Annual Corporate Governance Report 2017

64 investigation – the broadcast of music in certain off-peak time slots – has been and remains a widespread practice in the industry. Atresmedia believes that earning income from its publishing subsidiary’s business, coupled with suitable management of music programming on its channels, is a transparent and widely practised way of obtaining income from its core activity, which is entirely in accordance with the rules of the SGAE and perfectly lawful and publicly known. Atresmedia further believes that its executives are under a duty to optimise any source of income for the benefit of the company, and in this specific case have mitigated the otherwise extraordinarily heavy burden of expenditure that use of the SGAE musical repertory involves. In addition, having carried out internal action and reviews, Atresmedia believes that the Group’s current risk management and control system satisfies the requirements effectively to control risks and pre-emptively detect any materialisation of risk, including criminal offences. Our exhaustive review has not detected any negligent or intentional breach of any procedure or requirement of the Atresmedia Code of Ethics. We have verified the existence and proper functioning of a Crime Prevention Model at the Atresmedia Group, which encompasses: a Whistleblowing Channel, a Code of Conduct (which is communicated to all employees), an SAP-based risk management, control and assessment system, a crime prevention protocol, and the necessary material and human organisational structure and resources, having decision-making and supervisory powers (Compliance Committee, Compliance Officer for Crime Prevention, Corporate Governance Department, Internal Audit and Audit and Control Committee). As a result, no adverse impact on Atresmedia has occurred as a result of contingent materialisation of the risk relating to management of musical authors and the Group’s relationship with the SGAE. However, in response to these events, by a decision of the Board and under the oversight of the Audit and Control Committee Atresmedia has immediately undertaken a comprehensive review of the business area concerned. This has involved the design and implementation of new specific controls that reflect the experience acquired in the past few months. In the course of the review Atresmedia was advised by criminal law experts.