Our success depends on the highest standards of professionalism of all of our colleagues – in all our external dealings and in how we conduct ourselves in relation to other individuals. Upholding our ethical principles and guidelines is dependent on all colleagues understanding and observing them. 

Our Code of Ethics and Conduct demonstrates our commitment to ethical business conduct, to make sure we’re complying with all relevant laws and regulations and to demonstrate that such conduct is a fundamental part of our values and culture. 

This Code is not intended to cover every eventuality that could arise but instead provides guiding principles as to how we should deal with a particular situation and where to go for guidance and support. The need for personal accountability and individual good judgement by all of us 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 adherence to the letter and spirit of this Code seriously - our colleagues, ITV shareholders, investors, viewers, producers, suppliers, advertisers and other stakeholders expect no less from us. Breach of the Code could result in disciplinary action, so it’s vital that we all comply. 

1. Equal opportunities, respect, dignity and understanding 

All colleagues should be treated fairly and courteously, whether in/out of normal working hours, or in/out of the workplace. 

All colleagues will have equal opportunities in their engagement. People will be recruited for their aptitude, skills, experience and ability. 

Each colleague is responsible for upholding and implementing our Equal Opportunity policy in the workplace and any other policy dealing with such matters. 

2. Harassment, discrimination and abusive behaviour 

We are committed to a working environment that is 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 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 is any conduct that creates an intimidating, hostile or offensive working environment, violates a person’s dignity or unreasonably interferes with an individual’s work performance. A single incident can amount to harassment - it doesn’t have to be an ongoing problem. Examples include: 

• threatening behaviour, intimidation, harassment, assaults or violence;

• sexual, transphobic or racial harassment; 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 are committed to the safeguarding and protection of children and take both our legal and moral duties to children very seriously. Colleagues who work with children must follow our Child Protection Policy. All colleagues should respect children (any person under 18 years old) and conduct themselves appropriately around any child who is working with us, visiting or who has made contact with our business. If a colleague has any concerns regarding a child’s welfare they must tell a Mammoth director or you can use the confidential Speaking Up Hotline. 

4. Drugs and alcohol 

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

Colleagues whose behaviour, judgement or performance of their work responsibilities is impaired by drugs or alcohol will be prohibited from entering our premises or engaging in company business and may be subject to disciplinary proceedings in appropriate circumstances. 

5. Theft or misuse of property 

Any colleague found to be engaging in, or attempting, theft, fraud or misuse of any property of the company or the personal property of other colleagues may result in dismissal. Matters may also be referred to public authorities for possible criminal prosecution. 

Theft, fraud or misuse of company property can take many forms. Examples include, but are not limited to: 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

YYou 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 a different password must be used to that used to access Mammoth’s network. 

Software / Keeping devices safe 

All software on any device must be properly licensed and when operating in the Mammoth environment 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. 

Keeping our data safe means we must always be vigilant. Malware (malicious software) is often sent by email (e.g. phishing) and these can cause significant damage to our information systems. Be particularly cautious in relation to unsolicited email from unknown sources or to urgent requests for personal information or payments to be processed. Do not open such emails unless you are sure of the sender and the contents. 

Use of email 

You must exercise the same care, caution and etiquette in sending email or other messages as you would in normal written business communications. 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. You must never 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. 

Reporting Incidents 

You must 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. Colleagues may not register any Mammoth intellectual property rights, including trademarks, internet domain names or social media accounts in their own names.

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. At Mammoth we sometimes use intellectual property, trade secrets and/or confidential information belonging to others under licence. We expect colleagues to ensure that their use of any such assets or information is permitted by the owner and does not infringe anyone’s intellectual property rights.

10. Health & Safety 

We are committed to conducting our business with the utmost concern for the health and safety of our colleagues, customers and the general public. 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. 

Every colleague is responsible for checking and ensuring that their working environment is healthy and safe. As well as considering their own health and safety, colleagues must also consider the health and safety of anyone who may be affected by their 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 Jon Williams or James Penny. 

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. The company has a system of limits and other controls for the proper authorisation of expenditure which must be adhered to, 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. Preservation and protection of corporate assets 

Every colleague has a duty to preserve and protect our assets, including our property, equipment and monies, and is expected to use those assets properly and appropriately. Please report to your line manager any suspected fraud, theft or abuse of our assets by either a colleague or any third party, or you can use the confidential Speaking Up Hotline. 

14. Creating documents and retaining records 

All colleagues must ensure that any documents created (electronically or otherwise) are accurate, clear, detailed and timely. They must also be written in a polite tone. In order to comply with our legal and regulatory requirements, we may be required to retain our 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 a particular investigation or legal dispute must not be destroyed once we have received notice of related pending litigation. 

15. 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 of a conflict of interest could be if any colleague: 

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

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

• carries on a business in their own time of a similar nature to their work at Mammoth;

• is in, or enters into a personal relationship in the workplace;

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

• obtains 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 

Every colleague has a responsibility for protecting the company’s confidential information both during and after their engagement by the company. 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 

Colleagues and their family members should not 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 

We aim to compete vigorously and fairly in the marketplace and so all colleagues are required to comply fully with laws governing free and fair competition. 

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 all act with integrity and 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.

Any colleague who suspects 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) should raise their concern. You may feel worried about raising such an issue, perhaps feeling that it is none of your business or that it’s only a suspicion. If in doubt, raise it. Although the vast majority of workers are honest and act reasonably, no organisation is immune to acts of dishonesty and other misconduct. 

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

Colleagues can speak directly to their manager or any other senior manager or to any of the contacts given in the ITV Speaking Up policy. 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. Full details are available on myITV. 

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 was 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 producers and 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 producers and suppliers. Any corrupt, improper or unethical behaviour in dealings with producers and/or suppliers is prohibited. 

We will also seek to promote the same ethical standards and high level of corporate responsibility with our producers and suppliers as we operate within Mammoth. 

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. All colleagues 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. 

Colleagues must obtain written clearance from Jon Williams or James Penny 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 or Jon Williams. 

Immediate notification to Jon Williams or James Penny is critical when requests are made in the form of a legal document requiring a response by a specified date. 

e. Contacts with the media 

As part of ITV plc, we are committed to delivering accurate and reliable information to the media, financial analysts, investors, brokers and other members of the public. We are committed to responding to all public, media and other enquiries appropriately. 

All public disclosures including forecasts, press releases, speeches and other communications will be honest, accurate, timely and representative of the facts. 

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 by our colleagues must occur strictly in an individual and private capacity and not on behalf of the company. Colleagues may 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 or Melanie Morris 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

Mammoth recognises the importance of our responsibilities towards 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.