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body entrusted with analysing breaches and proposing remedial and penalty
measures.
The Code of Conduct forms part of Atresmedia's corporate responsibility and
good governance policies, whose determination and ultimate tutelage
corresponds exclusively to Atresmedia's Board of Directors.
In this regard, the Atresmedia Group's Code of Conduct was approved by the
Board of Directors. The Board of Directors is responsible for directing and
supervising all matters related to effective compliance with this code, as well
as the obligation to adopt and implement the measures that may be necessary
to align the Code with the rest of the regulatory and procedural elements of
corporate governance, with which it shares the same values and objectives.
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.
With respect to the preparation and publication of financial information,
article 7.4.3 of the Code of Conduct stipulates Atresmedia's undertaking to
provide informative transparency, understood to be the commitment to
transmit reliable information to markets and to the company, which permits
them to form a true and fair view of its activities, strategy and economic, social
and environmental performance. Likewise, it is bound to immediately
broadcast any information which is relevant for investors, by applying the
channels established by the CNMV.
This article stipulates that Atresmedia's employees must transfer the
information in a true, integral and understandable manner. In no case, will
they knowingly provide incorrect, untrue or imprecise information which may
lead to errors on the part of the person receiving it. Likewise, it establishes the
obligation for all Atresmedia's transactions to be clearly and accurately
included in its accounting records and, in particular, all the accounts must be
correctly reflected in the records, together with all the transactions performed
and all the expenses incurred. In general, the Code stipulates that
Atresmedia's employees will abstain from any practice which contravenes the
undertaking to clearly and accurately reflect the transactions in Atresmedia's
records, and will take special care in terms of the reliability of the information
introduced in Atresmedia's IT systems.
Likewise, article 7.4 on Transparency and Confidentiality establishes the
obligation, and rigour in the processing of personal and business data
constitutes solid support to obtain a climate of mutual trust, via the adequate
protection and reservation of the information held and of the permanent
undertaking to inform in a complete, objective and true manner customers,
internal and external workers, the market and the company. It also stipulates
that the deliberate falsification, manipulation and use of false information
constitutes fraud.
The ultimate responsibility with regard to the interpretation and application
of this Code of Conduct corresponds to the Regulatory Compliance Committee.
This Committee is, inter alia, responsible for managing and supervising its
compliance, for supporting the Internal Audit Department in the management
of the Internal Control over Financial Reporting (ICFR) system, and for
coordinating the management of the specific communication channel which
was implemented at Atresmedia to receive the communications of employees
in the areas relating to the effective and correct integral application of all
these regulations within the Group: Whistleblower channel