards and stakeholder expectations mature.
4. Avoid greenhushing by being transparently imperfect. As Gundula says, “start early, even with imperfect data. Build, learn, refine. CSRD is not a one-off project, it’s a continuous process of alignment and improvement.” Transparent progress builds credibility faster than polished silence.
5. Translate reporting into procurement demand signals. Where supplier production choices (e.g., use of renewable energy) materially change emissions, allocate demand accordingly. FUNKE formalised a “green” tonnage allocation for paper suppliers; Australian firms can design equivalent procurement incentives.

A short checklist to begin, with practical next steps:

• Identify ASRS applicability and reporting timelines for your entity.
• Run a 3–6 month activity-level data gap analysis in your top 3–5 emission categories.
• Nominate a sustainability-data owner inside finance or procurement.
• Update supplier contracts to request activity data and evidence of energy sources.
• Budget for systems, staff time and assurance in the next financial year.

Final note

FUNKE’s path is not a one-size-fits-all playbook, but it’s a clear demonstration that reporting becomes durable only when it is operational: when data, procurement and governance align. As Gundula put it, “sustainability is not a department, it’s a direction.” For Australian organisations aligning to the ASRS, the practical work starts now: measure activities, mobilise procurement, and commit to iterative transparency. That’s how mandates become muscle, and how credible, resilient disclosure programs are built.

Join Gundula and dozens of other thought-leaders at the Sustainability Reporting Summit 2026 in Sydney from 3-5 March 2026. Learn more.