Page 30 - MEDIASET ESPAÑA / 2013. Corporate Responsibility Report

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GOVERNANCE MODEL
of corruption arising. The Internal Audit Department in
its efforts to monitor the activities of the Company itself,
has undertaken a process of analysing the risks related
to corruption that has covered those business units with
the greatest impact on the Group either by volume of
income generated or by volume of expenditure they
incur, involving an analysis of 70% of the business lines.
This analysis is part of the annual audit plan.
Additionally, as well as informing all employees of the
policies and procedures in place to reduce the risk of
corrupt practices taking place, the Company has provided
specific anti-corruption training to part of the workforce.
9% of managers and 2% of non-managerial employees
have received this type of training, which has been
provided to employees with jobs that could be exposed
to the development of corrupt practices.
Other training programmes have also been devised
for personnel involved in the preparation and review
of financial information and other matters subject to
internal control and risk management regulations that
are applicable to the Company. Specifically, the Finance
Division and Internal Audit management are covered by
these training plans.
During 2013, these employees received a total of
940 hours of training, covering issues relating to
accounting standards, risk management, auditing and
changes in tax legislation, money laundering and
information techno­logies.
It is notable that among all the courses taken during
2013 in the risk management area, a considerable
amount of training investment has been aimed at
qualifying all company personnel associated with the
new online gambling activity, both in terms of their
knowledge of existing legislation and the communication
of internal procedures, framed in a training programme
called Prevention of Money Laundering and Terrorism
Financing. This training scheme has been limited to
employees whose functions are related to the gambling
activity, i.e. Premiere Megaplex workers and Mediaset
Spain structural personnel who provides suppor t
services to Premiere Megaplex. Therefore, training has
been provided to 2.7% of the workforce, who have
received 70 hours of training.
As evidence of its commitment towards compliance
with the regulations governing its business activity,
Mediaset España has concluded the following self-
regulation agreements:
• Code of Self-Regulation of Television Content and
Children;
• Code of Conduct on Commercial Advertising of
Gambling Activities;
• Advertising Code of Conduct of the Association
for the Self-Regulation of Commercial Advertising
and other specific advertising codes issued by that
Association.
In the normal course of business, Mediaset Spain manages
the participation of under-age artists in its programmes
in strict compliance with the criteria and procedures
established for this purpose by the Department of
Employment of the Madrid Regional Government.
In this regard, special mention should be made of the
emphasis placed by the Company on complying with
the Law on the Prevention of Occupational Risks which,
among other matters, addresses the protection of minors
in the work place. Due to the participation of children
in some of its programmes, Mediaset Spain carries out
a constant review of its activities and the sets on which
they work, in order to ensure full security and full respect
for their rights.
Among other issues, the Company verifies the suitability
of the access and waiting areas for minors, or the creation
of properly adapted rest areas. Similarly, the measures and
actions to be taken in an emergency are notified, and the
presence of the minors’ legal guardians during the relevant
sessions is guaranteed.Working hours can never exceed 8
hours and additionally the scheduling of recording involving
children is coordinated with their learning timetable, to
allow them to attend class on a regular basis.
The company has drawn up a manual where all necessary
information is brought together concerning minors’ rights,
to ensure the proper conduct of children’s activities on
television and ensure that their rights to education and
the enjoyment of their free time are not infringed. This
manual is available on the intranet and is given to all
production companies which hire children in order for
them to implement the measures it sets out.