Given the nature of Atresmedia’s activities and the fact that most of its business is conducted in Spain under national legislation, the Group understands that content acquisition and distribution, as well as employee relations, are the areas requiring the most attention to avoid adverse impacts on Human Rights.

One of the most relevant developments for the Atresmedia Group in recent years has been the creation of a Human Rights Due Diligence procedure, which has enabled the Group to identify and assess potential adverse impacts in this area. Accordingly, Atresmedia has a corporate Human Rights Due Diligence Manual that serves as an internal guide for the proper management of key issues, as well as for the future identification of relevant matters in the event of significant changes to the Group’s business model.

This Manual incorporates the essential elements of any Due Diligence process, as outlined in the OECD Guidelines for Multinational Enterprises:

• Formulate a commitment to responsible conduct and incorporate it into policies and procedures.
• Identify and assess adverse impacts.
• Take steps to stop, prevent, and mitigate adverse impacts.
• Monitor the effectiveness of the measures implemented.
• Publicly report on its approach to Human Rights, identified adverse impacts, measures taken, complaints and remediation mechanisms.
• Establish and apply (when applicable) remediation mechanisms, including a grievance/whistleblowing channel.

It is also worth noting that in 2023, the Atresmedia Group updated its Code of Conduct, which explicitly states its commitment to Human Rights. This Code also covers topics such as regulatory compliance, respect for ethical values, and Human Rights as basic principles of the Group’s conduct. It reflects a clear commitment to respecting, protecting, and upholding the UN International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights, and the European Charter of Fundamental Rights, which enshrines the protection of personal data as a fundamental right.

In line with the main national and international Human Rights protection instruments, Atresmedia has also established mechanisms for the prevention, identification, and elimination of behaviors that may constitute violations of fundamental rights, with particular attention to freedom of expression, human dignity, the rights to honor, privacy, and personal image, and the protection of personal data. Ensuring these rights is aligned with Atresmedia’s values and corporate culture.

Along with the updated Code of Conduct, Atresmedia has revised its Queries and Complaints Channel, which is the primary means for reporting any infringement related to the Atresmedia Group or related individuals that involves a violation of Human Rights and Public Freedoms, according to internationally accepted laws and practices or in contradiction to the standards of the International Labour Organization (ILO), especially those relating to child labor. In 2023, no reports or complaints regarding Human Rights abuse or violations were received through this channel.

In addition to the aforementioned channel, Atresmedia has other mechanisms for identifying potential Human Rights violations, such as the Corporate Responsibility mailbox, which is accessible to anyone.

Among Atresmedia’s mechanisms for protecting Human Rights is its commitment to respect and ensure their enforcement, as outlined in its General Corporate Responsibility Policy. This policy specifically includes Atresmedia’s commitments to:

• Promote freedom of expression, diversity, pluralism, and non-discrimination in its news and entertainment content, and to protect the Human Rights recognized in the Universal Declaration of Human Rights.
• Ensure that advertising content strictly respects Human Rights, firmly rejecting campaigns that incite violence, promote discrimination, encourage behavior against human dignity, or harm minors or any minority group requiring special protection.
• Uphold Labor Rights, ensuring compliance with ILO provisions, particularly those related to employee privacy or child labor, rejecting practices contrary to these and other principles.

Alongside the Corporate Responsibility Policy, there are other policies and procedures that contribute to the protection of Human Rights, most notably:

Human Resources Policy

The Human Resources Policy is based on the following principles, applicable to all employees:

• Provide stable employment and a rewarding work environment.
• Train and support the professional development of human capital.
• Attract and retain talent.
• Ensure Human and Labor Rights.
• Promote equality, diversity, and work-life balance.
• Ensure a safe and healthy working environment.

Beyond these principles, Atresmedia guarantees Human and Labor Rights through its HR Policy by including international standards of conduct, primarily from the United Nations. These refer to compliance with the ILO’s provisions, especially those related to child labor, recognition of the right to freedom of association, and promotion of social dialogue with employee representatives.

Responsible Advertising Policy

Advertising is a key area of Atresmedia’s business; therefore, the Group is committed to offering content suitable for all audiences. In this regard, the company ensures that its advertising content clearly upholds fundamental values such as truthfulness, honesty, credibility, and respect for Human Rights, as stated in the Responsible Advertising Policy.

This policy also includes Atresmedia’s unequivocal commitment to safeguarding Human Rights, particularly the protection of minors. This has led to not only adapting to the latest legal changes but also adopting a specific framework to protect viewers—especially younger audiences.

For Atresmedia, respecting and protecting Human Rights means safeguarding the rights of all workers in its value chain, within its sphere of influence, particularly those of its own employees, ensuring respect for all Human and Labor Rights.

New employees of the Group are required to complete a training course on the Group’s Compliance and Crime Prevention Model when they join, which includes content related to Human Rights.

Finally, it is important to highlight that this document further details the measures that the Atresmedia Group has implemented and continues to implement to uphold its strong commitment to the principles of the United Nations Global Compact and the well-being of its employees and stakeholders.