Given the nature of Atresmedia’s activity, and the fact that most of its business is carried out in Spain under national legislation, the Group believes that the purchase and dissemination of its content and the relationship with its employees are the aspects meriting the greatest attention so as not to generate any adverse impact on human rights.

In 2023, one of the most relevant aspects was the development of a Human Rights Due Diligence procedure that allowed the Group to identify and assess potential adverse impacts in this regard. Notably, Atresmedia has a corporate Due Diligence Handbook on Human Rights, which acts as an internal guide to ensure that key issues are handled properly and to identify material concerns in this regard should the Group’s business model undergo any changes.

The handbook covers the essential aspects of any due diligence procedure, as prescribed by the Organisation for Economic Co-operation and Development (OECD) in its Guidelines:

• Formulate a commitment on responsible conduct and embed it into policies and procedures.
• Identify and assess adverse impacts.
• Take action to cease, prevent, mitigate adverse impacts.
• Gauge and track the effectiveness of the actions taken.
• Publicly report its approach to human rights, adverse impacts identified, actions taken, complaints/grievances and remediation mechanisms.
• Establish and implement (as and when needed) remediation mechanisms, including a whistleblowing channel.

Another highlight of 2023 was the update by Atresmedia Group of its Code of Conduct, which expressly sets out its commitment to human rights. The Code also addresses issues such as regulatory compliance, respect for ethical values and human rights as basic tenets of the Group’s behaviour and sets out its explicit commitment to respect, protect and comply with the United Nations International Bill of Human Rights, as well as the commitment to the United Nations Guiding Principles on Business and Human Rights and the commitment to the European Charter of Human Rights, which enshrines the protection of personal data as a fundamental right.

In 2023 Atresmedia developed a human rights due diligence handbook to serve as an internal guide for the proper management of the rights flagged as priority concerns

In line with the main national and international instruments on the protection of human rights, Atresmedia also has mechanisms in place for the prevention, identification and eradication of any conduct that might constitute an abuse of fundamental rights, paying particular attention to freedom of expression, the dignity of individuals, the right to honour, privacy and one’s own image, and the protection of personal data. Atresmedia’s values and corporate culture are all about upholding these rights.

Not content with solely updating its Code of Conduct, Atresmedia also updated its Whistleblowing Channel in 2023. This is the preferred means of communication for reporting abuses or violations of human rights and public freedoms by Atresmedia Group or its related persons, in accordance with internationally accepted laws and practices or that are contrary to the provisions of the International Labour Organization (ILO), especially those related to child labour. In 2023, no queries or complaints were received through this channel in connection with abuses and/or violations of human rights.

Aside from the aforementioned Whistleblowing Channel, Atresmedia has other mechanisms enabling it to detect possible human rights abuses, such as the Corporate Responsibility mailbox, which anyone can contact.

Atresmedia also has various mechanisms in place for the protection of human rights, most notably its General Corporate Responsibility Policy, which sets out its firm commitment to respect them and ensure their compliance. More precisely, this policy embodies Atresmedia’s commitment to:

• Promote freedom of expression, diversity, freedom of expression and opinion, and non-discrimination in its news and entertainment content and ensure the protection of human rights, as enshrined in the Universal Declaration of Human Rights.
• Ensure that advertising content strictly respects human rights, firmly rejecting campaigns that incite violence or discrimination, or encourage behaviours that violate human dignity, or that harm minors or any minority group requiring special protection.
• Uphold labour rights by ensuring compliance with ILO provisions, especially those related to the privacy of employees or the work of minors, rejecting any practices that infringe on them or any other of its principles.

Aside from the Corporate Responsibility Policy, there are other policies and procedures that contribute to the protection of human rights, most notably:

HR Policy

The HR Policy sets out the following principles, applicable to all Atresmedia employees:

• Providing stable employment and a rewarding working environment
• Training and promoting the professional development of our workforce
• Attracting and retaining talent
• Guaranteeing human and labour rights
• Championing equality, diversity and work-life balance
• Overseeing a safe and healthy work environment

In addition to these principles, Atresmedia guarantees human and labour rights through its Human Resources Policy, which enshrines international principles of conduct, mainly emanating from the United Nations. These principles refer to compliance with the provisions of the International Labour Organization (ILO), especially those related to child labour, recognising the right to freedom of association and fostering dialogue with the employees’ representatives.

Responsible Advertising Policy

Advertising is a key part of Atresmedia’s business and for that reason the Group is committed to offering advertising that is suitable for all audiences. In this regard, the Company ensures that advertising content clearly upholds the fundamental values of truthfulness, honesty, credibility and respect for human rights, as enshrined in the Responsible Advertising Policy.

Furthermore, in this policy the Group unequivocally pledges to ensure respect for human rights, especially the protection of minors. This has meant not only keeping up with the latest changes in the law, but also adopting a specific framework for the protection of audiences, especially the youngest ones.

For Atresmedia, respect for and protection of human and labour rights is crucial in upholding the rights of all the workers along its value chain, especially its own workers (see section 8.3.5 Safeguarding labour rights).

Upon joining the Group, all new employees must undergo mandatory training in the Group’s Crime Prevention and Compliance Model, the content of which was updated in late 2023 to include human rights issues.

All of the activities and initiatives described in this document illustrate the lengths that Atresmedia Group goes to to uphold the principles of the UN Global Compact and ensure the well-being of its employees and stakeholders.