Code of conduct


Dear colleagues
Together we make up a business group with clear strengths. These strengths are based on the quality of our products as a result of a responsible and honest conduct.
Everyone’s commitment to continue honouring these values is essential and we have, therefore, taken those principles that guide us to act responsibly and take decisions in our daily jobs and collected them in this Code of Conduct.
The Code of Conduct will serve to guide those who are already familiar with our standards, to lead those who join us and, above all, to define a way of understanding this business, which means to imbue our products with social values, respect for the rules and commitment with good practices
Our jobs must be guided by a commitment to the principles that inspire us: integrity, responsibility and quality.
Integrity means doing the right thing. By acting with integrity, we have a positive impact on Imagina Group’s goodwill and brand, strengthening our way of doing things.
Responsibility means acting within the law: the Imagina Group, its management and business partners must ensure that any chance of violating the law is avoided.
Quality is striving for excellence in business; we strive to operate and achieve success and profitability while acting responsibly.
Everything is inter-connected and shapes our Group’s image. That is why it is so important for us to live up to the commitment pledged and follow the guidelines defined by our Code of Conduct.
We must act correctly from the ethical point of view when dealing with each other, but also in the way in which we present ourselves to the outside world. Therefore, this Code explains the principles that govern the way in which we should behave with our customers, suppliers and the social environment. Since our business goes further than our offices, our Code of Conduct goes beyond national borders and is valid for all persons working at the Imagina Group and business partners.
Any one of us can confidentially ask for help and advice when trying to decide over ethical, legal or conduct matters or if we perceive any illegal or ethically questionable behaviour at the workplace. This Code explains how this can be done.
Best regards,
Tatxo Benet

We must always do the right thing, act with honesty, responsibility, integrity and quality. All our internal actions are reflected and transcend to the outside.
Our Code of Conduct shows how we will act in the performance of our business and professional responsibilities wherever we act on behalf of any of the companies comprising the Imagina Group, either at the offices of the Group or in any other national and international location, with the aim of avoiding any situation that could lead us to commit an offense or crime that would imply unwanted consequences, for ourselves and for the Group.
Our Code of Conduct reflects the principles that guide us to act with responsibility and help us when taking decisions for our jobs :
• We respect everyone’s confidentiality and privacy
• We guarantee transparency in our financial and accounting data
• We seek proper use of new technologies
• We respect the intellectual and industrial property rights of third parties
• We protect consumers
• We demand fair working conditions
• We protect children
• We manage conflicts of interest properly
• We avoid traffic fines
• We keep hygiene and order at the workplace
• We seek a cordial relationship with co-workers
• We do not work under the influence of alcohol or other drugs
• We protect natural resources and the environment
• We act with integrity in our business dealings
• We protect and support free competition
• We maintain a transparent relationship with the Administration

The Code of Conduct will be applicable to the following:
• The company IMAGINA MEDIA AUDIOVISUAL, S.L. and its majority-owned subsidiaries. The terms “the Imagina Group” or “the Group” shall refer collectively to all these companies throughout the present document
• All the persons working at the Group, regardless of their geographic location, position held and type of contract determining their relationship with the company (labor, civil or commercial). Administrators and managers are, thus, also included
• Students on internships
• Third parties that have a relationship with the Imagina Group, whether as suppliers, contractors, partners or customers, to the extent that it may be applicable and provided that the Group has the capacity to enforce it
Everyone has an obligation to immediately inform the Corporate Compliance Committee of any improper or unethical behavior relating to this Code of Conduct. Channels to contact the Committee are indicated at a later section of the Code.

We respect everyone’s confidentiality and privacy
The Imagina Group respects the confidentiality and privacy of all its partners, persons working at the Group, clients, suppliers, associates and anyone else whose data we process to conduct our business.
Those who process personal data will:
• Act responsibly and in compliance with the law
• Act in accordance with all contractual obligations undertaken
• Use this information only for legitimate purposes
• Prevent the disclosure of confidential information and/or unauthorized personal information

We will limit access to information only to those with a legitimate purpose for it. We will be especially careful with the information stored in our computer systems, denying access to unauthorized persons. Likewise, we will avoid accessing alien computer systems, with the aim of not revealing personal data of third parties.
We will avoid recording and playing back images or conversations of others, in which we have not intervened.
Whenever managing Group profiles in social media, we will always try to use an appropriate tone, taking into account that any comment is associated to the Imagina Group.

For example:
If an employee were to access the Persons Department database to find out what his/her coworkers earn, without authorization, that person would be incurring in a discovery and revelation of secrets offense.
If in news production we accessed photos or recordings taken within the privacy of a third party in which intimate details were revealed and, even though we suspected of their illegal origin, we went ahead and broadcasted them, we would be incurring in a discovery and revelation of secrets offense.

We guarantee transparency in our financial and accounting data
We will guarantee the accuracy of our economic data from all the Group departments
In our relationships with third parties, with the Administration and in our own internal relations we will ensure that accounting data accurately reflect the economic reality of each department.
The accounting data will be updated and always match the actual state the Group. Therefore, we will ensure that all records are accurate, with special attention to the information provided to the Public Administration, due to its official nature.
This will help foster goodwill of the Group and the persons working at it, as well as enable the achievement of goals.

For example:
If incorrect information was provided to the Social Security in order to obtain social benefits, it would constitute an offense against the Social Security.
If the financial department does not reflect on the tax return all commercial transactions conducted throughout the year because revenues were high, with the aim of paying less taxes, it would constitute an offense against the Public Treasury.
If the financial statements of the company are distorted, for example overvaluing the assets of the company in order to offer creditors payment through the sale of those assets, it would constitute false accounting fraud.

We seek proper use of new technologies
The use of the Internet and new technologies is a vital tool for the Group, not only in our relations with external entities, but also among ourselves.
Our work is stored in computer systems, which means we will consider new technologies as a vital asset for the Group.
Therefore, we will be especially careful when using computer systems, so that we do not delete or damage our own information and/or that of third parties.
We should bear in mind that the computer systems belong to the Group and their use should be limited to performing the professional tasks assigned.
The Group may access any of its terminals and systems, as well as corporate electronic mail in extraordinary cases, with the aim of verifying the correct use of computer systems or for business continuity purposes.

For example:
If audience share data was accessed and altered in a way that made it seems as if our content had obtained better results than our competitors, it would constitute a computer damage offense.
If someone accessed the website of a competitor who, on that date, was launching a new application that could hurt our sales, and somehow made it impossible for third parties to access said website, it would constitute a computer damage offense.
If someone accessed the computer systems of a competitor to damage or alter the emission or signal so that end users could not see a certain football game, it would constitute a computer damage offense.

We respect the intellectual and industrial property rights of third parties
The results of our work are especially valuable for the Group. What we create and share with third parties, due to the nature of our business, is the result of our daily effort and one of the most important products for the Group, as is our brand.
We will therefore take great care to ensure and guarantee that our products are protected by intellectual and industrial property rights.
Likewise, we will protect and respect these rights when the creators are third parties outside the Group. To use them, we will ensure that we have obtained the necessary authorizations.

For example:
If in a production we use content downloaded from the Internet, without respecting intellectual property rights, it would constitute a violation of intellectual property laws.
If a promotion was done by the Group, which used photographs protected by copyrights without obtaining authorization from the owner of the photographs, it would constitute a violation of intellectual property laws.
If we used protected software for editing images without the appropriate licences, it would constitute a a violation of intellectual property laws.

We protect consumers
Our audiovisual content intends to promote social values and principles through plots aimed at various sectors of the population.
We will not participate in projects that belittle the values that inspire us as a Group.
In addition, we will ensure that our advertising is accurate, legal, honest and loyal.
Also, any contract with consumers will observe all legal principles in order to generate greater consumer confidence in our products and services. We will be guided by transparency, clearly informing of the contract conditions and the rights held.

For example:
If we include products of dubious legality in our product placements we would be contravening our commitment to accuracy, legality and honesty, as well as incurring in other possible legal consequences.
If we offer a subscription to a pay television channel with a particular television offer, and this offer can then not be watched by the subscriber (having known that we would not hold the rights), it would constitute an offense of misleading advertising.
If a customer is misled by being given false business expectations, with the aim of the service cost being greater and thus getting a higher price, it would constitute fraud.
We demand fair working conditions

We are all entitled to protection against discrimination and harassment of any kind; thus, we will be cordial and respectful in our dealings with colleagues and third parties.
We will also ensure that our labor relations are compliant with the regulation in force and we will not promote or encourage hiring people illegally.

For example:
If the Persons Department hires a foreign individual who does not have a permit to work in Spain with the aim of avoiding administrative costs, it would constitute a violation of the rights of workers.

We protect children
The children of today are the future of tomorrow. Therefore, we protect our children and prevent their participation in exhibitionist shows, always seeking the best possible conditions.
We will be especially careful in the processing of data concerning children under fourteen years of age, making sure we have the parent’s prior consent.
Likewise, we will be particularly careful with those scripts or content aimed at children.

For example:
If we produced a film in which minors participated and that was linked to questionable content, the production department would be committing a corruption of minors offense.
If we create an ad in which minors are depicted in obscene situation, it would constitute a corruption of minors offense.
We manage conflict of interest properly
If we establish commercial relationships with family or friends which may cause a conflict of interest with the Group, we will inform our superior.

We shall not use confidential information pertaining to the Group for our own benefit or the benefit of third parties.
Internal or external relations that arise from the performance of our job in the Group will not be used for our personal benefit or for the benefit of family or friends.

For example:
If we hold a management position in a company that may be a competitor, supplier or customer of the Group while having a labor relation with the Group, we will be facing a conflict of interest.
If there is a job opening and we think a relative is perfect for the job, we may advice him/her to send his/her CV to the URL currently called “Would you like to work with us?” However, we will abstain from doing so if we are in a position to decide on the eventual hiring of the candidate.
Suppliers will be selected through fair and open selection procedures, based on quality, need, performance and price. All purchases from suppliers will be done in accordance with established purchasing policies.

We avoid traffic fines
Every person working at the Imagina Group is responsible for observing all traffic regulations in force when carrying out his/her job in a vehicle provided by the Group.
If, while at work, the person is fined, the Imagina Group is obliged by law to notify the traffic authorities of his/her identity for the possible imposition of a fine or penalty.
Updated on November 16, 2015
In the event of a temporary or permanent suspension of the person’s drivers license and if said license were necessary for the job entrusted, the Imagina Group will analyze the possible labor implications.
We keep hygiene and order at the workplace
Good hygiene in the workplace directly affects the security of all people.
Persons working at the Group will be able to access clean toilets, drinking water and facilities for the preparation and storage of food in hygienic conditions.
We will avoid lack of cleanliness or poor personal hygiene that may affect the productive process or the Group’s image.

For example:
If the person working at the Group believes the facilities do not meet the expected standards of hygiene, he/she will immediately inform his/her superior.

We seek a cordial relationship with coworkers
We encourage a cordial and respectful relationship among work colleagues to achieve a better working environment.
We will avoid any type of labor or sexual harassment that could take place at the workplace, or that could originate while working for the Imagina Group. In addition, any kind of verbal or physical offense will be avoided.
Anyone who believes to be in such a situation may notify the Corporate Compliance Committee through any of the channels indicated in this Code.

We do not work under the influence of alcohol or other drugs
Alcohol, drugs and misuse of prescription drugs negatively affect job performance. Furthermore, they may cause accidents that could endanger the safety of our colleagues.
Therefore, while providing services at the Group, we will not consume alcoholic beverages or any other substance that could affect our health.

For example:
Drinking a beer or a glass of wine with a meal is acceptable because it does not affect our health negatively. However, getting drunk or being under the influence of any other drug may impair our judgment and our decision-making process.
Respecting the integrity, legality and transparency of the Imagina Group when dealing with other companies, competitors, suppliers and the government, is not only important to maintain the reputation of our work and the good image of our Group but also to prevent incurring in some kind of offense or liability.
In general, in any external dealings we will act by respecting, at all times, the principle of free market competition, business confidentiality and equal opportunities when entering into agreements with other companies and with the Public Administrations.

Following are the lines of action that we will all abide by when facing certain common situations of conflict in the relations between the Group and any external agent, which will help us to avoid unintended negative consequences that could affect both ourselves and the Group.
We protect natural resources and the environment
The nature of the audiovisual sector, in particular the production of content, implies carrying our certain activities outdoors and, at times, building sets in natural environments, which is why we are committed to respecting the environment, avoiding emissions, discharges, radiation, extraction or excavation, silting, noise, vibrations, injections or deposits into the air, soil, subsoil or ground, underground or maritime waters.
We respect the balance of natural systems and people’s health, and we will avoid depositing or dumping waste or waste solids or liquids which are toxic or dangerous. We will dispose of those things we no longer need in the right places, always observing the principle of respecting nature.
If the setting of a work of fiction requires explosives, we will make sure we meet all legal requirements to do so. In any case we will always act with the necessary administrative permits to develop our activities.

For example:
If, during a recording outdoors, a non-authorized construction was built on underdeveloped land, it would constitute a zoning offense.
If regular or camcorders batteries were abandoned during the coverage of a sporting event, it would constitute a violation of environmental laws.
If works for the deployment of fibre optic lines were made without obtaining the necessary licenses it would constitute a zoning offense and a violation of environmental laws.

We act with integrity in our business dealings
When conducting our business, we strive to achieve better results than our competition in a legal, fair and honest manner. We seek competitive advantages through our own merits, never through unethical or illegal business practices. This means that in relations with suppliers, customers and partners, officers or public officials we will observe business integrity and respect the law.
Therefore, we shall avoid offering or promising any consideration to an official or public officer, either directly or indirectly, in exchange for favorable treatment or benefit.
Our relationships with other businesses, customers, external partners and suppliers will also be based on the strictest sense of integrity and loyalty in business. In this regard, we will refrain from offering, promising or accepting tokens or gifts from persons or entities that currently do business with us or may do so in the future, which would have the aim of encouraging these people to favor us or us favoring them, in some way, over others. In any case, we will avoid payments or cash equivalents, such as gift cards or gifts of significant economic value.
In general, we will refrain from accepting from or giving gifts to customers, suppliers or interested third parties, for whatever purpose, beyond the practices and customs of mere courtesy.
Nonetheless, attending sporting or entertainment events, or business meals with the customer or supplier, is an acceptable and normal business practice, as long as it remains within the financial limits above. Thus, we must avoid offering to or accepting from customers or suppliers personal trips or
vacations or similar gifts, except to support the legitimate commercial interests of the Group and always within the financial limits indicated above.

For example:
If person working in the Group in charge of organizing trips for the company accepts a discount from the travel agency for a personal trip (not available to the other persons working at the Group), that individual would be committing a private-to-private corruption act.
If, when faced with the possibility of a sanction for surreptitious advertising, that person accepted the proposal of the assigned officer to give him/her a cash payment in exchange for not sanctioning the company, it would constitute bribery or an act of corruption of officials.

We protect and support free competition
The protection of free market competition, especially in the audiovisual sector, is part of our philosophy, our trade policy and the way in which we interact with the market. It is very important that we all respect this free competition and, above all, we must agree to compete fairly with all other companies in the market. We want to compete on quality, good services and content, and not taking advantage of favors obtained illegally or fraudulently.
One way of interfering with free competition may be to seize data, documents or media from other companies without authorization, or to intercept any communication to obtain secret or confidential information pertaining to other companies, either in order to get some sort of advantage over such companies, or for personal gain, or for the purpose of harming said companies or their employees by disclosing such information, or even if there is no apparent purpose at first sight. We will avoid this type of action, whether such confidential information has reached us directly or through a third party.
The concept of “business secrets” or “confidential information” of a company is a broad concept, covering all data or information that any company wants to keep secret. Thus, it may refer, for example, to the organization and structure of the company or the group to which it belongs, the manner in which company resources are managed, marketing or commercialization techniques, projects, their customer base, industrial secrets or inventions, personal data of persons working at the Group, economic data and other company results that are not public, or any other data or information that is reserved and that may be relevant to the proper functioning of the company. It will often be information marked as “Confidential” or “Secret” but is not limited to these cases.
Another way of infringing free competition may be to use, directly, or through a third party, privileged information on the price of any class of shares or securities traded on a stock market, or providing or disseminating such information to obtain personal benefit or for the benefit of third parties.
Privileged information refers to information that is not generally public, relative to any company, or even relative to the Group, to which an individual may have had reserved access during the performance of his/her professional or business activity, for example, because said individual was involved.

For example:
If the Group hired a person who previously worked for one of our competitors, in exchange for that person providing specific information about that competitor’s business processes, it would constitute an offense of unfair competition.
If during trade negotiations with a customer, this client offered access to the commercial proposal of a competitor, even though said client had agreed to keeping information contained in the competitor’s proposal confidential, it would constitute an offense of seizure of data to discover a company secret.

If the launch of a new product or service had been approved at a meeting but revealing it to third parties had not been authorized and, despite this, it was revealed, it would constitute an offense of seizure of data to uncover a company secret.

We maintain a transparent relationship with the Administration
The integrity of the Imagina Group before the Administration requires our commitment to total transparency with regards to the information we are required to convey to the public bodies at all times, and in particular when it comes to requesting and obtaining public aids, grants or tax allowances that can help the development of our business.
This transparency commitment means that we shall not fall into irregularities or infringements when applying for these public aids, grants or tax allowances, such as distorting the conditions required for being eligible, or hiding facts or relevant information that would lead to these grants or aids not being granted.
In addition, once these public aids, grants or tax allowances have been granted, we will not fail to fulfill whatever conditions have been imposed by the Administration when granting them, and we will not alter the purposes for which said grant or aid was allowed. In order to keep this aid we are required to be transparent in our practices and our budgets, facilitating external control by the Administration when requested, so as to certify the proper use and allocation of the grants.

For example:
If the Group applied for a public grant and documentation was manipulated to simulate the conditions to which the grant was subject, and the Administration awarded said grant, it would constitute fraud or misappropriation of public subsidies.
If the Group applied for aid for the promotion of employment under the condition that it would need to be devoted to hiring young people under 30 and, despite this, the Group decided to use the aid for other purposes, it would be committing fraud or misappropriation of public subsidies.
If the Group resorted to using its personal relations with the official(s)/grantor(s) of a public tender in order to ensure it was awarded to the Group, it would be committing an offense of influence peddling.


With the aim of illustrating what we consider are violations of the Code of Conduct we have included examples in each of the prior sections.
In addition, the following violations are listed as reference (in no way are violations limited to these examples):
• Workplace harassment, including sexual harassment, or verbal and/ or physical offenses to colleagues
• Perform operations for a personal, family or third party benefit, to the detriment of the Group
• Reach agreements with competitors in tenders offers
• Accept or send gifts beyond the practices and customs of mere courtesy
• Provide access or disclose confidential information to third parties
• Not report a violation of the Code of Conduct when being aware of it
• Distort accounting data
• Present signs of alcohol or drug intoxication within the premises of the Imagina Group
• Repeatedly send malicious reports on the Code of Conduct
• Report false transactions, such as sales, purchases, loans, credits and expenses
• Carry out unnecessary purchases of goods and services to the detriment of the Group
• Discriminate, intimidate or harass anyone because of race, gender, age, national origin, religion, beliefs, sexual orientation or health reasons


Breaching the Code of Conduct will be subject to sanctions that will be applied to any person who authorizes, directs, approves or participates in the Code violation or to any employee who intentionally does not report the violation.
The severity of the sanctions will depend on the severity of the misconduct.
In the case of minor offenses, a mere verbal or written reprimand may suffice, and for serious violations the penalties may range from termination of the relationship with the Imagina Group, to filing a report (criminal, civil, commercial) with the competent authorities.
The Corporate Compliance Committee is established with the aim of promoting awareness of the Code of Conduct among the persons working at the Group, as well as to enforce compliance thereof.
In addition to the above functions, the Corporate Compliance Committee also performs the following activities:
• Inform the the Board of Directors about any actions undertaken
• Establish controls to prevent violations and review the effectiveness of these controls
• Resolve any issues concerning the interpretation of the Code of Conduct
• Manage violation reports and establish the appropriate sanctions
• Inform courts or security forces in those instances in which the breach of the Code of Conduct may constitute a crime
• Drafting of amendments to the Code of Conduct
• Decide to release an external communication that may have an impact on the image of the Group
• Design training plans so that the people that comprise the Group are aware of the principles, values and recommendations contained in the Code of Conduct
The Corporate Compliance Committee, as a collegiate body, is composed of the following members:
• Management
• Representative from the Financial Department
• Representative from the Legal Department
• Representative from the Internal Audit department
• Secretary
• Supervisor

How it works:
The Committee meets upon request from the Secretary when a report on a violation of the Code of Conduct has been received. It may also act ex-officio if any of its members is aware of a violation.

In case of any query regarding the interpretation or application of the Code of Conduct, we will ask our immediate superior, or send an email to
The above email address may also be used to propose improvements on the Code or on the controls implemented.
Reports state actions that are contrary to the Code of Conduct and they are submitted in good faith to the Corporate Compliance Committee
Channels for reporting actions that violate the Code of Conduct:
• Remittance of an email to
• Filling out the form available on the website, under the Corporate Compliance section
If no reports have been received, the Committee shall meet every quarter to discuss the adequacy of the controls in place and whatever suggestions for improvement may have been received.
The Imagina Group guarantees that there will be no retaliation for reporting, raising a concern or cooperating in an investigation. Anyone imposing reprisals against another who has reported a violation shall be liable to disciplinary action.
In accordance with regulation in force, anonymous reports shall not be accepted. Nonetheless, confidentiality of the person who reports is ensured, since the appropriate technical and organizational measures will be taken to guarantee that the identity of the person reporting in not revealed
The Committee guarantees its independence and respect for the right to a fair hearing as well as the presumption of innocence of the individuals involved
The Committee will appoint the corresponding Supervisor, based on the facts and the Group company or companies involved, to draft a report with the findings of the investigation. This report will include a summary of the facts, the evidence collected and conclusions reached.
Once the report has been reviewed, the Committee will decide whether the facts reported are actually a breach of the Code of Conduct, and the possible sanction to be imposed on the person(s) involved.
The people involved shall be informed of the outcome of the decision taken and, if the result of the investigation concluded that an unlawful act with criminal implications had been committed, the competent authorities will also be informed of the result of said investigation