50
•
Training programmes and periodic update for the personnel involved in the
preparationand reviewof the financial information, and in theassessment of the
Internal Control over Financial Reporting (ICFR) system, which cover at least
accounting rules, audit, internal control and riskmanagement.
The organisational structure of the Atresmedia Group is defined by the CEO
when it affects the senior management level, and by themanagers in charge of
eachorganisational unitwhen it corresponds to the rest of the resource levels.
The lines of responsibility of the AtresmediaGroup in the different processes for
the preparation of financial information are shown in the organisation chart of
theGroupandof thedifferent organisational areas.
The Internal Audit and Process Control department is the area responsible for
defining themainprocesses and linesof actionat theAtresmediaGroup.
The Atresmedia Group’s Code of Conduct, whichwas approved by the Board of
Directors, provides a general description of the policies, principles, objectives
and values of theAtresmediaGroup. In this connection, theBoardof Directors is
responsible for directing and supervising all matters related to effective
compliancewith this code, aswell as the obligation to adopt and implement the
appropriate measures to align the Code with the rest of the regulatory and
procedural elements of corporate governance, with which it shares the same
values andobjectives.
The Code of Conduct contains the general guidelines that should be followed by
all the employees in the Atresmedia Group relating to basic principles of
behaviour, relations with and between employees, internal control and
prevention of fraud and commitment with the market, the company and the
community.
The ultimate responsibility with regard to the interpretation and application of
thisCodeof Conduct corresponds to theRegulatoryComplianceCommittee.
Currently, the Atresmedia Group's code of conduct has been communicated to
all Group employees through a specific notification for this purpose, inwhich all
themainaspects thereof and theobligationswhichmust bemet by all theGroup
employees in relation to this Codewere specified. Likewise, this Codeof Conduct
was publishedon the corporatewebpagewww.atresmediacorporacion.com and
on theGroup's Intranet in order to be consulted by any employee or third party
relatedwith theGroup.
The Atresmedia Group has set up a “Whistleblower Channel” that allows its
employees to communicate, in a simple and confidential manner, those actions
which, to their understanding, constitute conduct or actions that do not comply
with theCodeof Conduct or other applicable regulations.
Likewise, this is the communication channel which may also be used to detect
irregularities in the preparation of financial reporting; or to ascertain significant
weaknesses in the Internal Control over Financial Reporting (ICFR) system; or in
the prevention of situations of discrimination, harassment at work and sexual
harassment, and the prevention of any other illegal conduct or any conduct
whichgoes againstAtresmedia's policies andvalues.
The Regulatory Compliance Committee is the body responsible for its
management, composed of executive posts which are identified in the Code of
Conduct itself, all relatedwith areas and procedures regulated in the Code. The
