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V.
Control and control tools
The system includes a full identification and description of all the controls. All the controls are associated to all
those risks in order to be mitigated; accordingly, the satisfactory application thereof enables the potential
impact of risks materialising to be reduced.
The Atresmedia Risk Management and Control System has different tools which boost internal control and
reduce the potential impact of existing risks:
a.
Procedures and protocols -including most notably-:
Notification management
Criminal risk procedures
Use of Information Technology and Communication (ITC) resources
Delegation management
Recruitment of executives
New contractual clauses
Guide on the use of cookies
Domain management
ARCO procedure
Seizure flows
Diligence measures related with gambling
Purchases of goods and services
Customer billing objections
Freezing and unfreezing of customers
Bad debt risks
Procedure in the event of an emergency
Media-for-Equity investments
b.
Other IT control tools (additional to the GRC system itself)- including most notably-:
Purchasing management system
Management and authorisation system for contracting proposals
Management and authorisation system for programme estimates
Quality System
c.
Code of Conduct
Its objective is to establish policies, principles, objectives and values which must guide performance within
Atresmedia and in its relationships with third parties and with the company, consolidating a culture and
responsible performance guidelines which are shared, accepted and respected by all people to whom they
apply.
d.
Whistleblower channel:
Enables all employees to notify, in an easy and confidential manner, those procedures which constitute
inappropriate conduct or behaviour under the Code of Conduct or any other applicable legislation, and
especially those which do not comply with the Internal Control over Financial Reporting (ICFR) System.
e.
Control procedures related with the Internal Control over Financial Reporting (ICFR) System:
Atresmedia, in its undertaking to provide reliable, integral, true and uniform information to investments
and to the market, has implemented an Internal Control over Financial Reporting (ICFR) System which
guarantees the accuracy of the financial information issued.
f.
Regulatory Compliance Committee
Body charged with the management, surveillance, coordination and integration of corporate policies and
actions aimed at complying with all applicable legislation and regulations (both external and internal
protocols and procedures), as well as supervision of compliance with the Code of Conduct.
g.
Internal conduct regulation in securities market matters.
h.
Criminal Compliance Head
A specific figure exists charged with providing the necessary advisory services to executives and directors
of Atresmedia in decision making which may have potential criminal consequences.