28
GOVERNANCE MODEL
Other management procedures:
• Procedure for control of furnishings and sundry
materials.
• Procedure for operational control of advertising
campaigns.
• Procedure for processing of advertising orders.
• Procedure for the use of mobile devices.
• Procedure for the control of personal data stored in
non-automated files.
• Procedure for ordering work materials.
• Procedure for returning assets.
The Mediaset Group has a Code of Ethics which
establishes the fundamental values and principles which
govern the Company, to which all employees, managers
and Board members are subject. The Code is therefore
applicable to all kinds of professional relations and
governs, among other areas, contractual, commercial
and business relations between Mediaset España and
its suppliers and customers. All natural or legal persons
who have any type of relation with Mediaset España in
the course of their professional or business activities
as external auditors, consultants, advisers, suppliers,
advertisers, media centres, external producers, bodies,
institutions, etc. are also required to comply with the
Code of Ethics.
The main principles laid down in the Code include the
following:
• Integrity, responsibility and transparency in financial
information.
• Right to equality and non-discrimination.
• Right to health and safety at work and protection of
the environment.
• Compliance with prevailing legislation and
regulations.
The Company’s Code of Ethics was approved by
the Board of Directors in December 2011 and has
been revised annually, and updated as appropriate.
It is available on the Company’s intranet and both
employees and directors have confirmed that they are
aware of its content and the fact that they are subject
to its provision During 2013, the Company updated
the acceptance of the Code of Ethics for newly hired
employees.
Control over compliance with the Code of Ethics pertains
to Internal Audit and Human Resource management.
Compliancemanagement,which is dependent on theAudit
and Compliance Committee, comprising the Corporate
General Manager of Mediaset España, the Management
and Operations General Manager and the Internal Audit
Director, is responsible for ensuring compliance with the
Internal Code of Conduct. Its functions include notifying
any infringement of said Code to Human Resources
management, which takes the requisite disciplinary action,
if appropriate.
In order to ensure the effective implementation of the
Code of Ethics and the various procedures that develop
and implement it, the Company complements and
reinforces its preventive framework with a number of
control processes that identify areas for improvement
and detect potential breaches, with a view to taking the
requisite corrective measures.
Internal Audit Management carries out control procedures
over the application of the pertinent procedures and codes.
Any possible case of irregularity, fraud or corruption, and
any infringement of the Code of Ethics, may be submitted
to the Independent Directors, who must pass the case on
to the Audit and Compliance Committee.
The Code of Ethics includes the following sections: legal
and regulatory compliance; conflict of interest; confiden-
tiality and confidential information; privileged informa-
tion; integrity, responsibility and transparency of financial
information; equality and non-discrimination, health and
safety at work and protection of the environment; drugs
and alcohol, intellectual property, material resources for
the carrying on of work activity, money laundering and
financing of terrorism, freedom of expression and of the
press, trade relations and links with competitors; external
communication, e-mail, internet and telephone; privacy
and data protection; fraudulent practices and mislead-
ing undertakings; duty of communication and complaints