Annual Corporate Governance Report 2017

42 performance. Likewise, it is bound to immediately communicate any information that is relevant for investors using the channels established by the CNMV. This regulation stipulates that Atresmedia’s employees must report the information in a true, complete and understandable manner. In no case will they knowingly provide incorrect, untrue or inaccurate information that may mislead 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 the Company 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 obligations 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 safekeeping of the information held and the permanent commitment to inform customers, employees and external partners, the market and the Company in a complete, objective and true manner. It also states that the deliberate falsification, manipulation or use of false information constitutes fraud. The ultimate responsibility with regard to the interpretation and application of the Code of Conduct rests with the Compliance Committee. This Committee is, inter alia, responsible for managing and supervising compliance, for supporting Internal Audit in the management of the Internal Control over Financial Reporting (ICFR) system, and for coordinating management of the specific communication channel that was implemented at Atresmedia to receive the communications of employees in the areas relating to the effective and correct comprehensive application of all these regulations within the Group: Whistleblowing Channel. Whistleblowing Channel. In the hierarchy, the Compliance Committee is accountable to the Board of Directors, although some information is submitted to the Audit and Control Committee (for the matters that specifically relate to this Committee) or to the CEO (for matters related with management). The Chief Compliance Officer and Chairman of the Compliance Committee is appointed by the Board, on the proposal of the Audit and Control Committee. He/she must fulfil the technical, professional and personal requirements under the legislation applicable to the post and have adequate preparation and professional experience and hierarchical independence in the organisation of the Atresmedia Group. 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 and the obligations that must be met by all the Group employees in relation to the Code were specified and explained. The Code of Conduct was published on the corporate website, www.atresmediacorporacion.com, and on the Group intranet within the Compliance and Control section, so that it is available for reference at any time to Group employees and related parties.  Whistleblowing channel allowing for communication to the audit committee of financial or accounting irregularities, breaches of the code of conduct or irregular activities within the organisation. Indicate whether communications over the channel are kept confidential. The Atresmedia Group has in place a Whistleblowing Channel that enables all Group employees to report, easily and confidentially, any action which they believe to be inappropriate in the light of the Code of Conduct or any other applicable laws, regulations or standards.