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Likewise, he/she is in charge of the operating coordination of the measures required to apply the Code of
Conduct and to execute the decisions adopted by the Regulatory Compliance Committee. Lastly he/she is
the head of the implementation of a crime prevention programme within Atresmedia.
6.
Heads
All the System risks and controls have identified the heads thereof, who periodically, in line with the assessment
schedule defined in each case, must implement the control procedures established for each risk.
Aside from the risk and control heads, the figure of supervisor has been defined, charged with
approving/rejecting the assessment of risks and controls performed by the heads at each time.
7.
Test plans and proof
All controls included in the System have defined a test plan which must be executed and completed by the
control head on each of the control assessment dates defined.
Additionally, the System requires that the execution of the controls performed in each period be supported by
documentary proof. This enables the full control assessment performed by the heads to be put in place and
verified, where appropriate, and to have a documentary system of all the controls performed in each period.
In 2015, Atresmedia reinforced its Internal Control and Risk System and, within such system, its Regulatory
Compliance and Criminal Prevention System, to make them effective to identify, prevent and manage risks of all
types, especially criminal risks, implementing the necessary controls. The main novelties of the System are as
follows:
1.
The Company verified the adaptation of the Regulatory Compliance and Criminal Prevention System to
the new regulatory requirements, especially the criminal liability of legal entities and the new types of
crimes. The result of such analysis confirms that the System functions correctly and is adjusted to the
needs of the Atresmedia Group. It also has the capacity and flexibility required to be adapted in the
future to the new business or legal requirements and to improve the Group's quality and efficiency.
2.
A new Regulatory Compliance Director has been appointed, which presides over the Regulatory
Compliance Committee. He is an independent external professional, with greater decision-making and
procedural capacity, since he originates from outside the Group’s organisational and hierarchical
structure.
3.
A new Criminal Compliance Head was appointed by the Board of Directors, in the figure of the Internal
Audit and Process Control Director.
4.
The Regulatory Compliance Committee Regulations were approved, which detail the body’s functions
together with its lines of action.
5.
The scope of application of the Whistleblower Channel was extended to encompass queries, thereby
improving its preventive and training capacity for all employees that need to rely on a safe reliable
method in this regard. The Regulatory Compliance Committee has also approved a specific procedure
that regulates the functioning of this channel.
6.
Access has been enhanced to all information relating to Regulatory Compliance and Control for all
employees and workers of the Atresmedia Group, providing a specific section on the Atresmedia
Group’s Intranet devoted to Regulatory Compliance and Control, which contains complete updated
information on the Corporate Governance System, the applicable Internal Regulations and Policies and
Procedures, and the mechanisms established for their adequate functioning, means of access and use.
7.
A series of new Policies, Protocols and Procedures has been approved by the Group’s different
governing bodies.
8.
The SAP - GRC System was implemented in greater depth, extending it to the whole organisation and
incorporating it into the normal work processes of the areas responsible for the execution of the
controls.
9.
Adequate training was provided in the management of the SAP - GRC System to all employees affected
by the new risk management and control systems and that are responsible for the controls included.