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approval of the Regulatory Compliance Committee, to the whole organisation for
compliance.
Code of Conduct, approval body, degree of implementation and instruction,
principles and values included (indicating whether specific mention is made of
the register of transactions and the preparation of financial information), 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 to Atresmedia's Board of Directors.
In this regard, the Atresmedia Group's Code of Conduct was approved by the
Board of Directors, subject to a review by the Regulatory Compliance Committee
and the Audit and Control Committee. The Board of Directors is responsible for
directing and supervising all matters related to effective compliance with this
code, as well as for 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 that
is relevant for investors, by applying the channels established by the CNMV.
This regulation 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 that may lead to
errors on the part of the person receiving it. Likewise, the Code of Conduct
includes the obligation to reflect all Atresmedia transactions clearly and
accurately in the Company’s accounting records. Specifically, all accounts must
be correctly reflected in these records, together with the transactions performed
and all the expenses incurred. In general, the Code stipulates that Atresmedia's
employees will abstain from any practice that 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 entered into
Atresmedia's IT systems.
Likewise, in article 7.4 on Transparency and Confidentiality, it is stated that the
obligation, and rigour in the processing of personal and business data constitutes
necessary support to obtain a climate of mutual trust, through the adequate
protection and reservation of the information held and of the permanent
undertaking to inform customers, internal and external workers, the market and
the Company in a complete, objective and true manner. 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 Division in the management of the Internal
Control over Financial Reporting (ICFR) system, and for coordinating the
management of the specific communication channel that was implemented at
Atresmedia to receive the communications of employees in the areas relating to