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In the hierarchy, the Regulatory Compliance Committee is accountable to the
Board of Directors, without affecting, where appropriate, the information
which must be submitted to the Audit and Control Committee (for the matters
which specifically relate to this Committee) or to the CEO (for matters related
with management).
Currently, the Atresmedia Group's Code of Conduct has been communicated to
all Group employees through a specific notification for this purpose, in which
all the main aspects thereof and the obligations which must be met by all the
Group employees in relation to this Code were specified. Likewise, this Code
of
Conduct
was
published
on
the
corporate
web
page
www.atresmediacorporacion.comand on the Group's Intranet in order to be
consulted by any employee or third party related with the Group.
•
Whistleblower channel, which enables disclosure to the Audit Committee of
irregularities of a financial and accounting nature, in addition to possible
breaches of the Code of Conduct and irregular activities in the organisation
notifying, where appropriate, whether the latter is of a confidential nature.
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 the Code of 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 which goes against Atresmedia's policies and values.
The Regulatory Compliance Committee is the body responsible for its
management, composed of executive posts which are identified in the Code of
Conduct itself. The Whistleblower Channel will be monitored by the Internal
Audit and Processes Control area and by General Corporate Management.
The Regulatory Compliance Committee will report regularly to the Audit
Committee regarding those matters which have been identified and
investigated via the Whistleblower Channel set up.
•
Training programmes and periodic update for the personnel involved in the
preparation and review of the financial information, and in the assessment of
the Internal Control over Financial Reporting (ICFR) system, which cover at
least accounting rules, audit, internal control and risk management.
At present, the Atresmedia Group provides all employees involved in the
preparation and review of the financial information with the necessary
training to carry out their functions. Said training is carried out through a
series of adequately planned training courses.
All employee training plans are integrated within the Atresmedia Group's
Training Plan, which is prepared and reviewed annually based on the training
objectives defined at Group level by each organisational area/business unit,
depending on the training needs identified.
In this regard, the areas most related with the Internal Control over Financial
Reporting system, which are the Financial Department, the Internal Audit and
Processes Control Department and the Legal Advisory Department, have
received a series of technical training courses related with accounting rules,
risk management, tax rules, penal compliance, etc. which enabled them to
update the knowledge required to ensure the correct functioning of the ICFR.