Charter of ethics

Updated on 04 March 2022

Asacha Media Group, (hereinafter “AMG” or “The Group”) is a fast-growing multinational IP creation and production business, that serves the international demand for scripted content from TV networks and streaming platforms.

The Group comprises a pan-European alliance of content creators and producers. The Group produces drama, documentaries, factual, and kids’ programs. This Charter of Ethics is a formal expression of the basic ethical principles and rules of our Group.

Scope of the Charter

It applies to all employees of the Group and its subsidiaries and affiliates (including interns and temporary employees, producers, directors, scriptwriters…), contributors, and any other employee category according to local regulation, whatever their position in the hierarchy, their entity, or their geographical sphere of intervention. It also serves as a reference guide for our customers and partners across the globe.

Purpose of the Charter

The purpose of this Charter is to guide each employee and anyone acting with or on behalf of the Group,

  • to be compliant with the laws that govern the practice of our business worldwide, and locally when relevant,
  • to adopt and promote ethic conduct across the Group,
  • to handle ethical dilemma.

At AMG, we have a clear policy: complete commitment to compliance with ethical rules – those in the countries of our affiliates and those we set for the Group and zero tolerance, particularly regarding discrimination and harassment.

To our suppliers and service providers:

We undertake to adhere to the above-mentioned general principles with respect to our suppliers and service providers. In return, we expect them to adhere to principles equivalent to those in our Charter of Ethics. We ensure that all parties’ interests are taken into consideration, transparently and in accordance with contract terms when appropriate.

It is by acting in an ethical and responsible manner and by applying the commitments of our Charter of Ethics that we will be acting in the interests of the Group, its employees, customers and shareholders, and its long-term reputation.

We promote the goals and principles of the United Nations Declaration of Human Rights. We are committed to adopting the sustainable and socially responsible policies around the themes of human rights, labour, environment, and anti-corruption.

We focus on diversity on and off the screen to ensure that a variety of balanced, diverse voices are represented in all areas of production. We respect, in all circumstances, the rights of persons, their dignity, their singularity, and their culture.

By signing the “Charte de la Diversité”, we commit to promoting corporate social responsibility and particularly encouraging diversity and inclusion across all the Group.

Where to seek advice

As a media and entertainment group, we have specific duties imposed by the laws and regulations that can be increasingly complex. When in doubt or in sensitive situation, seek advice from your manager, a senior executive, the Human Resources Department or the Legal Department, or the AMG Ethics Officer before deciding, to avoid any risk for yourself or for the Group.

Themes addressed by the Charter

This Charter defines the 6 fundamental ethical principles:

  1. Compliance with laws, rules and regulations
  2. Loyalty and integrity
  3. Diversity and inclusion
  4. Respect of the environment
  5. Data protection and confidentiality
  6. Responsibility and accountability

The Charter of Ethics helps us adopt the right attitude and make the right decisions by acting with loyalty and integrity, respecting others, and avoiding conflicts of interest both at work and elsewhere.

 

1. Compliance with laws, rules and regulations


Compliance

In all circumstances, all employees must observe international, national, and local regulations, in force in all the countries in which the business is conducted, as well as rules of professional ethics for their job duties, and the Group’s ethics and compliance policies.

Each of the entities belonging to AMG may, where appropriate and compulsory, adopt specific provisions pursuant to the legal or regulatory obligations applicable at the local level.

At AMG, we are committed to exemplarity and ethical commitments regarding content, and rigorous management of information, the diversity of perspectives, respect for human rights, notably human dignity, and the fight against discrimination.

Every employee and contributors must ensure their strict adherence to laws and regulations governing our business.


Respect of Human Rights

Human Rights and Modern Slavery Human rights are defined by conventions and principles, such as the United Nations International Bill of Human Rights and the ILO Core Conventions of Labour Standards and the UNCG.
We recognize that the respect for human rights is a global standard and that upholding such rights is a responsibility to be expected of all businesses wherever we operate.
Child Protection
AMG have a moral and legal obligation to ensure that, when given responsibility for children in a production, all employees, chaperones, parents/legal guardians when appropriate, and volunteers, accept their responsibilities to safeguard children from harm and abuse.

This means to ensure that everyone follow procedures:

  • to make the environment as safe as possible for children and young people,
  • to ensue children are properly supervised by the right people,
  • to follow the relevant legislation and guidance for child performers,
  • to protect children and report any concerns about their welfare to appropriate authorities.

We recognize that the “entertainment industry” can be a very “adult” environment and we expect that all employees, chaperones, parents/legal guardians, volunteers, and anyone else who meets children always behave in an appropriate manner and remember that “The Welfare of the Child is Paramount”.

Modern Slavery

We do not support or deal with any person or business knowingly involved in slavery or human trafficking. We are committed to maintaining high ethical standards and acting with honesty, integrity, and transparency in all our business dealings worldwide. We do not tolerate any form of slavery or human trafficking in our Group. We expect the same high standards from all our affiliates, contributors, or business partners.
Modern slavery is a criminal offence and is strictly forbidden. Modern slavery can take various forms such as forced and compulsory labour, child labour, domestic and indentured servitude (e.g., debt bondage) as well as human trafficking, all of which deprive a person of their liberty to exploit them for personal or commercial gain. We all have a responsibility to be alert to the risks within our business dealings.

Therefore, AMG will not tolerate acts that breach this policy, and all such breaches or alleged breaches will be taken seriously, be fully investigated and may be subject to disciplinary action where appropriate.
Any individuals who is unsure whether a situation violates any applicable law, rule, regulation, or Group policy should discuss the situation with its manager, a senior executive or member of the HR or legal team or seek advice from internal experts.

We will ensure that all managers understand and maintain their responsibilities and those of their team under this policy.

2. Loyalty and integrity

We are committed to ensuring that honesty, loyalty, and integrity govern both business and interpersonal relationships, and everyday professional practices.

It is essential for every individual to adopt an ethical conduct in all circumstances and promote a culture of honesty, loyalty, and integrity. Based on this principle, the Group attaches the greatest importance to exemplary behavior from its employees and contributors.

Loyalty

The quality of a relationship relies on the loyalty of the parties. This requires that we honor the commitments made and that we do not make any commitment that we cannot keep. Every project, contract, broadcast, or production is realized in good faith, in a constructive spirit, in respect of everyone’s interests, and caring about providing sincere information.

All employees or contributors should seek, accept, and offer honest criticism of work, acknowledge, and correct errors, and give proper credit and respect to the contributions of others.

Honesty and Integrity

Integrity entails honesty and adherence to the highest ethical standards in all actions and is a condition for recruitment.

Meeting our goals of integrity towards the Group and in our business, relationships mean rejecting all forms of bribery, kickbacks, or corruption of any kind directly or indirectly through third parties and avoiding conflicts of interest.

Gifts

AMG employees are not permitted to give or offer anything of value (including gifts, hospitality, advantages, or entertainment) to anyone that might affect their independence or lead to doubts as to their professional integrity or for the purpose of improperly obtaining or retaining a business advantage. Similarly, employees may not solicit or accept such improper payments.

Keeping this in proportion, for protocol or courtesy purposes, employees may occasionally offer or accept gestures such as small gifts or invitations of reasonable value, provided that these are not encouraged, are merely a token of courtesy or hospitality and do not undermine the independence of employees or the impartiality of the beneficiary.

In all cases, the employee concerned must comply with the applicable requirement of the Group which is that all gifts/hospitalities whose value is > 100€ required an approval from a line manager.

Anti-bribery

The AMG Group entities and their managers and staff members are engaged in fair trade and must comply with the applicable anti-corruption laws and regulations.

The Group’s senior management takes particular care to ensure that the negotiation and performance of contracts does not give rise to behaviour or practices that could be described as active or passive bribery or considered complicit in influence peddling or favouritism. No Group Employee should, directly or indirectly and by any means, grant any kind of unjustified benefits to a third party to obtain or maintain a favourable business deal or treatment.

Therefore, we accept no compromise in the matter of integrity. We will prosecute fraudulent behaviour known as any act of deception designed to gain an improper or illegal advantage: theft, extortion, embezzlement, abuse of trust, fencing, concealment, money laundering, corruption, offence of favouritism, unlawful taking of interest, insider dealing or the misuse of the Group assets, and usurpation of identity / of office.

Every effort must be made to avoid conflicts of interests and suspicions of bias.

We encourage reporting of ethical incidents, and no employee may be sanctioned neither for using a reporting measure for these incidents, nor for refusing to carry out an act which they believe goes against the Group’s policies.

Financial integrity

All operations and transactions carried out by the Group are recorded in a true and faithful manner in the financial statements of each company, in accordance with current regulations and internal procedures: employees preparing accounting records specifically verify the existence of documentation corresponding to each entry.

Every fund transfer requires particular care, notably in relation to the identity of the recipient and the reason for the transfer.

AMG Group condemns all forms of corruption and trading in influence. Active and passive corruption, irrespective of type and target, both in the public and private sector, as well as trading in influence, are prohibited.

AMG is actively involved in combating both money laundering and the financing of terrorism. AMG comply with all applicable Anti money laundering laws.

3. Diversity and inclusion

At AMG, we attach importance to the values of tolerance and respect for others, for their rights, their dignity, their singularity, and their culture.

Respect for others in all circumstances implies treating everyone fairly, by giving equal importance to everyone. It requires reciprocity: everyone has rights they can exercise, but also duties to fulfill, towards others, their entity, the Group, and society.


Diversity

AMG is committed to valuing diversity and seeks to provide all employees with the opportunity for employment, career and personal development on the basis of ability, qualifications and suitability for the work as well as their potential to be developed into the job.
We believe that people from different backgrounds can bring fresh ideas, thinking and approaches which make the way work is undertaken more effective and efficient.

Discrimination

AMG will not tolerate direct or indirect discrimination against any person on the basis of age, gender, gender reassignment, marriage / civil partnership, pregnancy / maternity, race / color, religion or belief, sex, or sexual orientation, national origin, disability, ancestry, political opinion, or any other basis prohibited by the laws whether in the field of recruitment, terms and conditions of employment, career progression, training, transfer or dismissal.

Harassment

AMG undertakes to provide an environment free of sexual or any other form of harassment. Consequently, no harassment by an AMG employee or a customer or supplier shall be tolerated. Therefore, Asacha Media Group:

  • Will promote a culture where everyone feels welcome, included, safe and recognized not only for results but also for a greater engagement and creativity in the workplace
  • Will offer opportunities for flexible working patterns, wherever operationally feasible, to help employees to combine a career with their domestic responsibilities.
  • Will provide a workplace free from unlawful discrimination in any form, where employment decisions are based only on the requirements of the job.
  • Will conduct harassment training to sensitize all employees to the damaging effects for victims and witness and provide to all a safe and harassment-free workplace.
  • Will provide equal employment opportunity to all who apply for vacancies through open competition.
  • Will promote equal representation for women and minorities.
  • Will select candidates only based on their ability to carry out the job, using a clear and open process.
  • Will provide all employees with the training and development that they need to carry out their job effectively.
  • Will provide all reasonable assistance to employees who are or who become disabled, making reasonable adjustments wherever possible to provide continued employment. We will ensure an appropriate risk assessment is carried out and that appropriate specialist advice is obtained when necessary.

It is the responsibility of all employees in their daily actions, decisions, and behaviour to endeavour to promote these concepts, and to comply with all relevant legislation and to ensure that they do not discriminate against colleagues, partners, suppliers, or any other person associated with AMG.

We encourage employees to pursue any matter through the internal procedures which they believe has exposed them to inequitable treatment within the scope of this policy and ensure that all managers understand and maintain their responsibilities and those of their team under this policy.

4. Respect of the environment

We are all responsible for protecting the environment. We will take account of the impact of our activities on the environment and seeks to reduce negative impacts where feasible. We strive to reduce our carbon footprint by encouraging the implementation of environmentally responsible practices in our daily work and in all production phases, for all projects filmed.

We sensitize and train our employees to adopt environmentally responsible behaviour and best practices at work such as:

  • Managing waste generation and disposal (hazardous and nonhazardous)
  • Sourcing local labour and materials and when possible
  • Sourcing goods and services from sustainable suppliers
  • Reducing paper consumption, using digital documents whenever possible, save paper when distributing scripts and opt for videoconferences instead of travel
  • Curtail energy consumption (turnoff electric equipment when not in use (if doing so does not affect operations), using LED lights across all the office building, wherever possible…

For most of our production, we encourage to be environmentally sustainable, and in our programmes, we pay particular attention to environmental protection issues.
Locally, when relevant, we foster independent external certification aimed at guaranteeing our commitment to continuous improvement in sustainability.

Health and Security

AMG is responsible for the health and safety of all employees and contributors at work and aims to provide a comfortable and efficient working environment. Employees and contributors are also expected to contribute to the maintenance of safe and healthy working conditions by:

  • Respecting the rules in force in the group in terms of hygiene and safety.
  • Making sure they know what to do in the event of an emergency at the workplace, including promptly complying with all evacuation procedures and instructions.
  • Reporting to their hierarchy or the person in charge of security any situation that may compromise the safety of the work environment.
  • Not working under the influence of drugs or alcohol. Employees must be in a fit state to carry out their work and AMG will act if their performance is impaired by the use of alcohol, drugs or other substances.

5. Protection of data - confidentiality and privacy

The protection of personal data and the respect for privacy is a fundamental right set forth in the Charter of Fundamental Rights of the European Union, and a principle of our Charter of Ethics. In particular, AMG ensures full compliance with the EU General Data Protection Regulation and any applicable national data protection laws.

Protection of data

Therefore, we keep accurate, up to date (when necessary), and in a form which permits identification, all personal data of our employees, only for the period necessary for the purposes for which they are processed. We ensure that appropriate security, integrity, and confidentiality measures are implemented, using appropriate technical and organizational measures, to provide protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Pursuant to the EU GDPR, employees have the right to access, rectify, and/or, in certain circumstances, erase any of their personal data that could be held by AMG, and/or to restrict or object to the processing of their personal data. They have the right to data portability, only if applicable.

Also, when employees have given, us consent to the processing of their personal data, they have the right to withdraw their consent at any time. Should they wish to exercise these rights, or should they have any questions related to data privacy, they can consult the Personal Data Protection- Privacy Policy or contact their manager, or the DPO.


Confidentiality

It is the responsibility of all employees to protect the confidentiality of the Group information.

During their employment, employees may have access to proprietary and confidential information concerning the Group’s business, clients and suppliers, and about future productions. Confidential information includes such items as non-public information concerning the Group’s business, financial results and prospects and potential corporate transactions.

Employees may also have access to proprietary and confidential information in connection with the business carried on for customers by the Company and in relation to the private lives of such customers.

Employees are required to keep such information confidential during employment as well as thereafter, and not to use, disclose, or communicate that confidential information other than in the course of employment.

To ensure the confidentiality of any personal information collected and to comply with applicable laws, any employee in possession of non-public, personal information about the Group’s production companies, or other employees, must maintain the highest degree of confidentiality and must not disclose any personal information unless authorization is obtained.

6. Responsibility and accountability

This Charter of Ethics applies to all entities controlled by Asacha Media Group and all employees including producers, directors, scriptwriters, and managers.

All of us are required to read, understand, and comply with this Charter of Ethics.

We require that all employees at every level in the hierarchy accept responsibility for their own behavior in respect of the application of this Charter of ethics.

We are committed to ensure good governance management and social responsibility.

Any violation of this Charter of Ethics may result in disciplinary action, including termination, and if warranted, legal proceedings. This Charter is a statement of certain fundamental principles, policies and procedures that govern the Group in the conduct of its activities. It is not intended to and does not create any rights in any employee, contributor, supplier, competitor, shareholder or any other person or entity.

Employees should speak with anyone in their management chain, or the Human Resources Department, the Legal Department, or the Ethics officer when they have a question about the application of this Charter or when in doubt about how to properly act in a particular situation.

Employees who observe or become aware of a situation that they believe to be a violation of the Charter have an obligation to notify their manager, the Human Resources Department, or the Legal Department.

They also can report the violation through the whistleblowing system implemented by the Group.

Violations involving a manager should be reported directly to an Independent Director, to the Human Resources Department, the Legal Department or by the whistleblowing system (helpline or email).

When a manager receives a report of a violation, it will be the manager’s responsibility to handle the matter in consultation with the Human Resources Department, or the Legal Department or the Ethics officer.

If an Employee reporting a violation wishes to remain anonymous, all reasonable steps will be taken to keep their identity confidential.
All communications will be taken seriously and, if warranted, any reports of violations will be investigated.

AMG will not allow retaliation against an employee for reporting misconduct by others in good faith.

Employees must cooperate in internal investigations of potential or alleged misconduct.

We will ensure that this Charter of Ethics and its policy statement will be distributed and publicized throughout AMG by all means.

Specific guidance and procedures with regards to specific areas are incorporated into attached documents.