1. INTRODUCTION
   BULLDOG TV SPAIN S.L. (hereinafter “BULLDOG TV”) is a television production company established with the aim of producing programs of all genres for a commercial audience. Its activities focus both on adapting major international formats and on creating and developing original formats.
   This Code of Ethics (hereinafter “the Code”) aims to establish the principles and values that shape BULLDOG TV’s activities and should be considered a guide for the conduct of its employees, executives, and Board members in all professional relations.
   This Code does not cover every possible situation that may arise; however, it sets out the principles that should guide the behavior of anyone working at BULLDOG TV at all times.
   Therefore, it is essential that all personnel are familiar with this Code and adhere to its principles when performing their duties. This is without prejudice to any other internal rules that may be in place at any time, and, of course, the applicable legislation, which will prevail in case of conflict or contradiction with this Code.

2. SCOPE OF APPLICATION
   This Code of Ethics applies to all employees, executives, and members of the Board of Directors of BULLDOG TV.
   Likewise, it applies to all individuals or legal entities maintaining any professional or business relationship with BULLDOG TV in the course of their activities, such as external auditors, consultants, advisors, suppliers, advertisers, media agencies, etc.

3. ETHICAL PRINCIPLES AND CORE VALUES
   BULLDOG TV’s corporate culture is focused on achieving positive results across all areas of the organization, based on honesty and professionalism, compliance with applicable laws, and corporate responsibility.
   This Code of Ethics is built upon the following mandatory ETHICAL PRINCIPLES:

• Principle of legality and regulatory compliance
Compliance with legal regulations is a primary mandate for BULLDOG TV. All employees must comply with the legal framework in which they operate, as well as BULLDOG TV’s applicable internal policies. Violation of the law must be avoided under all circumstances.
Regardless of any penalties imposed by law, any employee responsible for a violation will be subject to disciplinary consequences for breaching their obligations.
Therefore, when dealing with clients, public authorities, suppliers, and other partners, employees must act in the interest of BULLDOG TV and in accordance with applicable laws and regulations.

• Conflict of interest
A conflict of interest arises in any situation where the interests of individuals linked to BULLDOG TV may be, directly or indirectly, different or opposed to the interests of the company, whether for personal, professional, business, or other reasons.
A personal interest exists when the matter affects the individual or someone closely connected to them, including:
I. The employee’s spouse or equivalent partner.
II. The employee’s ascendants, descendants, and siblings, or those of the spouse or equivalent partner.
III. The spouses of the employee’s ascendants, descendants, or siblings.
Examples of potential conflicts of interest include:
• Entering into contracts on behalf of BULLDOG TV with companies owned or managed by family or friends.
• Working for a supplier or client of BULLDOG TV.
• Running a personal business similar to one’s role at BULLDOG TV.
• Having a personal or financial interest in a transaction with BULLDOG TV.
• Receiving personal gain or financial benefit—beyond regular compensation—as a result of an agreement made by a third party with BULLDOG TV.
Decisions must always be based on the best option for BULLDOG TV, not influenced by personal relationships or interests.
To manage conflicts of interest, professionals must follow these principles:
I. Independence: Act professionally and loyally to BULLDOG TV, regardless of personal or third-party interests.
II. Abstention: Refrain from participating in decisions involving a conflict of interest or accessing related confidential information.
III. Disclosure: Inform BULLDOG TV’s Legal Officer of any potential conflicts before engaging in the matter.

• Principle of integrity and professionalism
BULLDOG TV promotes integrity and professionalism in workplace relations.
Professionalism is defined as responsible, efficient, and quality-driven performance.
Integrity means acting loyally, in good faith, and aligned with BULLDOG TV’s interests.
BULLDOG TV’s reputation is built on the behavior of each employee. Unlawful or inappropriate conduct by one person can significantly harm the company.
Employees must make business decisions in BULLDOG TV’s interest, not their own.
Conflicts of interest arise when employees engage in outside activities or prioritize personal interests.
Employees must inform their supervisor of any personal interest related to their professional duties. They must not use companies with which they do business in their BULLDOG TV role to secure personal deals.
Holding business interests in a competitor or customer of BULLDOG TV may create a conflict. All employees must recognize and avoid conflicts of interest or even the appearance thereof.

• Principle of objectivity, impartiality, and transparency in supplier procurement
BULLDOG TV applies objective, impartial, and transparent criteria in selecting and contracting suppliers at all stages of negotiation and execution.
Once selected, contracts are prepared or reviewed by BULLDOG TV’s Legal Department and must include the mandatory good conduct clause.

• Principle of equality and non-discrimination
BULLDOG TV promotes equal opportunity in hiring, working conditions, training, and promotion. No discrimination is tolerated based on personal characteristics such as skin color, gender, race, religion, origin, political views, sexual orientation, age, or physical/mental ability, in line with constitutional principles and International Labour Organization conventions.
The company fosters a workplace free of discrimination or harassment.
All relationships among employees, executives, and directors must be based on mutual respect, fairness, and courtesy.
There will be no retaliation or unfair treatment of anyone who, in good faith, reports misconduct or participates in investigations.

• Intellectual and industrial property
As BULLDOG TV’s activities revolve around creating and using intellectual and industrial property, proper management is essential. Employees working with such content must:

• Respect applicable laws.

• Verify the validity of any rights (contracts or licenses) before using intellectual or industrial property (e.g., written, audio, audiovisual works, trademarks, patents).

• Never copy, disclose, distribute, upload, or host protected materials without proper authorization.

• Human and labor rights protection and fight against modern slavery
BULLDOG TV is committed to ethical operations and full respect for its employees’ rights, as per national and international law, especially ILO conventions regarding forced labor, freedom of association, collective bargaining, equal pay, child labor, and non-discrimination.
The company ensures these policies are applied throughout its supply chain, taking action to avoid any form of modern slavery or human trafficking.
Employees must follow this policy in all business dealings and report any suspicious behavior via internal channels, particularly the Whistleblower Mailbox.

• Duty of secrecy and confidentiality
Confidentiality is critical. Employees must protect all information accessed during their work or by mere association with BULLDOG TV.
They must use such information only for professional duties, share it only with authorized personnel, and never for personal or third-party benefit. This duty continues even after employment ends.
Employees must not use unethical or illegal means to obtain confidential information about competitors, suppliers, or clients.

• Information security
Information is a vital asset. BULLDOG TV implements policies, controls, and structures to protect data confidentiality, integrity, and availability, ensuring access is limited to those needing it.
Employees must preserve these values in their daily work.

• Occupational health, safety, and environmental protection
BULLDOG TV ensures high safety and health standards. Training and internal controls support this goal. Employees must comply with risk prevention policies and environmental laws, especially regarding noise, electricity, or telecoms risks.
All activities must have proper administrative and environmental permits.
Suppliers must commit contractually to health, safety, and environmental standards.

• Use of professional resources
Employees must use the company’s resources solely for work purposes and protect them from misuse, theft, or unauthorized access. Personal use is allowed only with express approval.

• Drug and alcohol policy
Drug possession, distribution, or consumption is strictly prohibited during working hours. Alcohol is generally prohibited but may be consumed moderately during certain events, provided it does not affect job performance.

• Audits and inspections
Employees must cooperate fully with internal and external audits or investigations. If aware of any potential inquiry, they must notify their supervisor and Legal Counsel before taking action.
Do not:
• Destroy, alter, or hide documents.
• Provide false or misleading information.
• Conduct investigations alone; proper resources must be assigned.

• Freedom of expression and journalistic independence
Journalists, presenters, and collaborators at BULLDOG TV work in strict adherence to truth, objectivity, and independence.
Information must be thoroughly and legally obtained.
Offensive content should be avoided, especially during hours when minors may be watching.
Legal rights to honor, privacy, and image must always be respected.
BULLDOG TV is fully committed to correcting any false information broadcast.

• Gifts, illegal payments, donations, and illicit benefits
Generally, offering, accepting, or requesting gifts, payments, or invitations related to clients, suppliers, or authorities is prohibited unless in line with local customs and legal norms.
Any such benefit must be reported to the CEO and only accepted if approved.
Donations to political parties or NGOs on behalf of BULLDOG TV require CEO approval and must comply with the law.

• Business relationships with third parties
All relationships must be formalized in contracts before any agreement or service is carried out.

• Privacy and data protection
BULLDOG TV’s privacy principles include:

1. Full compliance with data protection laws.

2. Commitment to internal privacy policies.

3. Prohibition of unauthorized access to or processing of personal data.

4. Immediate reporting of data leaks or unauthorized access to the Legal Officer.

5. Responsible use of communication and IT systems.

6. MANAGEMENT OF CODE OF ETHICS VIOLATIONS
   This Code governs all BULLDOG TV relationships, whether contractual or not.
   Employees, executives, and management must adhere to it at all times.
   Ignorance of the Code does not exempt from compliance.
   No violation will be tolerated. Serious breaches may be treated as employment offenses and sanctioned accordingly, per applicable collective agreements and law.
   Violations may also result in civil, criminal, or administrative liability.
   Reports will be handled by Human Resources, ensuring confidentiality throughout the process.

7. COMMUNICATION AND DISSEMINATION OF THE CODE
   BULLDOG TV’s Management will ensure that the Code is communicated to all employees, executives, and directors.
   It will also be available to stakeholders on the BULLDOG TV website.

8. COMMITMENT TO EQUALITY
   BULLDOG TV sees gender equality as a strategic goal of its HR and corporate policy. It developed its Second Equality Plan to prevent direct or indirect discrimination and ensure real equality.
   Management and employee participation are essential for the plan to be a true tool for workplace improvement, productivity, and well-being.
   Real equality includes equal access, hiring, working conditions, promotion, training, pay, work-life balance, and health.
   Management promotes:
   • Implementation of Equality Plan measures.
   • Principles of equal treatment, diversity, and respect.
   • Gender perspective and elimination of stereotypes.
   • Balanced representation of qualified men and women in management.
   • Non-sexist language and imagery.
   Any employee may contact HR to contribute to gender equality.

9. ETHICAL MAILBOX
   BULLDOG TV has set up an Ethical Mailbox as a direct, efficient, and confidential channel for employees, management, and third parties (suppliers, clients, shareholders, etc.) to report breaches of laws, the Code of Ethics, or internal regulations.
   Email: buzonetico@bulldogtv.es

10. APPROVAL, UPDATE, AND ENTRY INTO FORCE
    The Code of Ethics was approved by BULLDOG TV’s CEO in 2021, entered into force on March 1, 2021, and was revised on November 15, 2022.