Our success is built on the pride, passion and professionalism of everybody working on our programmes. How we conduct ourselves and treat other people is crucial. Whilst it should be obvious and natural to treat others how you expect to be treated yourself, it’s important to be clear about those expectations and ensure everybody understands and observes them.

This Code is not intended to cover every eventuality but provides guiding principles as to how to deal with a particular situation and where to go for guidance and support. Personal accountability and individual good judgement remains paramount.

This Code of Ethics and Conduct is incorporated in your contract with us (whether you’re an employee or a freelancer) so it is vital that you understand and comply with it. 

We take the letter and spirit of this Code seriously - our colleagues, ITV shareholders, viewers, suppliers and other stakeholders expect no less from us. Breach of the Code could result in disciplinary action so please read it carefully.

The Basics

• Everybody should be treated fairly and courteously, whether in/out of normal working hours and in/out of the workplace.

• Be conscious of your role and your seniority – what you say and do can have a disproportionate impact especially on less experienced colleagues.

• Offer kind words to recognise great performance or when a colleague goes above and beyond.

• If something is not working well, raise issues courteously and politely. Think before you do or say anything critical – your point may be perfectly valid but it’s usually helpful to pause for a moment before explaining your concerns.

• If you would like some advice on how to deal with a problem or if something is just bothering you, please ask for help.

1. Equal opportunities

People will be recruited for their aptitude, skills and experience. We provide equal opportunities to all – please see our Equal Opportunity policy for further guidance.

‍2. Harassment, discrimination and abusive behaviour

‍ Your workplace should be free from verbal, physical or online harassment, bullying and abuse. We will treat one another with courtesy, dignity and respect and we will not tolerate any discrimination or harassment on grounds of race (including the traveller community), national origin, gender, gender identity or expression, age, disability, marital status, sexual orientation, pregnancy, maternity, socio-economic background, religion or belief.

Harassment means conduct that creates an intimidating, hostile or offensive working environment, violates a person’s dignity or unreasonably interferes with an individual’s work performance. Conduct that has this effect can be harassment even if the effect was not intended and a single incident can amount to harassment - it doesn’t have to be an ongoing problem. The conduct can also take place outside of the workplace or via social media. Examples include:

• ‍threatening behaviour, intimidation, assaults or violence; or

• unwanted conduct, which can include jokes/pranks/banter, mimicry, physical/facial expressions, social media posts/contact; or

• unwanted conduct of a sexual nature including sexual comments or jokes, displaying sexually graphic imagery, staring or leering, sexual gestures, intrusive questions about a person’s sex life, sending sexually explicit messages and unwelcome touching, kissing, hugging or massaging; or

• abuse of position such as to cause distress to subordinates. Any form of reprisal or victimisation against anyone who has raised a concern or participated in an investigation will not be tolerated and will itself be treated as a serious disciplinary matter.

3. Child safeguarding and protection

‍We take our legal and moral obligations to children very seriously. Anyone under the age of 18 is considered a child. If you work with or will be near children at work then you must follow our Child Protection Policy and conduct yourself appropriately. If you have any concerns regarding a child’s welfare, please tell your producer or Emily Russell (emily@mammothscreen.com), Jon Williams (jon@mammothscreen.com) or James Penny (james@mammothscreen.com) or you can use the confidential Speaking Up Hotline.

4. Drugs and alcohol

Do not use, distribute or possess illegal or unauthorised drugs on any of our premises.

If your behaviour, judgement or performance of your work responsibilities is impaired by drugs or alcohol then you will be prohibited from entering our premises or engaging in company business and may be subject to disciplinary proceedings.

5. Theft or misuse of property

Anyone found to be engaging in, or attempting, theft, fraud or misuse of any company property of the property of other colleagues is at risk of being dismissed. You may also be subject to a criminal investigation.

Theft, fraud or misuse of company property can take many forms including stealing supplies, equipment, documents, cash or other property; misusing corporate credit cards, telephones, mobile phones and devices, tablets, computers, printers or other equipment; submitting falsified time sheets or expense claims; using company information or other assets without authority; retaining any benefit from a customer or supplier that properly belongs to the company.

6. Acceptable use of systems and technology

You are responsible for using Mammoth’s systems and technology (and, if they are used in connection with Mammoth business, your own systems and technology) properly and in accordance with this Code. Failure to do so could result in damage to our business and reputation and could lead to disciplinary action, termination of contract or in extreme cases criminal prosecution.

Passwords

You must use a strong complex password and should not share, write it down or store it, or attempt to logon as another user.

When registering with third party websites, please use a different password to the one you use when accessing Mammoth’s network.

Software / Keeping devices safe

All software on any device must be properly licensed and should only be used for legitimate business purposes.

You are personally responsible for the security of all equipment allocated to or used by you. When travelling with Mammoth equipment or information, please take all necessary care to prevent loss or theft.

Only share information with those authorised to view it and do not store Mammoth’s sensitive information on a device unless the data is password protected. Sensitive information should always be password protected when sending it by email or otherwise.

Be particularly cautious in relation to unsolicited emails from unknown sources or to urgent requests for personal information or payments to be processed. If you have any suspicions about an email, ask for help.

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Artificial Intelligence

Please do not use any AI tools to generate materials to be used in connection with any Mammoth production. This includes the use of AI tools in connection with storyboarding, script analysis, research and on-screen graphics. Scripts, personal data about cast and/or crew (including images of cast) should never be uploaded to AI platforms. 

Generative AI platforms create content by copying similar content on the internet then adapting it to answer the question or fulfil the user’s request. If a user generates content via the ‘free’ version of the AI tools, then the AI tool will own the copyright in the content created and will use the information inputted to develop and improve the AI tool. We are also not protected if there are any third party claims regarding copyright infringement.

If you have any specific queries about the use of any AI tools, please speak to the production executive on your production.

Use of email / text messages / WhatsApp

You must exercise the same care, caution and etiquette when sending an email, text message or WhatsApp message as you would when talking to somebody face-to-face. We will not tolerate abusive or unprofessional emails or other messages, or anything that may damage our reputation or our relationship with our clients or viewers.

You are accountable for your actions on the internet and email systems. Do not use our systems or equipment to send or intentionally receive, retrieve, distribute, store or access:

• information that is defamatory, illegal, abusive, harassing, sexually explicit, discriminatory or offensive;

• copyrighted materials, trade secrets or similar materials without proper authority or in breach of the rights of third parties, or

• ‍messages, files or websites for any illegal or unethical purpose, or for any purpose that violates our policies or may lead to liability or cause harm to Mammoth (including accessing the “dark web” or circumventing Mammoth’s security controls or policies).

You should never attempt to evade any security control and a device may be disconnected immediately from the network if any security issue is detected. You should also not attempt to exceed the limits of your authorisation or specific business need to integrate the system or data. To do any of these will constitute a disciplinary offence, which may result in dismissal.

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Reporting Incidents

Please be vigilant against any cyber threats and phishing attacks and report any security incidents or suspicious activity in accordance with our Cyber Security and Data Privacy Incident Breach Procedure.

Please inform your line manager immediately if you do suspect any computer may have a virus and do not use it again until informed it is safe to do so.

7. Privacy and data protection

You must comply with applicable local privacy and data protection laws and regulations to respect the rights of our viewers, customers, contractors and colleagues and to protect the company from regulatory fines and reputational damage. If you handle personal data at Mammoth, you must follow our Privacy Notice (available here: www.mammothscreen.com/privacy). Failure to do so could result in disciplinary action, termination of contract or even criminal prosecution.

Any system used to collect and process personal data should provide the data subject with information regarding its processing. This is usually done via a privacy notice.

8. Monitoring

Any use of company systems, telephones, email and internet facilities may be monitored (in accordance with all applicable laws). For example, we may monitor your usage:

• for legitimate business purposes;

• ‍to prevent, detect or investigate suspected illegal conduct, wrongdoing or other misuse;

• to ensure that customers and other business contacts are being appropriately responded to;

• to comply with legal obligations; or

• to locate and retrieve lost messages or files.

Sometimes we may need to check your email accounts or voicemail during your absence from work (e.g. when you are on holiday or sick leave).

Some production offices may use CCTV and you may be recorded when working from our premises.

Email, voicemail messages, recordings and internet usage are potentially subject to interception and to disclosure to third parties in the course of litigation or an investigation. We have a legitimate basis on which to access and protect company data stored or processed on a device, including the content of any communications sent or received from the device.

However, we recognise the need to balance our obligation to process data for legitimate purposes, with your expectations of privacy in respect of your personal data. Therefore, when taking (or considering taking) action to access your device or delete data on a device (remotely or otherwise) in accordance with this policy, we will, where practicable:

• consider whether the action is proportionate in light of the potential damage to the company, our customers or other people impacted by company data;

• consider if there is an alternative method of dealing with the potential risks to the company's interests (recognising that such decisions often require urgent action).

9. Intellectual property

You must safeguard our confidential information, trade secrets and intellectual property (including copyrights, trademarks and patents) in the same way as all other physical assets belonging to the company.

All documents, files, materials, records and reports acquired or created in the course of your engagement are the property of the company. You must not register any Mammoth intellectual property rights, including trademarks, internet domain names or social media accounts in your own name.

You may only remove originals or copies of such property from our offices for the sole purpose of performing your duties, and they must return such records at any time upon request. We often use intellectual property, trade secrets and/or confidential information belonging to others so please check that your use complies with the permissions and limitations set by those owners.

10. Health & Safety

We are committed to conducting our business with the health and safety of you, your colleagues, customers, suppliers and the general public always in mind. We will always strive to comply fully with all applicable and relevant laws and regulations relating to the workplace health and safety and environmental protection for the benefit of our colleagues, customers and members of the general public.

We are committed to ensuring that our health and safety policies conform to best practice and encourage open dialogue and constructive feedback.

We ask everyone working on our projects to help ensure that their working environment is healthy and safe. As well as considering your own health and safety, please also consider the health and safety of anyone who may be affected by your actions or behaviour.

You must always follow Health and Safety policies and guidelines and fully cooperate with the instructions of ITV’s and Mammoth’s Health and Safety advisors.

Please make sure that you have read and you comply with all Health and Safety policies and guidelines that are relevant to your role. Further details can be obtained from Mammoth.

11. Financial and accounting controls and records

All financial and accounting information about us must be recorded and presented accurately, diligently and fairly, in accordance with good business practices, applicable accounting standards and local laws. There are spend limits and other controls for the authorisation of expenditure, details of which are available from Jo Silvester.

12. Tax evasion and facilitating tax evasion

Tax evasion is the deliberate, fraudulent cheating of the public revenue. You must not commit any acts intended to result in tax evasion by Mammoth and must not facilitate tax evasion by third parties.

When choosing agents, contractors, suppliers or other intermediaries, you are expected to carry out pre-contract enquiries to ensure that they do not condone tax evasion, and that they have procedures in place to prevent tax evasion and the facilitation of tax evasion. If you need any help please contact James Penny or Jon Williams. If you are concerned that you may have identified tax evasion within Mammoth, please report it to any Mammoth director.

13. Creating documents and retaining records

In order to comply with our legal and regulatory requirements, we may be required to retain business records for reasonable time periods before they can be destroyed. This relates particularly to contractual documentation, tax, finance, accounting, employee related documentation, Health and Safety and the environment. Also, records and documentation pertinent to an investigation or legal dispute must not be destroyed once we have received notice of related pending litigation.

14. Business Ethics

a. Conflict of interest

We should actively avoid any obvious or implicit conflict between our personal interests and those of the company. Any actual, potential or perceived conflict of interest must immediately be disclosed to a Mammoth director for approval. Examples include:

• offering a contract on behalf of Mammoth with a supplier managed by a close friend or family member;

• working as a consultant, paid or unpaid, in a private capacity for a supplier or customer of Mammoth;

• having or entering into personal relationships in the workplace;

• having a personal or financial interest in a business that has transactions or dealings with Mammoth; or

• obtaining a personal financial gain or advantage (other than normal remuneration) in business transactions or dealings involving Mammoth.

No one should use any inside information they have gained through their engagement with Mammoth for his or her own advantage, for that of a friend or relative or for anyone else. “Advantage” in this context includes both positive benefit and avoiding what might otherwise result in a loss.

b. Honesty and fair dealing

We should be honest, fair and truthful in all of our dealings. Our stakeholders (including colleagues, customers, consumers, business partners, suppliers and governmental authorities) expect absolute integrity from us. We must never attempt to deceive or mislead others.

c. Confidential information and trade secrets

Please protect the company’s confidential information both during and after your engagement. Confidential information and trade secrets include any of our information and technology, financial, operational or strategic plans or data and any financial, commercial or technical information that is valuable to us and has not yet been disclosed to the public and may be valuable to a third party if they had access to it.

If you have access to confidential information and trade secrets, you must be careful about its use and be vigilant about protecting it from disclosure. You should comply with our obligations to maintain the confidentiality of information received from third parties.

Whilst you should be aware of and keep up to date with freely available industry information, you must not use any unethical, unlawful or improper means to obtain confidential information from any competitor, supplier, customer or other third party. This includes hiring any person with the intent of that person providing confidential knowledge of their former employer.

d. Inside information and share dealing

You must not buy, sell or transfer stock or shares of ITV plc (which is the ultimate owner of Mammoth) or any other companies, or buy or sell any property or assets, on the basis of inside information, i.e. information acquired through engagement here which has not been made public and may be share price sensitive. Colleagues must not provide such information to others for the purpose of financial gain or avoiding a loss. To do so would be a criminal offence.

Inside information includes any facts that may affect the price of shares and/or which a reasonable investor would consider important in deciding whether to purchase or sell shares and which have not been made public. Inside information should not be communicated to any other person with the expectation that they would deal in the shares of the company concerned.

Directors, senior managers and colleagues who are likely to be regularly in possession of material information about the company which has not been disclosed to the public are prohibited from dealing in ITV shares during certain periods. Please contact the ITV’s Group Secretariat for more information (groupsecretariat@itv.com).

e. Gifts, entertainment and sponsorship

Neither you nor any family members should give or accept any gift, entertainment, transportation, sponsorship, charitable donation or other benefit which might be intended or perceived as an attempt to improperly influence the business relationship between us and any current or prospective supplier, customer or other party doing business or connected with us.

This does not mean that customary and reasonable gifts or hospitality are not acceptable, such as token gifts, meals or transportation of modest value given or received in the normal course of business dealings. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable and not linked in any way to an improper act. Gifts of cash must never be made or accepted.

Please seek prior written approval from a Mammoth director using the Gift/Hospitality Notification Form for:

• any hospitality to be given to a third party or received by you which is in excess of a value of £500 per person; and

• any gifts (i.e. tangible assets) to be given to a third party or received by you with a value in excess of £100 per person.

Once you have received approval, as set out above then you should submit the signed notification form to Jo Silvester and to the Group Secretariat who will record the information in the ITV Gift and Hospitality Register. The Gift/Hospitality Notification Form is available from Jo Silvester.

In addition, all gifts or hospitality (even for amounts below those set out above) offered to a third party must either be claimed back through expenses via the company expenses procedure.

If you are in any doubt about what you need to do, please contact Jo Silvester, Jon Williams or James Penny.

f. Competition and competitor relationships

Collusion with competitors is strictly prohibited and may contravene competition laws resulting in serious adverse consequences for us including damage to our reputation, the imposition of heavy financial penalties and in some cases criminal penalties for individuals.

g. Speaking up

We are committed to an open working environment in which colleagues feel able to voice any concerns. We can only live up to the commitments contained in this Code if we speak up if something might be wrong.

Our collective responsibility to act with integrity and adhere to the Code and all Mammoth’s policies includes an obligation to exercise sound judgement in seeking help, reporting concerns and speaking up when observing unethical conduct or action that you suspect is inconsistent with the law, our Code or any of our policies.

We encourage you to seek guidance regarding any ethical dilemma and to speak up about genuine concerns in relation to unethical and/or illegal business behaviour.

If you suspect wrongdoing at work (including financial fraud, unethical business practices, illegal activities of any kind, dangers to workplace health and safety, the environment, or efforts to cover up any such activities in the workplace) then please raise your concern. You may feel worried about saying something or feel that it is none of your business or that it’s only a suspicion. If in doubt, raise it.

The wrongdoing doesn’t have to affect you directly – it’s ok to speak up on behalf of somebody else.

You can speak directly to your line manager, or  somebody at Mammoth or any of the contacts given in the ITV Speaking Up document. If you are uncomfortable using these routes, or where you believe that your concern has not been adequately addressed, please use the independent confidential Speaking Up Hotline managed by Safecall (0800 915 1571 or go to safecall.co.uk/itv to file a report).

Anyone raising a concern in good faith will not be criticised or penalised in any way even if it is shown, after investigation, that they were mistaken. Any form of reprisal or victimisation against anyone who has raised a genuine concern will not be tolerated and will itself be treated as a serious disciplinary matter. If a concern were to be raised maliciously then that would also be a serious disciplinary matter.

16. Our dealings

a. Customers & Viewers

We must act appropriately and quickly in relation to any complaints.

We are committed to providing viewers and customers with accurate information on which they can make an informed decision.

The trust of viewers, the wider public and customers is central to everything we do. We will not hesitate to take appropriate disciplinary action against anyone who breaches that trust.

When making our programmes, we are committed to being honest, fair and transparent and not to mislead viewers in any way.

b. External suppliers

We deal with a wide range of suppliers of goods and services and they should be treated with respect and fairness at all times.

It is our intention to contract only with suppliers who satisfy our standards with regards to labour and welfare conditions, health and safety, anti-slavery, anti-bribery, the prevention of tax evasion and/or facilitation of tax evasion, information and cybersecurity, and environmental management or who have given a commitment to achieve these standards within an agreed time-frame.

We will observe high ethical standards in all our dealings with customers and suppliers. Any corrupt, improper or unethical behaviour in dealings with customers and/or suppliers is prohibited.

c. Public and government officials and employees

In some countries, specific rules apply to the business relationship, contract negotiation or contract terms with government agencies and officials. People engaged in business with any governmental body, agency or official must know and abide by those rules. Any violation of these rules may result in harsh penalties for us, and even criminal prosecution.

You must avoid any dealings that might be perceived as attempts to improperly influence public officials in the performance of their official duties and they must not give to, or receive any gifts from, government employees or officials.

There are laws restricting companies from hiring as an employee or retaining as a consultant a present or former government employee (other than secretarial, clerical or other similar grade employees). These restrictions may also cover informal agreements for prospective employment.

You must obtain written clearance from Jon Williams, James Penny or Emily Russell before discussing proposed employment or retention with any current or any former government employee who left government employment within the past two years.

d. Official requests for information

If you are contacted by government regulators or authorities, agents, investigators, lawyers who do not represent the company or by other third parties seeking information or documents concerning investigations or potential or actual litigation, you should immediately notify James Penny, Jon Williams or Emily Russell.

e. Contacts with the media

No statement should be made or opinion expressed to the press or any third party without the explicit permission of a Mammoth director and the supervision of ITV’s Corporate Affairs department or programme publicity team.

All enquiries from the press and other media must be reported to a Mammoth director.

Speaking to the press or any other media on behalf of the company without the express permission of a Mammoth director is prohibited.

f. Advertising and marketing

All our advertising and marketing must be ethical and lawful. To achieve this, we need to be accurate and avoid misrepresenting ourselves, our programmes, products or our services, avoid defaming our competitors and respect the privacy rights of individuals to whom we may direct marketing materials.

g. Bribery and corruption

Bribery is a common form of corruption. Bribes (the giving or receiving of anything of value or advantage to try and make someone do something improper or reward them for this) are illegal and the giving or receiving of them a criminal offence.

Any colleague who solicits, participates in or condones a bribe or other unlawful payment or benefit or attempts to participate in any such activity, will be subject to strict disciplinary action, including dismissal and may be the subject of criminal prosecution.

We could be liable even if one of our agents, suppliers or other intermediaries bribes someone without our knowledge for our benefit. When choosing agents, suppliers or other intermediaries please carry out pre-contract enquiries to ensure that they do not accept or give any bribes, and require contractual protection and commitments from them as to their compliance with anti-bribery laws. If you need any help, please contact James Penny or Jon Williams.

You must be vigilant to anything you think may be a bribe and report this to your line manager immediately.

We are all committed to an open working environment in which we feel able to voice our concerns. If you are worried about raising an issue with your line manager then please feel free to contact any Mammoth director or you can raise it via the Speaking Up policy.

h. Modern Slavery

Please read and comply with the Company’s Modern Slavery Statement at mammothscreen.com.

We are committed to ensuring that human rights abuses and modern slavery are not a feature of our operations and supply chains. We know that such practices can be hidden and hard to uncover and can affect workers across the world in a wide range of sectors. We are also conscious that to tackle modern slavery, we need to address poor labour practices wherever they occur as tolerating them can provide the conditions for exploitation.

We aim to identify and address the risks of modern slavery in our operations and supply chains by:

• Conducting human rights due diligence on our business activities and relationships

• Reviewing our own commissioning and purchasing practices to ensure they do not contribute to poor labour practices

• Engaging our suppliers, partners and peers to find ways of working together to reduce risks

• Enabling workers in our operations, productions and supply chains to raise concerns

• ‍Listening to those potentially affected by poor labour practices and taking action to address the issues they flag

• ‍Being victim-centric in our response

We expect you to:

Think about your area of work and consider where there could be risks of labour exploitation

• ‍Consider whether our activities or approach make poor labour practices more likely

• ‍ Flag potential issues to your manager or supervisor

• ‍ Raise awareness of labour issues among your contacts internally and externally

• ‍ Be curious about the people involved in our operations, business relationships and supply chains.

i. Money laundering

Money laundering is the process of concealing the identity of illegally obtained money so that it can be transformed from “dirty” money into “respectable” money or other assets. Colleagues must not engage in any transaction which they know could reasonably be considered to be money laundering. If you have any queries or concerns then please contact James Penny or Jon Williams.

j. Donations and political activities

It is our policy not to make cash donations to political parties.

Any political activity and participation in electoral politics must occur strictly in an individual and private capacity and not on behalf of the company. Do not use company time, property, equipment or funds to conduct or promote personal political activity. You should also not suggest that your views are representative of Mammoth or that Mammoth supports your personal views.

We only make charitable donations that are legal and ethical under local laws and practices. All charitable donations must comply with our Charitable Donation Policy.

k. Compliance with laws and contracts

You are responsible for complying with the laws, regulations and codes of practice applicable to your areas of responsibility. You should seek assistance from James Penny, Melanie Morris or Laura Johnston for the creation, negotiation, amendment and/or termination of any contract.

We are committed to complying with our contractual obligations and take seriously any failure by another party to do the same.

You should also contact our Legal team if you have any matters of concern arising under this Code of Ethics and Conduct, any applicable laws, regulations and codes of practice or any issues related to business ethics.

If you have any questions, please contact any Mammoth director.

17. The Environment

We strive to identify and understand the environmental aspects of our operations and adopt processes that encourage the conservation of resources and energy.