Grupo Clarin S. A.

GRUPO CLARÍN S.A.

Annual Report and Con

solidated Financi

al Statement

s

For the year ended Dec

ember 31, 2021,

presented on a co

mparative basis

 
 
 
 
1 
 
 
 
 
 
INTEGRATED ANN
UAL REPORT 
2021 
 
INDEX 
 
1. 
MESSAGE FROM TH
E CHAIR
.......................................................................................................
3 
2. 
ABOUT THIS REPORT
...................................................................................................................
4 
3. 
ABOUT THE CONT
EXT 
..................................................................................................................
4 
3.1. 
MACROECONOMI
C ENVIRONMENT 
IN 2021
......................................................................
4 
3.2. 
PERSPECTIVES FOR TH
E UPCOMING 
YEAR
....................................................................
5 
3.3. 
THE YEAR 2021 AND
 THE MEDIA SE
CTOR IN ARGENT
INA AND THE WORLD
..............
6 
3.4. 
REGULATORY FRAM
EWORK 20
21 .....................................................................................
8 
4. 
THE COMPANY. ORIG
IN, EVOL
UTION AND PRO
FILE
..............................................................
10 
4.1. 
COMPANY PROFI
LE 
................................................................................................
............
10 
4.2. 
GRUPO CLARÍN AN
D ITS BUSINESS
 SEGMENTS IN
 2021
.............................................
12 
4.2.1. 
PRINT AND DIGITAL
 PUBLICATION
S 
........................................................................
12
 
4.2.2. 
BROADCASTING 
AND PROG
RAMMING 
....................................................................
19 
4.2.3. 
OTHER 
..........................................................................................................................
23
 
4.3. 
AWARDS AND R
ECOGNITIONS
................................
.........................................................
23 
5. 
FINANCIAL POSITIO
N AND RE
SULTS OF ITS OP
ERATIONS
................................
..................
24 
6. 
CORPORATE GOV
ERNANCE, ORG
ANIZATION, A
ND INTERNAL
 CONTROL S
YSTEM
.........
25
 
7. 
SUSTAINABILIT
Y 
..........................................................................................................................
28
 
7.1. 
SUSTAINABILIT
Y STRATEGY 
.............................................................................................
28 
7.2. 
VALUE CREATION 
MODEL AND FRA
MEWORK OF 
THE INTEGRAT
ED REPORT
.........
28
 
7.3. 
INDEPENDENCE,
 TRANSPARENC
Y, AND INTER
NATIONAL GUIDEL
INES
...................
30
 
7.4. 
DIALOG AND ALLIAN
CES
...................................................................................................
31 
8. 
RESPONSIBLE CRE
ATION AND DISTR
IBUTION OF
 CONTENTS
............................................
31 
8.1. 
ETHICS AND EDITO
RIAL GUIDELINE
S
.............................................................................
31
 
8.2. 
DIGITAL PLATFORM
S AND TECHNO
LOGY
......................................................................
32
 
8.3. 
OUTSTANDING IN
VESTIGATIONS 
AND CONTENT
S
.......................................................
33
 
8.4. 
INTERACTION WITH 
AUDIENCES AND 
READ
ERS 
..........................................................
34
 
8.5. 
SOCIAL COVERAGE
................................................................................................
............
36 
8.6. 
PROMOTION OF DIVE
RSITY 
..............................................................................................
36
 
8.7. 
CIVIC INVOLVEM
ENT AND PU
BLIC DEBATE
....................................................................
38 
8.8. 
ACCESSIBILITY A
ND PROTECTION OF V
ULNERABLE A
UDIENCES
.............................
39 
9. 
CUSTOMERS AND S
UPPLIER
S 
................................
..................................................................
40 
9.1. 
CUSTOMER SERVIC
E AND S
ATISFACTION
.....................................................................
40
 
9.2. 
VALUE CHAIN
......................................................................................................................
41 
10. 
OUR PEOPLE
...........................................................................................................................
41 

 
 
 
 
2 
 
 
10.1. 
T
EAM MANAGEMENT
.........................................................................................................
41 
10.2. 
INT
EGRITY PROGR
AM .......................................................................................................
42 
10.3. 
CO
MMUNICATION 
AND DIALOG
........................................................................................
43 
10.4. 
WORK-
LIFE BALAN
CE AND BENEFIT
S 
.............................................................................
44 
10.5. 
PRO
FESSIONAL DE
VELOPMENT
......................................................................................
44 
10.6. 
HEA
LTH AND SAF
ETY ........................................................................................................
45 
11. 
SOCIAL DEVELO
PMENT
.........................................................................................................
45
 
11.1. 
PRI
VATE SOCIAL IN
VESTMENT 
STRATEGY
....................................................................
45
 
11.2. 
CO
MMUNITY ENGAG
EMENT AND 
SOCIAL AD
VERTISING
................................
.............
45 
11.3. 
T
HE ROLE OF TH
E MEDIA IN EDUC
ATION
.......................................................................
46 
11.4. 
F
OSTERING EDUCATION
...................................................................................................
47
 
11.5. 
PRO
MOTION OF CULTUR
E AND SOC
IAL DEVELOP
MENT
.............................................
48
 
11.6. 
ALLI
ANCES WITH CI
VIL SOCIETY ORG
ANIZATIONS
......................................................
48 
12. 
THE ENVIRONM
ENT ...............................................................................................................
49 
12.1. 
CO
NTENT THAT PRO
MOTES EN
VIRONMENT
AL AWARENES
S
....................................
49 
12.2. 
ENV
IRONMENTAL M
ANAGEMENT
 AND POLICY
.............................................................
49
 
12.3. 
MAT
ERIALS 
..........................................................................................................................
50 
12.4. 
ENE
RGY AND EMI
SSIONS
................................................................................................. 
50 
12.5. 
WA
STE 
..................................................................................................................................
51
 
12.6. 
WAT
ER AND EFFLU
ENTS 
...................................................................................................
52 
13. 
RISK FACTORS
................................
........................................................................................
52
 
14. 
BUSINESS PROJE
CTIONS AND P
LANNING
.........................................................................
74
 
15. 
PROPOSAL OF THE 
BOARD OF DIR
ECTORS
......................................................................
74
 
16. 
EXHIBIT I - REPORT ON THE CODE OF 
COR
PORAT
E GOVERNANCE OF GRUPO CLARÍN 
S.A.  
75
 
17. 
EXHIBIT II –
 GRI CO
NTENT INDEX 
AND COMMUNIC
ATION ON PROG
RESS 2021
..........
86 
18. 
EXHIBIT III –
 NOT
E ON COVID-
19
........................................................................................
105 
 
 
 
 
 
 

3

1.

MESSAGE FR

OM THE CHAIR

Messrs. Shareholders,

I

am

pleased

to

present

the

Integra

ted

Annual

Report

of

Grupo

Clarín

S.A.

which

consolidates,

in

a

single

document,

the

reporti

ng

on the

Group's

econo

mic

-financial, social,

environm

ental, and

corporate

governance performance.

Developed in

accordance

w

ith

t

he Int

er

national Int

egrat

ed

Report

ing

Council

guidelines

and

GRI

Standards,

it

follows

the

best

practices

of

transparency

at

the

global

level.

In

addition, it

shows the

progress made

in fulfilling

the 10

principles of

the

Unite

d

Nati

ons Global

Compact

and

the contrib

ution to the Susta

inable Developme

nt Goals.

2021 was

marked by

the second

year of

the health,

social and

economic crisis triggered

by the

COVID

-

19 pandem

ic. In

the l

ocal context,

the

complex

macroec

onomic env

ironment g

enerated

an infla

tionary

acceleration, a

dec

line in

private consumption and

in the

GDP, which had

a considerable impact

on the

performance

of

this

industry.

However,

the

economic

recovery

of

2021

due

to

the

gradual

eas

ing

of

much

of

the

health

restrictions

impl

emented

in

2020,

eve

n

in

a

context

of

high

inflation

and

high

uncertainty, had an impact on

the advertising market and on

Grup

o Clarín’s revenues, especially in

the

Broadcasting and Program

ming segment.

The

subsidiaries of

the Group maintained

their position

and

leadership

in each

of

the business

segments: Print media, radio, broadcast and cable television, audiovisual content producti

on, and print

industry.

Amid

a

challenging

scenario,

we

pr

ovided

tr

uthful

and

relevant

informati

on

to

our

audiences

focusing on verifying c

ontents

to prevent tamperin

g and fake

news.

The

complex

reconversion

and

convergence

process

in

the

media

industry,

coupled

with

t

he

str

ong

impact

of

COVID-

19

and

t

he

lockdown,

co

ntinued

to

forc

e

companies

eng

aged

in

these

ac

tivities

to

reformulate

their

bus

iness models

to

adapt

to the

digital era

and

to the

changes

in

consumption

derived

from

ne

w

tec

hnologies.

Thus,

w

e

promoted

a

syner

gy

between

tra

ditional

m

edia

and

tech

nology

platforms,

expanding

the

reach

of

digital

aud

iences

and

offering

broad

mu

ltiplatf

orm

coverag

e

with

novel formats.

Throughout

the

year,

the

G

roup

re

inforced

its

commitment

to w

ork

r

esponsibly

to

satisfy

and

respo

nd

to

the

citizens'

right

to

infor

mation.

We

focused

on

further

contr

ibuting

to

the

development of

the

country

through the creation of responsible content, sustainable managem

ent in all business units, transparent

communication, and pro

motion of divers

ity.

In a

year

in which

the

impa

ct

of gl

obal war

ming

continued

to

be

evid

ent, t

he C

ompany

also

reinforced

its

commitment

to

environ

mental

awareness

with

an

ex

tensive

med

ia

coverage

and

dissemi

nation

of

the

United

Nations

Climate

Change

Conference

(COP26)

.

It

covered

forest

fires

,

floods,

and

w

ater

emergencies

in

Argentina

and

around

t

he

world.

The

Gr

oup

focused

on

the

environment

al

management

of each of its subsidiar

ies.

Looking

f

orward,

Grupo

Cl

arín

w

ill

seek

to

maintain

and

c

onsolidate

its

pres

enc

e

in

the

l

ocal

and

regional

market,

foc

using

on the

creation

of

quality

contents in

all

multimedia and

multiplatform

for

mats.

All

t

he

Group’s

busines

s

un

its

will

strive

to

seize

opportunities,

seekin

g

t

o

re

inforce,

i

mprove

and

expand

the range of pro

ducts and s

ervices offered;

increase mark

et share; reach ne

w audiences

and promot

e

permanent innovatio

ns in all its

activities

.

4

At

the

corporate

level,

it

will

continue

to

focus

on

the

core

processes

to

conso

lidate

a

sustainable,

healthy and efficient growt

h.

Best regards,

Jorge C. Rendo

Chair of Grupo Clarín

2.

ABOUT THIS REP

O

RT

We

hereby

submit

for

y

our

consideration

the

Annual

Report

an

d

Exhibit,

the

C

onsolidated

Statement

of

Financ

ial

Posit

ion,

the

Consolidated

Statement

of

Comprehens

ive

Incom

e,

the

C

onsolidated

Statement

of

Changes

i

n

Shareho

lders'

Equity

and

the

Co

nsolidated

Stat

ement

of

Cash

Fl

ows

and

Notes of Grupo Clarí

n S.A. (hereinafter, “the C

ompany”

or “Grupo Clarín”) for fisc

al year No. 23 ended

December 31, 2021.

The

ma

in

subs

idiaries

in

which

Grupo

Clarín

S.

A.

h

as

a

direct

or

indirect

controlling

interest

are:

Arte

Gráfico

Editorial

Arg

entino

S.A.

(AGEA),

Co

mpañía

In

versora

en

Me

dios

de

C

omunicación

CIMECO

S.A.

(CI

MECO),

Arte

R

adiotelevisivo

Arge

ntino

S.A.(AR

TEAR),

GC

G

estión

Com

partida

S.A.,

Inv

ersora

de Eventos S.A.(IE

SA), and Radio Mitre S.

A.

Grupo

Clarín

prese

nts

its

fir

st

Integrated

Report,

a

document

that

includes

its

Annual

Report

and

its

Sustainability

Report. It

is a

s

ingle

doc

ument in

which the

Company reports

on

its economic, social,

and

environmental

performance

.

This

pub

lication

was

prepared

in

accordan

ce

with

the

guidelines

of

“The

International <IR> Fr

amework

” developed by the Internati

onal Integrated

Reporting Counci

l (IIRC).

3.

ABOUT THE CON

TEXT

3.1.

MACRO

ECONOMIC EN

VIRONMENT

IN 2021

Argentine

economy

closed

the

year

2021

w

ith

opposing

results

regard

ing

the

2020

-2021

global

cris

is,

despite the externa

l surplus collected.

This raises questions

about the short

- and me

dium-term

performance,

es

pecially

bec

ause

of

the

uncertainty

posed

by

the

c

ourse

of

the

economic

policy

and

because of the agreem

ent t

hat the Governmen

t has to reach wit

h the IMF and its

due compliance.

The

most

re

levant

indicators

of

fiscal

ye

ar

2021

were

the

evo

lution

of

the

va

lue

of

exp

orts

(+

42%

or

US$23.000

million

from 20

20, r

ecovering fro

m

the 16%

decline

in

2020),

the

increase

of

the

real GD

P

(close

to pre

-pandem

ic lev

els),

and

a fisc

al

deficit

of

approximate

ly 3.0%

at the

nationa

l leve

l reach

ed

in an election year.

Among the

ne

gative indicators,

Argentina experienced an

ac

celeration of

i

nflation levels

(+50.9% in

the

year,

+

15%

than

in

2020)

with

the

consequent

adverse

effect

on

the

purc

hasing

power

of

wages

and

pensions,

an

d

the

gro

wing

sovereign

indebtedness

(equivalent

to

a

lmost

+USD28.000

million

i

n

the

year) and

that

of

the

Central

Bank (m

onetary

base

and r

emunerated

liab

ilities gr

ew +1

00%

and

+68%

point-

to

-point). More

over, the large

exchange

-rate gaps (

of more than 100%) are

a cause of concern.

5

The

economy

r

emained

under

pressure

despite

so

me

relevant

events

that

were

intended

to

generate

dynamism. The

f

irst was

th

e easing

of most of

th

e

mea

sures aimed

at mitigating

C

OVID infections.

The

effect

on

activity

was

positive

an

d

was

reflected

in

the

se

cond

half

of

the

y

ear,

m

ainly

in

t

he

rec

overy

of services such as trad

e, gastr

onomy, and hotel

business.

At the same

time, t

he econ

omy received a

significa

nt extr

aordinary foreign

currenc

y injection fro

m two

sources. As a resul

t of the s

ignificant rise i

n th

e price of agric

ultural commod

ities in general

and of soy

in

particu

lar,

the

surr

ender

of

forei

gn

exchange

by

the

agr

icultural

sector

was

a

record

high

for

this

century

(~USD33,000

millio

n) and

the

val

ue o

f Arg

entine

exports

rose

to

almost

USD78,000 m

i

llion, a

growth

of

+USD23,000

million

in

absolute

values.

As

a

result,

revenues

from

export

duties

(taxes

on

exports)

grew

by

almost

150%, incr

easing

the

country's

r

evenue co

llection

levels.

In

add

ition,

the

IMF

issued US$ 4,300 mil

lion in Special Draw

ing

Rights (SDRs)

.

This

significan

t

for

eign

exchange

injection

allowed

the

government

to

use

offi

cial

exchan

ge

r

ates

(together

w

ith

th

e

near-fre

eze

of

utility

tariffs

,

including

tr

ansportation)

in

an

attempt

to

moderat

e

inflation

(which

conti

nued

its

upward

tre

nd).

Thus,

t

he

multilateral

exc

hange

rate

index

showed

a

deterioration of 17%

in real terms as me

asured by the

Central Bank of Arg

entina.

The

normalizatio

n

of

CO

VID spending

and

the high

f

iscal imbalances

resulting from

the pandemic

w

ere

the

comm

on

den

ominator

for

the

world's

ec

onomies

in

2021,

and

Argent

ina

was

no

exception.

In

this

sense,

it

is

worth

noting

that

after

an

unprecedented

6.4%

record

high

in

2020,

the

primary

fiscal

imbalance

at

the

national

level

closed

the

year

at

around

3.0%

of

GD

P

(

4.

5%

c

onsidering

interest

payments on sovere

ign debt).

Argentina’s

fiscal

imbalances

over

the

past

t

wo

years

were

“monetized”

by

the

Central

Bank

for

the

most

part,

and

then

“steriliz

ed”

partly

through

the

plac

ement

of

remun

erated

l

iabilities

in

ba

nks

(wi

th

rising interest expense). S

ome of the hi

ghlights that illu

strate the above are:

a.

The BCRA's fi

nancia

l assistance to

the Treasury accumulated

during the period

2020/2021

amounted

to

$3.7

billion

(7.3%

and

3.6%

of

G

DP,

respectively).

If

it

had

n

ot

been

st

erilized,

t

his

issue

would

have

been

equivalent

to

slightly

more

than

doubling

the

monetary

base

recorded

at

the end of 2019;

b.

As

a

result

of

the

ster

ilization,

the

BCRA's

stock

of

re

munerated

liabilities

(mainl

y

Liqui

dity

Bills

(LELIQs)

and Reverse

Re

purchas

e

Agreements)) amounted

to

a

record

high

of

$4.5

billion

(average

Dec-2

021)

and it

was nearly

four times

h

igher than

the

figure recorded

at the

end

of 2019

and just over 30% hig

her than the m

onetary base.

The

Argentine

economy

has

low genui

ne

demand

f

or

the

currency

it

issues

and

negative

rea

l

interest

rates

for

savings.

The

excess

of

pesos

often

translates

quickly

into

excess

demand

for

goods

and/or

dollars. Under

foreign exchange

control regimes, this

additional demand

for foreign currency

generates

in

creases

in

the

diff

erent

alternative

exc

hange

rates

of

the

US

do

llar

existing

in

Arg

entina

and,

therefore,

widens the gaps betw

een the unofficia

l rates and the “official”

ARS/USD exchan

ge rate.

The exchange-

rate gap

does

not only

have a

marginal

impact on

prices,

but also

fuels exp

ectations o

f

devaluation. Even if

the official exchange

rate is

ar

ound the

historical average, the large

exchange

-rate

gaps

generat

e

the

widespread

perc

eption

of

a

chea

p

dollar

that

erodes

both

the

external

front

flows

and

the

BCRA’s

reserv

e

stock

.

In

an

extreme

sc

enario,

t

he

monetary

authority

could

e

nd

up

with

its

reserve position be

ing decimated and b

eing forced to let off

icial parity float, exac

erbating the crisis.

3.2.

PERS

PECTIVES FOR TH

E UPCOMING YE

AR

The

ec

onomy

c

ontinues

t

o

prese

nt

high

and

s

ustained

fiscal

imbalanc

es

t

hat

are

exacerba

ted

in

election

ye

ars.

T

hese

may

repres

ent

a

potential

source

of

imbalance

for

the

r

est

of

the

f

undamental

economic vari

ables. Fi

nanc

ing fiscal

deficits t

hrough

inflation

tax often

leads t

o ce

rtain consequ

ences:

6

stagflation,

s

carcity

of

fore

ign

currenc

y,

growi

ng

exc

hange

contro

ls,

and

deteri

oration

of

the

s

ocial

environment.

The

trade balance of

the Argentine economy

has been showing high surpluses

sinc

e

2019, higher than

US$10,000

million.

While

there

is

an exc

ess flow

of

US

dollars,

partly ex

plained

by the

current

foreig

n

exchange

administration

sc

heme,

the

Central

Bank

has

a

c

ritical

stock

of

reserves

used

to

make

payments

on

the

coun

try's

sovereign

de

bt

a

nd

to i

nterv

ene

in

the

official

and

financial

exc

hange

market.

The

baseline

scenario

foreseen

for

the

local

economy

by

c

onsultants

and

investment

banks

for

2022

contemplates

t

wo

critica

l

ass

umptions:

That

the

Gove

rnment

w

ill

reach

so

me

sort

of

agreem

ent

with

the

IMF

to

be

approved

by

the

Congress

before

t

he

m

aturities

in

March

which

a

mount

to

~USD2,900

million

and

that

it

wi

ll

kee

p

C

OVID

infections

u

nder

control

to

avo

id

new

health

restri

ctions.

This

scenario

also f

oresees

the

com

plex

ities p

osed

by

an

adv

erse

external

front

, w

hich

will

mak

e less

likely to

hav

e

an external surplus such

as the one rec

orded in 20

21.

In this

way, the speed at

which the fiscal imbalance will

be unwound in

the coming years and which

will

be

t

he sources

of financing wi

ll be

fundamental to

measure the

performance of

t

he Argentine

economy.

The econo

mic au

thorities

have proj

ected the

gene

ral gu

idelines

for the

unwinding

of the

fiscal

imbalance

over

the

n

ext 4

years,

but

wi

thout

specifying

in

d

etail

the

respect

ive

paths

of

revenues

and

spending.

A

sustainable

agree

ment

w

ith

the

IMF

cou

ld

result

in

better

access

to

financing

f

rom

the

private

and

public

s

ectors.

This

maj

or

challenge

is

likely

t

o

h

ave

less

support

fro

m

t

he

external

front,

wh

ich

is

expected

to

be

less

benign

(

lower

volume

of

agr

icultural

exports

d

ue

to

the

effects

of

the

climate

phenomena

called

La

Niñ

a

and

greater deficit

in the

bal

ance

of

services, as

the outbound

touris

m

tends

to norma

lize). This

scenari

o could

lead t

o add

itional r

estrictions on

the dema

nd f

or fore

ign currency

or

some adjustment of

the official exc

hange rate par

ity.

The impact

of this

nomina

l corr

ection on eco

nomic ac

tivity

and infla

tion will

depen

d on

the size

and

its

implementation.

In

addition

,

segmented

increases

of

utility

tariffs

are

expected

to

reduce

the

growin

g

fiscal burden of welfare

payments.

Private

entities

estimat

e

a

real

grow

th

of

the

G

DP

o

f

around

3%.

In

this

way,

t

he

G

DP

wou

ld

allow

to

chain

2

consecu

tive

years

of

recovery,

but

it

would

still

be

about

6%

belo

w

the p

eak

v

alue r

eached

in

2017.

Private

sector

inflation

exp

ectations

for

20

22

(acc

ording

to

the

Mark

et

Expectation

Survey

c

onducted

by the Central Bank) are

around 55%

, above the 33%

projected

in the Budget Bill.

3.3.

THE Y

EAR 2021 AND T

HE MEDIA SECTOR I

N ARG

ENTINA AND T

HE WORLD

The

complex

reconvers

ion

and

convergence

process

in

the

media

industry,

coupled

with

t

he

str

ong

impact of

the outbreak of

C

OVID-19 and the

lockdown, continues to

force companies engaged in

t

hese

activities

to

reform

ulate

th

eir

business models

to

adapt

to

the digital

era and

to

the

cha

nges

in

consumption de

r

ived

from

new technologies.

In ad

dition

,

the

sustained migration

of ad

vertising towards

the

digital

environment

is

conc

entrated

in

a

few

fully

digital

global

players

,

especially

Facebook,

G

oogle,

Amazon and, to a less

er extent, Asia

n companies such

as Alibaba and Tence

nt.

Faced

wi

th

is

c

ontext,

the

sustainab

ility

challenges

and

certain

negative

side

e

ffects

inherent

to

the

expansion

of

the I

nternet

(s

uch

as

the

c

haotic

dissem

ination

of

news

-

tr

ue

and

f

ake

-

or

the

wor

rying

news

biases

create

d

by

th

e

algorithms

of

s

ocial

medi

a

and

platforms

that

reinfo

rce

their

users

’

own

beliefs),

the me

dia

continue

to

focus

on

gain

ing

strengt

h.

To

this

end,

th

ey

emp

hasize

differential

asset

s

such as the

credib

ility of their

brands

, they bet on

inco

rporating new technologies into their newsrooms

(content,

commerc

ial,

mark

eting,

big

data,

and

machine

learning),

and

hig

hlight

the

institutional

r

ole

they have historically p

layed in democr

atic soc

ieties.

7

Over the past

few years, the multimedia paradigm has been fully consolidated. The multiplatform is

the

norm

and,

without

except

ion, tra

ditional

media

are

exploring

other

languages

.

In

this

way,

the

consumption of

co

ntents

is simultaneous, overlapped

and

throu

gh multiple

windows. In

2021,

this trend

deepened as

a consequence

of the

quarantine ordered by

the National

Governmen

t

due to

the

CO

VID

-

19

pan

demic.

Video

consu

mption

via

OTT

platforms

(Netfl

ix,

F

low,

Amazon

Prim

e

Video,

HBO,

and

Disney+, among

others) has

increased as

wel

l

as the

revenues they

generate, a

tr

end that

will

continue

over the n

ext few y

ears. Du

ring the per

iod, there

was a

lso a s

ignificant

increase in

the consu

mption

of

e-books and Gamin

g products

.

Due

t

o

t

he

unusual

c

ontext

generated

by

the

pand

emic,

at

f

irst,

the

me

dia

industry

suffered

a

severe

impact on

its

economic

indic

ators. It

accelerated

chan

ges in

consumer

behav

ior

and digit

al disr

uption.

According

to

P

WC's

latest

annual

Global

E

ntertainmen

t

& M

edia

Outlook,

the

industry

revenues

grew

in

2021

at

a

rat

e

of

around

6.5%

(a

bove

gl

obal

GDP)

largely

driven

by

the

growth

of

advertisi

ng,

strongly

affected

during

2

020,

and

by

the

i

ncreased

consumption

of

digital

me

dia,

entertainment,

and

data.

In

thi

s

way,

digita

l

content

continued

to

increase

its

s

hare

in

the

revenue

structure

of

these

c

ompanies

and has consolidated i

tself, in many cases, as t

he main s

ource of revenues.

It

is evi

dent that

more

and more

users are

selecti

ng

the contents

t

hey

consu

me prioritizin

g

preferences,

quality,

convenience,

and

truthfu

l

information.

Therefore,

the

companies

in

this

industry

want

to

have

direct

contac

t

wi

th

the

us

er

to

build

loyalty

throu

gh

the

adde

d

va

lue

of

their

bran

ds

a

nd

th

e

personalization of conte

nt and ser

vices that they may d

evelop in the future.

While

au

diences

c

ontinue

to

migrate

to

the

digita

l

wor

ld,

users

increasingly

pr

efer

mobile

d

evices

to

search

for

the

contents

that

best

s

uit

t

heir

preferenc

es.

According

t

o

Chartbeat,

77%

of

the

visi

ts

to

news

sites

are

mad

e

from

a

mob

ile

phone.

This

phe

nomenon

poses

b

ig

c

hallenges

for

a

n

industry

forced to constantly cha

nge and adapt t

he contents and the

ads to mobile screens

.

During 2021, there was an increase in the number of users willing to subscribe and

pay for viewing the

content and

serv

ices that

they consume

the most,

espec

ially

in the

case of

platforms or me

dia that

they

already visited, but anony

mously.

Thus,

the

proces

s

of

co

nsolidating

s

ubscriptions

as

the

main

s

ource

of

r

evenues

in

th

e industry

continued

a

nd

deepened

during

2021,

largely

driven

by

the

consu

mption

of

video

streaming

(

mainly

OTTs),

digital

mus

ic,

podcasts,

video

games

and

several

digital

newspa

pers

that

l

aunched

and

boosted

their

paywall

m

odels.

In

f

act,

Deloitte

an

d

PWC

a

lready

estimate

that

th

ere

are

m

ore

consumers

subscribed to

at

least one video

s

treaming service

than to

a traditional

T

V

service. In the

U

nited States,

cable TV recorded a

fur

ther drop

in audience among

all age groups, espec

ially young people.

The

industry's

long-term

outlook

is

challenging

but

positive,

which

demonstrates

the

flexibility

and

adaptability of the

ecosy

stem. Professional reports argue

that the consumption of digital content

will be

the

industry

's

main

global

growth

fact

or

in

th

e

com

ing

y

ea

rs.

Succes

sful

media

will

be t

hose

that

best

adapt

their

strat

egies

to

engage

consumers

with

t

he

most

convenient

products,

services

,

and

experiences.

In

the

local

cont

ext,

just

lik

e

in

2020,

th

e

complex

m

acroeconom

ic

environment,

also

affected

by

the

coronavirus,

generated

an

i

nflationary

acc

eleration,

a

decline

in

private

c

onsumption

and

in

the

GDP,

which had a considera

ble impact on the p

erformance of th

is industry.

This

performanc

e

is

mostly

accounted

for

by

the

sens

itivity

of

Argentine

me

dia

c

ompa

ni

es’

revenu

e

structure to

the

economic

cycles.

In this

sense,

even t

hough t

hey contin

ue to

grow,

media

companies

’

advertising revenues are

s

till especially sensitive

to recessive cycles due

to

the

moderate

develo

pment

still shown by paid subs

cription mode

ls in the

domestic mark

et.

8

This shows that tra

ditional

media need to co

ntinue inn

ovating, creating

new and better

digital prod

ucts

and

services

that will

allow them

to achieve sustainable

business models in

an increasingly competitive

environment.

To

such

end,

they

need

to

find

a

mo

del

to

efficiently

monetize

digital

advertising

and

subscriptions, exploiting the consumption of contents via mobile devices without be

coming invasive for

the user.

Notwithstanding

the

foregoing,

consum

er

habits

go i

n t

he s

am

e

direction

as

in t

he

rest

of

the world

, in

turn

boosted

by

th

e

effects

of

the

quarantine

and

th

e

n

ew

form

of

te

leworking.

In

th

e

audiovisual

segment,

the

h

ighlights

were

a

s

light

drop

in

HUT

(households

usin

g

tel

evision)

an

d

the

growt

h

or

consolidation

of

various

OT

Ts

or

video

s

treaming

platforms

in

addition

to the

consu

mption

of

home

data

for video call tools.

In

the

newspaper

segment,

according

to

PWC,

in

2021

printed

newsp

aper

circulation

revenues

were

stable after

falling

at a

rate

of

about 1

8%

in 2020

, without t

hese rev

enues be

ing fully

capitalized

in

the

digital ecos

ystem

where

they

(advertising

and

dig

ital subs

criptions)

grew

by

around

8%

with

a s

till low

income

base.

This is

mai

nly

due

to the

relatively low

level

of maturation

o

f

the ma

rk

et

related to the

paid

digital

news

subscription

system.

However,

mor

e

and

more

local

media

are

deciding

to

move

toward

such a model as the exc

lusive advertisin

g model does

not seem to be sustai

nable.

According

to

Kantar

IBOPE,

traditional ra

dio

listeners

have

a w

eekly

reach

of

almost

60%

w

hile

there

was

a growth

in

digital

user

s

(18%

of reach),

in

additio

n to

the

growing

pheno

menon

of po

dcasting.

In

this

way,

the

radio

segment

is

managing

to

c

onsolidat

e

as

a

multiplatform

medium

that

re

aches

new

generations.

Thus, the challenges faced by the local industry do not di

ffer from those seen in companies around the

world,

exc

ept

for

the

complex

macroecon

omic

envir

onment.

T

he

w

illingness

of

society

t

o

pay

for

Internet

content

under

this

economic

environme

nt

ap

pears

to

be

one

of

the

c

ritical

challenges.

The

media

companies

t

hat

achieve

th

e

most

succ

essful

innovations

and bra

nds

that

add

v

alue

will

have

a

head start in the race t

o reach the user wit

h the possibility o

f building loyalty.

3.4.

REGULAT

ORY FRAM

EWORK 2021

The

lat

est

substantial

changes

in

legislation

were

introduced

in

December

2015

under

Decr

ee

No.

267/2015, which amen

ded Laws Nos. 2

6,522 and 27,078 (“Au

diovisual Commu

nication Serv

ices Law”

and “Digital Argentina

Law” respective

ly).

Upon

the issuance

of

Decrees Nos.

7/2

019

an

d

50

/2019,

published

in

the

O

fficial

Gazette

on

December

11, 2019

and

on Dece

mber

19, 20

19, respect

ively,

the ENACO

M

—

the Enf

orcement

Authority

of bot

h

Decrees

—

is

now

under

th

e

jurisdiction

of

the

Secretariat

of

Pu

blic

Innovation

und

er

the

Chief

of

the

Cabinet of Ministers.

The

subsidiaries

of

the

Company

hold

license

s

and

registrations

and

exploit

Audiov

isual

Communication

S

ervices

(Television,

Radio,

Cable

Televisi

on

Signa

ls,

Producers

and

Advert

ising

Agencies),

and

are

govern

ed

by

the

Audiovisual

Communication

Services

L

aw.

Currently,

the

on

ly

subsidiary

partially

gov

erned

by

the

Digital

Argent

ina

Law

is

Gestión

Compartida,

as

a

resu

lt

of

the

merger

by

acquisition

executed

with

Compañía

de

Medios

Digitales

(CMD)

S.A.

(“CMD”),

holde

r

of

a

Telecommunications

License.

All

the

subsidiaries

of

the

Company,

owners

of

licenses

for

th

e

exploitation

of

Aud

iovisual

Communication Serv

ices hav

e obtained an

extension of the t

erms of t

heir licenses

, for the exploit

ation

of

bro

adcast

television

and

AM

a

nd

F

M

sound

broadcasting

s

ervices.

All

t

he

licensees

were

deemed

to have opted to

request an

extension under

Article 20 of Decr

ee No. 267/1

5, and wer

e granted a ne

w

term

for

the

first

period

of

TEN

(

10)

y

ears,

wi

th

the

right

to

an

a

utomatic

extensio

n

for

a

term

of

F

IVE

(5) more years, in ev

ery case.

9

In

connecti

on

with

d

igital

t

elevision,

all

the

s

ubsidiaries

that

hold

broadcast

telev

ision

lic

enses

wer

e

awarded a digital ch

annel to render terrestr

ial digital television serv

ices.

Notwithstanding

the

foreg

oing,

Artear

filed

i

n

due

t

ime

an

unconstitutiona

lity

claim

requesting

the

revision

of

the

legal

regim

e

ap

plicable

t

o

th

e

trans

ition

to

digital

t

elevision

in

the

understanding

that,

through

its application,

t

he

rights of

the current

broadcast tel

ev

is

ion

licensees could

be infringed.

These

rights should be preserv

ed intact as estab

lished in Law No. 2

6,522, which has h

igher hierarchy.

Although Decree No.

173/2

019 provided

for the postponement of

the due date

for the analog

switch

-off

until

August 2021, it

has not been

implemented yet,

so our

Manageme

nt i

s focused on

restructuring

the

schedule for the trans

ition to digital tel

evision.

Significant changes in th

e legal framework of

ICT Services

o

Decree No. 690/20

–

Amendmen

ts to the LAD

On A

ugust 22, 2020,

the National Executive

Branch amended the

Digital

Argent

ina Act

throu

gh Decree

No. 690/2020, which w

as subsequent

ly ratified by Parliam

ent under the terms o

f Law No. 26,122

.

Within the

a

mendments

introduced,

ICT

serv

ices

–

fixed

and m

obile tele

phony,

s

ubscription

television

and

Internet

–

a

nd

the

ac

cess

to

teleco

mmunications

netw

orks

for

a

nd

between

lice

nsees

are

n

ow

deemed

“ess

ential

an

d

strateg

ic

public

services

provi

ded

on

a

competitive

basis

”,

and

their

eff

ective

availability shall be guara

nteed b

y ENACOM.

The prices of

essential

and strategic

public ICT

services

provided on

a competit

ive basis,

the prices of

the

s

ervices

provi

ded

under

the

Univers

al

Service

and

of

t

hose

deter

mined

by

ENACO

M

based

on

reasons of public interes

t, shall be regulated

by

said agency.

The

Decree

also

provides

that

E

NACOM

shall

establish,

in

the

r

espective

regulations,

the

Mandatory

Universal Basic Provis

ion of ICT serv

ices.

On

December

21,

2020,

R

esolutions

Nos.

1466/2020

and

1467/2020

w

ere

publis

hed

in

the

O

fficial

Gazette, whereby the

ENACOM regu

lated Decree No.

690/2020.

Resolution

No.

1467/202

0

regulates

the

Mandatory

Univers

al

B

asic

Service

set

forth

by

Dec

ree

N

o.

690/

2020

for

the

differen

t

services

provided

by

ICT

Services

L

icensees,

establ

ishing

the

price

and

characteristics of

each plan. Said Resolution

also sets out

t

he persons that

are eligible to

rece

ive those

services.

It

should

be

not

ed

that

su

bscription

telev

is

ion

service

licens

ees

are

under

the

obligation

to

apply

discounts

to

a

plan

and

programming

grid

that

alrea

dy

exist,

which

t

hem

from

creat

ing

a

specific and less expe

nsive grid to com

ply with the Mandat

ory Universal B

asic Serv

ice.

Since

the

subs

idiary

Art

ear

owns

s

everal

cable

tv

signals

and

is

therefore

a

pro

vider

of

conte

nts

to

subscription

television

serv

ices

via

phys

ical,

radio

-

electric

or

sate

llite

link,

it

is

c

urrently

evaluatin

g t

he

impact that this regulat

ion and its impleme

ntation will h

ave on its operations.

Large

o

perators

of

the

S

ubscription

Television

Service

have

brought

legal

actions

aga

inst

the

aforementioned

resolutions,

grounded

on

the

unco

nstitutionality

of

those

regulations,

and

obta

ined

different injunctions that

provided for t

he suspension o

f the application of

the challenged reg

ulations.

o

New

Genera

l

Rules

Governing

Physical

and/or

Radio

Electric

Link

Subscription

Broadcasting

Services

10

ENACOM Reso

lution No.

1,491/2020

issued on

December 24

, 2020

approved th

e new Gen

eral Ru

les

Governing Physical R

adio-

Electric and/or S

atellite Link

Subscription Broadcasti

ng Services.

Even though the new Gene

ral Rules maintain the oner

osity of all the broadcast television serv

ices and

signals that

fall w

ithin the s

cope of

the “m

ust carr

y” re

gime (signals a

nd services

s

ubject to ma

ndatory

retransmission) by

the pr

oviders of s

ubscription

television serv

ices, they

introduce

the concept

of “fair,

equitable and

re

asonable price” and

implement a

dispute resolution procedure i

n case of

disagree

ment

between signal

holders

and

distributors

(by

physical, radio

-electric or satellite link)

to be

brought before

the

ENACOM,

w

hereby

the

p

arties

are

d

eemed

to

h

ave

voluntarily

accepted

t

o

b

e

s

ubject

to

t

his

procedure.

In a

ddition,

the

Ge

neral

Rules

pr

ovide

th

at

in

t

he

event

that

s

ignal

holders

an

d

phys

ical, ra

dio

-electr

ic

and/or satellite

link subscription television

l

icensees do no

t settle

their dispute,

distributors

shall

inc

lude

the

s

ignal

in

the

progra

mming

grid

at

the

price

s

et

by

ENACOM’s

Board

based

on

the

information

gathered during the proce

eding.

It

should be

noted

that

both

the

price

and

the settlement

procedure is

ap

plicable

to any

signal, including

those which are not s

ubject to mandatory

retransmissi

on.

In

add

ition,

t

he

General

Rules

also

prov

id

e

that

t

he

commercializatio

n

of

on

e

signal

may

not

be

conditional

on

the

acquisition

of

other

s

ignals

and,

in

the

case

o

f

sales

of

signal

packages,

the

pr

ice

must include a breakd

own of the price of e

ach of the signals inc

luded in the pack

age.

ARTEAR’s

le

gal

advisors

believe

that

the

ENACOM

is

not

empowered

to

s

et

the

price

of

a

signal,

regardless

of

wh

ether

or

n

ot

it

is

a

signa

l

s

ubject

to

mand

atory

retransmiss

ion,

and

that

it

would

be

arbitrary

an

d

unc

onstitutional

i

f

th

e

agency

imposed

a

price

on

the

ow

ner

of

con

tents

that

does

not

voluntarily agree to the set

tlement proceedi

ng.

4.

THE COMPANY

. ORIGIN, EVOLU

TION AND PROFILE

4.1.

CO

MPANY PROFILE

Grupo Clarín is Argentina's most prominent and diversified media group and one of the most important

in

t

he S

panish-s

peaking world.

The Company

is

organiz

ed

and

operates in

Argentina

and its

contro

lling

shareholders

an

d

manage

ment

are

Argentine.

Grupo

Clar

ín

is

present

in

th

e

Argent

ine

print

media,

radio,

broadcast

television,

audiovisual

production,

and

in

t

he

printing

i

ndustry.

Substantially

all

of

Grupo C

larín's

assets,

oper

ations

and

audiences

are

located

in

Argentina

, wh

ere

it

generates

m

ost

of

its

rev

enues.

The

Compan

y

also

carries

out

operatio

ns

at

the

r

egional

level.

T

oday,

G

rupo

Clarín

employs almost 5,00

0 people.

Grupo

Clarín's

h

istory

dates

back

to

1945,

the

year

in

which

Robert

o

No

ble

founded

the

n

ewspaper

Clarín

of

Buenos

Aires

(“Diario

Clarín”),

w

ith

the

goal

of

becomi

ng

a

mass

dis

tribution

and

quality

newspaper,

privileging

infor

mation

and

committing

to

the

co

mprehensive

development

of

the

country.

Between 19

69 and

2017, D

iario Cl

arín was

led by

his

wife,

Ernestina Herr

era de

Noble.

It beca

me

the

flagship nation

al newsp

aper and h

as consol

idated its

position thr

oughout

the y

ears

thanks to th

e work

of

its

journal

ists

and

the

loy

alty

of

its

r

eaders.

Di

ario

Clarín

is

now

one

of

the

Spanish

-language

newspapers

with

the

highes

t

circ

ulation

in

the

wo

rld.

I

n

2

016,

Diario

Clarín

beca

me

t

he

most

widely

read digital newspaper in th

e Spanish-spe

aking world and, dur

ing 2019, it received a record high of 22

million

unique

users

durin

g

December,

wh

ich w

as

subseque

ntly

exceeded

in

202

0

during

the

COVID

-

19

pa

ndemic.

Over

the years,

Grupo

Clarín has

been one

of the

main

actors in

the changes

undergone

by

the

m

edia

worldwide.

It

incorpora

ted

new

and

varied

printing

activiti

es

and

decided

to

embrace

technological development

s, investing to reach its audiences thro

ugh new platforms and channels and

through new audiov

isual and digital

languages.

11

In th

is way

,

Grupo

Clarín

e

ntered

the

radio

an

d te

levision

sectors.

Tod

ay,

it

is t

he

owner

of

on

e of

the

two leading br

oadcast te

levision ch

annels in

Argentina

(Artear/ elt

rece) and of

AM/FM

broadcast rad

io

stations.

Along

w

ith

the

ne

wspaper,

these

media

are

recognized

as the

most

credible

a

nd

considered

leaders

of

Argentine

journa

lism

in

one

of

the

most

divers

e

media

m

arkets

in the

r

egion.

For

example,

in Buenos Aires, the

Company's med

ia compete in a mark

et that has 5 broadcas

t television stations, 6

news signals, 550 rad

io stations, and more tha

n 10 nat

ional newspapers.

Grupo Clarí

n

also p

ublishes

Olé,

the first

and

only

spor

ts

newspaper in

Arge

ntina,

and the

magaz

ines

Ñ, Genios, Jardín de G

enios, Pymes

, and El

le. Through CIMECO, t

he Company h

olds equity interests

in

the

newspapers

La

Voz

del

Interior

and

Los

Andes,

in

a

m

arket

of

appr

oximately

200

regional

an

d

local

newspa

pers.

In

the

audi

ovisual

fr

ont,

it

also

produces

5

cable

signals.

A

news

signal,

(Tod

o

Noticias),

an

d

the

signals

Volver,

M

agazine,

Q

uiero

Música

en

mi

Id

ioma

,

and

Can

al

(á).

It

also

produces

s

ports

channels and

events

(TyC S

ports

),

te

levision

contents and

motion pictures

(Po

l

-k

a

and

Patagonik Film Gro

up).

In line

with the

global tre

nd, Gr

upo Clarín h

as comm

itted itse

lf to

expanding d

igital

content prod

uction.

Grupo Clarín's Internet port

als and sites receive more than half of the visits to Argentine webs

ites. The

Group's

digita

l

media

are

b

enchmarks

of

journalistic

quality

and

h

ave

high

c

redibility

rat

es.

Its

social

media accounts have

the largest number

of followers and ge

nerate

significant

inter

action. Over

the last

years,

the

Group’s

media

and

journa

lists

have

r

eceived

ma

ny

awards

for

the

ir

ventures

in

differ

ent

digital

platforms.

In

2016

and

2017,

at

the

WAN

-IFRA

LATAM

D

igital

Media

Awards

,

Grupo

Cl

arín's

media received

three awards

each year,

and, in

2018, Diario

Clarín receiv

ed an

award for

its

subscription

s

trategy.

In

2019,

Clarín

rec

eived

awards

gran

ted

by

ADEPA

in

the

c

ategories

“

Human

Rights”,

“Phot

ography”,

“

General

Inf

ormation

and

Ent

ertainment”,

“Infographics”

,

and

“Eco

nomy”.

In

addition, FOPE

A granted

an

award to

Clarín

in the

category

“National

Print Media

” for

the coverag

e of

the

sexua

l

a

buses

that

to

ok place

at Próvolo

Institute’s summer camp

and the Society

for News

Design

granted

to the

news

paper

the

award

“Special

News

Topics

Editor’s

Choice”

for

t

he s

ports

section wi

th

the

c

overage

of

the

FIFA

World

Cup

held

in

Russia.

It

also

receive

d

many

aw

ards

from

the

Inter

-

American

Press

Assoc

iation

(IAP

A),

the

Association

of

Argentin

e

Journa

listic

Entiti

es

and

o

ther

natio

nal

and internat

ional agenc

ies. In

2020, Clarí

n rece

ived 10

ADEPA

Awards

and

Special M

entions, am

ong

which

the

most

rel

evant

was

a

series

of

articles

covering

the

COVID-19

pande

mic.

It

als

o

received

a

FOPEA award for

an article on the Govern

ment’s social spen

ding. In the Comm

unicator Awards of t

he

Academy

of

Int

eractive

&

Visual

Arts

(AIVA),

Clarín

received

two

awards

in

the

“Doc

umentary”

and

“Videography”

categories.

In

addit

ion,

the

Internation

al

Women’s

Forum

recogn

ized

Silvia

F

esquet,

Editor-

in

-

C

hief of

Clarí

n, for her work

and track record. She was recognized as one

of the “women who

made a difference in 2020”. Finally, it re

ceived

a ÑH bronze award in Spain. In 2021, Clarín received 7

ADEPA

Awards,

2

recogn

itions

at

t

he

Lola

Mor

a

Awards,

and

3

Eikon

Awards

to

Communication.

La

Voz

received

4

ADEPA

Aw

ards,

1

FOPEA

Award,

3

Eikon

Córdoba

Awards,

a

nd

1

Gabo

Foundation

Award.

TN

rece

ived

three

Marti

n

Fierro

de

Ca

ble

aw

ards.

Los

Andes,

El

Doce,

and

TyC

S

ports

also

received several awards

.

In 19

99, Gru

po

Clarín

was

incorporated

as an

Argentine

s

ociedad

anónima

,

a cor

poration w

ith

limited

liability. It

gradu

ally

opened

its

capital

to other

partici

pants

and, s

ince

October

200

7, it

has

been

listed

on

th

e

Buenos

A

ires

Stock

Exc

hange

and

on

the

London

Stock

Exchange.

It

ta

kes

pride

in

having

grown

in

Arg

entina,

i

n

bei

ng

a

source

of

influenc

e

a

t

the

loc

al

leve

l

in

an

increasing

ly

transn

a

tional

market with a size

that ena

bles it to

compete withou

t losing strength among large international players.

Grupo Clarín's i

nvestm

ents in

Argentina in

the last 20

y

ears have be

en very significant, always

with the

same

central

focus:

Journalism,

the

m

edia,

prod

uction

and

distri

bution

of

c

ontents

and

communic

ations.

Its

ac

tivities

have

c

ontributed

to

t

he

cr

eation

of

a

n

important

Ar

gentine

cultural

industry

and

generate

qualified

a

nd

gen

uine

em

ployment.

Its

vision

and

business

m

odel

focus

on investing,

p

roducing,

informing,

an

d

entertaini

ng,

pres

erving

Argen

tine

values

and

identity,

and

preserv

ing

business

independence in ord

er to ensure j

ournalistic independenc

e.

12

In

addition,

s

ince

its

foundation,

Grupo

Clarín

has

u

ndertaken

inte

nse

commu

nity

activitie

s.

Gr

upo

Clarín,

together

with Fundación Noble,

w

hich

was

established

in 1966,

organizes and

s

ponsors

sever

al

programs and

ac

tivities, particularly focused

on education, culture, and

civic involvement. Furthermore,

as

an

indication of

its

corpor

ate

social

respons

ibility,

Grupo

C

larín

foc

uses on

the ongoing

improve

ment

of its process

es, deve

lops initiatives

that arise

from dis

cussions

with different

stakeho

lders, and wor

ks

towards sustainabi

lity and diversity.

4.2.

GRUPO CL

ARÍN AND

ITS BUSINESS

SEGMENTS IN

2021

The

econom

ic

recovery

of

202

1

due

to

the

gra

dual

e

asing

of

much

of

t

he

health

restrictions

implemented

in

2020,

even

in

a

context

of

high

inf

lation

and

high

uncerta

inty,

had

an

i

mpact

o

n

the

advertising

mark

et

a

nd

on

Grupo

Clarí

n’s

reve

nues,

e

specially

in th

e

Broadcasting

and

Programming

segment.

In this context,

the Group's

net consolid

ated sales re

ached $40,1

49.3 million, 0.

2% below t

he $40,21

0

million recorded

in 2

020 in

const

ant currency

as of

De

cember 31,

2021; w

hile EBI

TDA grew

by

27.4%

to $6,239.9 million in

constant currency

as of Decemb

er 31, 2021.

By the end of 2021, Grupo Clarín's consolidated gros

s financial indebtedness

(including sellers

financing, accrued

interest and fair

v

alue adjustments) stood

at approximately $1,690.8 million,

and the

cash position at year

-end stood at $

4,284 million.

The following is a description of the

most significant events related to the situation and management of

each of Grupo Clarí

n's business s

egments during 20

21.

4.2.1.

PRINT AND DIGITAL

PUBLICATION

S

Grupo

Clarín,

through

AGEA,

is

the

main

newspaper

publisher

in

Argent

ina

and

one

of

the

most

prominent editoria

l content producers i

n Latin America.

Arte Gráfico Edito

rial Argentino

Arte

Gráfico

Editor

ial

Argentino

S.A.

(

AGEA)

p

ublishes

two

national

new

sp

apers.

In

the

first

place,

AGEA

publishes

Clarín

,

the

flagship

Argentine

newsp

aper

and

one

of

t

he

most

important

in

t

erms

of

circulation

in

th

e

S

panish-

speaking

wor

ld.

It

also

publishes

Olé

,

fo

unded

in

1996,

the

first

a

nd

only

sports

newspaper

of

its

ki

nd

in

the

Argent

ine

m

arket.

In

addition,

i

t

publishes

regional

newsp

apers;

Genios, a very popular magazine among schoolchildre

n; Jardín de Genios, aimed at children

aged 2-

5

that

co

mes

w

ith

a

s

upplement

for

parents;

Ñ, a

cultural maga

z

ine;

Py

mes,

aimed

at

s

mall-

and medium-

sized

bus

inesses;

a

nd

ARQ,

aimed

at

the

c

onstruction world,

architects an

d

design

ers.

It

also

publishes

the

Argentine

v

ersion

of

the

wom

en’s

magazine

Elle

and,

since

June

2020,

the

magazine

Disney

Preescolar, which inc

ludes educational

prop

osals for learning to r

ead and write.

AGEA

has

a

strong

prese

nce

in

t

he

digital

content

segment

through

its

webs

ites

clarin.com

a

nd

ole.com.ar,

wh

ich

are

among

the

most

visited

websites

in

Lat

in

Americ

a.

It

s

tands

out

in

vertical

sites

of sectors such as c

ars, real estate a

nd jobs.

Clarín

With

a

lon

g-standing

journ

alistic

a

nd

co

mmercial

leaders

hip

cons

olidated

in

its

7

5

-year

track

record

,

Clarín

is

the

mos

t

prominent

Argentine news

paper

in

terms of

o

utreach

to

its rea

ders,

circul

ation,

and

advertising.

The

success

of

its

prestigio

us

editor

ial

line

lies

in

its

ide

ntification

with

the

i

nterests,

ne

eds

and

emotions

of its audience through

a plural and in

dependent journ

alistic style.

13

With

innovation

at

the

core

,

Clarín

has

a

mu

lti-p

latform

newsr

oom

that

work

s

simultaneously

for

th

e

different

versions

of

the

newspaper

-paper,

mobile

and

d

igital-.

In

this

aro

und-the-clo

ck

news

produc

tion

process,

all

the

journalists

work

for

all

the

platforms

in

order

to

maintain

the

Com

pany’s

lead

ership

in

the print and digital mark

et and, at the sam

e time, boo

st its web and mobile serv

ices.

An

Arg

entine

leader

in

term

s

of

digital

subscr

ibers

and

registered

users

(the

two

mo

st

relevant

indicators

in

the

wor

ld's

leading

news

papers,

with

readers

that

are

high

ly

loyal

to

the

brand

and

its

journ

alistic

quality),

despite having

a paywall,

Clarín

also occupies

a

prominent place

in

terms of

un

ique users.

The

newspaper

seeks

to

cont

inue

expanding

th

is

base

with

readers

of

all

ag

es

and

different

rea

ding

frequencies and, at the same time, i

t seeks to offer original contents for the

most frequent readers that,

given

t

heir

periodicity,

choos

e

to

bec

ome

digital

sub

scribers.

The

quality,

flexib

ility,

im

mediacy,

and

close bond with the read

ers are the key pi

llars to face th

es

e new challenges

.

VIVA,

the

magaz

ine

which

has

com

e

f

or

free

w

ith

th

e

Sunday

newspaper

for

26

years,

is

n

oted

for

a

strong

represen

tation

of

Argentine

p

eople,

t

hrough

it

s

articles

and

co

ntents

th

at

reflect

t

he

soc

ial

phenomena and the c

urrent issues.

During

2

021,

Clarín

was

once

a

gain

one

of

th

e

m

ost

awarded

newspapers

in

th

e

country.

It

received

several

ADEPA

Awards:

Nata

lia

Iocc

o

r

eceived

the

most

importa

nt

award

in

the

category

Ju

dicial

Journalism.

Fe

derico

Mayol

an

d

Ignac

io

Ortelli,

in

the

category

Politica

l

Journal

ism.

Héc

tor

Hu

ergo,

Mauricio

Bartoli

and

Juan

B.

Raggio,

in th

e

category

Economy.

Rocío

Magna

ni r

eceived

the

first

prize

in

the

category Mu

ltimedia and

th

e

sec

ond

pr

ize

in

t

he

category

Investigative

Jour

nalism.

Marin

a

Zuc

chi

was ranked s

econd

in

the c

ategory G

eneral Informa

tion and

Entertainmen

t. Her

nán Sartor

i receive

d a

special

m

ention

in

the

category

Sports.

Paula

Cond

e

receive

d

a

special

ment

ion

in

the

category

Multimedia. In

addition, Lucía

Mer

le, ph

oto editor, received

the photojourn

alism award at

t

he Lola

Mora

Awards, a

nd Mar

iana

Iglesias

was

recognized

for

her

role

as

Gender

Editor.

Clarín

journalist

Gabri

ela

Samela

r

eceived

the

Accenture

Aw

ard

in

the

category

Innovatio

n

and

Inc

lusion.

Finally,

Clarín's

75

-

year campaign receive

d 3 Eikon Aw

ards to Commun

ication.

As

of

Dece

mber

20

21,

Cla

rín

exceeded

430,000

pay

digital

s

ubscriptions,

with

more

tha

n

4,000,0

00

registered

us

ers.

In

its

printed

edition,

C

larín's

sales

in

2021

exc

eeded

its

direct

competitor

by

43%,

with

weekend

editions

close

to

200

tho

usand

copies

.

This

places

Cl

arín

among

the

major

Sunday

newspapers

of

the w

orld. C

larín

has

a

49% s

hare i

n th

e news

paper

market

in

Capital

Federal

and

the

province of Buenos A

ires, and a 28% sh

are at the national leve

l.

The

Zepita

facility

-where

t

he

newspaper

Clarín

and

its

s

ections,

as

well

as

the

newspaper

Olé

an

d

those of other com

petitors are pri

nted- is loca

ted in the City of B

uenos Aires and

has a surface area

of

35,000

m2

and

capacity

to

store

12,

000

tons

of

newsprint.

It

has

five

Gos

s

Metrocolor

rotary

offset

printing

pres

ses

that

enab

le

it

to

print

300,000

copies

of

80

full

-c

olor

pages

per

hour.

AGL's

printing

facility,

located

in

the

province

of

Santa

F

e,

has

a

s

urface

area

of

3,900

m2

and

has

a

G

oss

Uniliner

rotary

offset

pr

inting

p

ress

which

enables

it

to

print

75,000

cop

ies

per

hour.

The

entire

production

process i

s de

veloped in

accordance with

leading industrial

criteri

a

an

d

environment

preservation

standards, such as, I

SO 14001.

Clarín

365

is

a

readers

club

created

in

2010

to

bui

ld

loyalty

among

r

eaders

and

to

reinforce

its

close

bond with

them, as well

as to strengthen

circu

lation. It

was created exclusively for

Clarín's publications,

but,

eventu

ally, it

w

as adopted

by other

newspapers and magazines i

n the

country

. Currentl

y, the

re are

over

30

editoria

l

pro

ducts

th

at

offer access

to

the Clarín

365

or

Clarí

n

36

5

Plus

card

s.

The

sys

tem

offers

more than 800 brands

and 6,000 loc

ations throughout the cou

ntry.

In 20

21,

365

remained

the

leading

benefits

cl

ub

and

continued

its

part

nership

w

ith

the

e-wallet

BIMO,

through which ne

w users of

the app

were able to

use the benefits

of 365, at

no

cost

for

a

limited

period.

During the last ye

ar, 365 continued

to focus on c

orporate agreem

ents and we

signed a

greements with

companies and govern

ment age

ncies that contrib

uted around 60

,000 new subscr

ibers.

Since

2019,

Clarín

has

had

a

G

ender

Editor

to

ensu

re

a

gender

perspective

i

n

all

the

areas

of

th

e

newspaper. The decision, whi

ch

i

s being adopted in

several

of

the leading newspapers worldwide, is

in

14

line

with the

deman

d

of audiences

that look for

an

d

des

erve info

r

mation and

s

tories

adapted to

the new

times. Clarín was a p

ioneer among t

he Argentine med

ia in adopting these

measures.

Products

The

core

offering

of

the

newspaper

co

mprises

the

main

sect

ions

(pol

itics,

econo

my,

society)

together

with

t

he

Spot,

S

ports,

and

Classified

ads

sections

.

Weekly

supple

ments

(such

as

,

Economic,

Rural,

Cars,

Traveling,

Re

al

Estate

and

The

New

York

Times)

make

Diario

Clarín

one

of

the

most

comprehensive newsp

apers in the m

arket.

The regional supplements

extend the spec

ific territorial coverage

to the surround

ing area of the

City of

Buenos

Aires.

In

digital

and

paper

f

ormats,

through

t

hree

publications:

North,

South,

and

West.

The

former

covers

San

Is

idro,

Vicente

Lopez,

San

Mart

in

,

Tigre,

San

Fern

ando,

Malvinas

Argentinas,

Escobar,

and

Pilar.

T

he

s

econd

cov

ers

Lanús,

Avell

aneda,

Quilmes,

Lo

mas

de

Zamora,

Almirante

Brown,

Esteban

Echeverría, E

ze

iza,

F

lorencia Varela,

an

d

Berazategui. And

the third

covers La

Matanza,

Morón,

Ituzaingó

,

Hurlingh

am,

Merlo,

Moreno,

Tres

de

Fe

brero,

Jose

C

.

Paz,

and

San

Mig

uel.

Spot provides th

e reader w

ith informat

ion on ent

ertainment, tre

nds, and

culture, a

ll in one

place. It is

a

supplement that off

ers interviews to

promine

nt

cultura

l figures

and news about show

business

,

film and

theater premieres, fas

hion, and gastronomy

.

Diario Clarín

’s Ec

onomic

Section off

ers its

readers

a t

horough

analysis of

the

economy,

the

secrets

of

leading c

ompanies,

personal

finances,

mark

eting an

d l

abor mark

et w

ith v

aluable

i

nformation,

easy-

to

-

read texts, and the

opinion of nationa

l and international presti

gious columnists.

In

2021,

t

he

Sports

section

r

egained

pr

ominence

b

ecause

of

the

e

asing

of

the

sa

nitary

measures,

which

allowed

the

return

of

the

professional

sp

orts.

There

was

a

special

coverage

of

the

most

relevant

international

sports

events

of

the

y

ear,

such

as

the

America

Cu

p,

the

Toky

o

Olympic

Games,

and

the

circuit's most importan

t Tennis Opens.

The Rural section is a management tool for the productive sector. It con

tributes

to the dissemination of

all

the

soluti

ons

and

u

pdating

on

new

technologi

es

for

agric

ultural

business

es.

It

is a

source

of

reference

for the diverse top

ics that are releva

nt to the agricultural

industry in Argentina.

Magazines

Since

200

3,

the

magazine Ñ

-

both

in

the

printed an

d

digital

formats -

has

feature

d

t

he

main

expressi

ons

of literature, thought

and cultural ph

enomena of Ar

gentina and the world.

The

m

agazine

Ñ

se

eks

to

enrich

debates,

generate

dis

cussions,

and

pro

pose

innovative

approaches

to

un

derstand

and

apprec

iate

th

e

m

anifestations

of

h

umankind

in

al

l

f

ields.

In

additio

n,

it

features

the

most prominent editori

al offerings and the

main cultural activ

ities in Buenos Aires

and in Argentina.

Through

Premio

C

larín

Novela

,

Magazine

Ñ

promotes

the

production

and

publishing

of

liter

ary

fiction

in

Spanish

langu

age.

In

20

21,

the

24

th

edition

was

he

ld.

It

is

a

s

ymbol

of

s

upport

for

culture

that

is

renewed

every

year,

discovering

authors

and

putting

them

in

contact

with

read

ers.

This

award

has

become

one o

f

the m

ost po

pular

literary

contests

in

Spanish

and

is

a

meeting

place

for

young

writers,

acclaimed

au

thors,

and

readers.

In

this

edition,

Agustina

Car

ide

receive

d

an

award

for

her

novel

“

Donde

retumba el silencio

”.

Since

2002,

Cl

arín

has

been

a

n

ind

isputable

source

of

reference

in

the

worl

d

of

arc

hitecture,

desig

n

and

cons

truction.

It

pu

blishes

ARQ

-

b

oth

in

prin

ted

and

d

igital

for

mats

-

a

prod

uct

of

excellenc

e

for

architecture and

design

professionals

and stude

nts. Periodic

ally, it publ

ishes the

spe

cial editions M

AS

ARQ

and

D

NI,

together

with

the

magazine.

MAS

ARQ

contains

a

selection

of

w

orks

from

around

the

world.

Dur

ing

2021,

it

publis

hed:

Amp

liaciones

y

R

eformas,

C

asas

d

e

Autor

y

Bares

,

and

Restaura

ntes.

DNI

is

a

pu

blication

referri

ng

specificall

y

to

national

and

international

design

in

all

its

forms.

I

n

April

2021,

ARQ

DNI

published

a

special

e

dition

com

memorating

t

he

Internati

onal

Day

of

Graphic

Desi

gn

which

came

with

a

wo

oden

stand

for

m

obile

d

evices

as

a

gift

for

its

re

aders.

In

August,

it

pub

lished

a

15

special

edition

about

t

he

Seal

of

Goo

d

Design

and,

in

Nove

mber,

about

the

200

y

ear

-anniversary

of

Universidad de Bue

nos Aires.

Revista E

LLE

is

a

high-en

d

magazine

for

women,

focu

sed

on f

ashion

and

beauty.

It

was

incorporate

d

into

AGE

A's

pro

duct

p

ortfolio

in

1994.

D

uring

2020,

ELLE

offered

the

products

E

LLE

Decor

ación

a

nd

ELLE C

ocina,

which

wer

e

published

twice

durin

g th

e

year,

with

a

website:

elle.c

om.ar,

which

al

lowed,

together with its socia

l media (Instagram/F

acebook), to r

each the

audience

24/7.

Genios

is

a

week

ly

c

hildren's

magazine

that

s

eeks

to

educate

a

nd

entertain,

with

a

c

lear

and

current

language

for

c

hildren.

During

the

year,

it

re

ached

an

average

sale

of

10,700

c

opies;

reaching

an

average of 38,000

copies in its 2 editions

of “Back

to School”. The monthly edition

of Jardín de Genios,

a

magazine targeted

at little

c

hildren,

maintaine

d

its

leadership in

the category

c

hildren's magazine

wi

th

over 18,000 copies s

old.

In June

2020, the monthly Disney Pre-School magazine was launched. It i

s a product with

an attractive

format that offers educational materials to

easily learn how to read and write

with a funny approach. To

boost

sales

in

2021,

the

m

agazine

launch

ed

special

editions

with

gadge

ts,

achi

eving

average

sales

during the year of 10

,000 copies.

Pymes is

a

monthly

publication

with

national

reach,

published s

ince 200

4, ai

med

at contr

ibuting to

the

development

an

d

consol

idation

of

s

mall

bus

inesses,

wit

h

special

em

phasis

o

n

the

entrepreneuri

al

wor

ld

and

the

so-

called

“startup”

or

“high

i

mpact”

entrepre

neurs.

In

2021, the

magazine

delivered

3 e

ditions

with

books;

in

F

ebruary

“

S

ustentabilidad

para

Pymes

”

by

Lucas

Utrera

(February

2021),

in

April

“De

hijos a

líderes” by Martín

Quiros and

“

Ahora me

toca a mí

” by

M

ónica Román, and i

n July “

Transformar

la Pyme

” by Santiago

Lazzatti.

Olé

Olé is

the first and only sports newspaper in

Argentina,

both

on the web and in

prin

ted format. Since its

launch in

1

996, it

has been an

Argentine benchmark in sports

information. Its

editor

ial offering

provides

the

most

comprehens

ive

a

nd

com

plete

cov

erage

of

footbal

l

and

other

sports

l

ike

tennis,

bask

etball,

rugby, and motor raci

ng.

The easi

ng o

f he

alth

restrictions

during

2021

allowe

d t

he r

eturn

of a

ll n

ational

and

international

sports

competitions,

after

the

sus

pensions

t

hat

had

bee

n

ordered

in

the

year.

In

this

way,

Olé

resumed

its

qua

lity

c

overage

of

the

main

s

porting

events

in

the

c

ountry

and

the

world,

s

uch

as

t

he

America

Cup

in

Brazil,

the

Olympic

Games

in

Tokyo,

Messi’s

transfer

to

PSG,

among

ma

ny

others

.

It

launched several sp

ecial projects

.

In

addition,

i

n

2021,

O

lé

celebrated

its

25

-year

a

nniversary

w

ith

actions

in

all

platforms

w

ith

extraordinary

results

an

d

globa

l

impact.

Som

e

of

the

mos

t

relevant

events

of

the

ye

ar

were

the

ex

clusi

ve

interview

wit

h

Li

onel

Mess

i

(translated

into

English

and

Chinese),

the

spec

ial

an

niversary

edition

w

ith

more

than 100

pages, the advertising

campaign in

hom

age

to the users

of Olé,

and

the

promotions and

sweepstakes.

Olé

launched

a

digital

subs

cription

that

offers

its

readers

unlimited

consumption

of

all

d

igital

content.

This makes it

the first Spanish

-speaking sports medium to do

so, generating a new source of revenues

for Olé.

Olé

contin

ued as

the undisputed leader

in

sp

orts news,

reaching daily all newsstands in

the country,

as

well

as

from

its

di

gital

vers

ion,

w

hich

yielded

significant

results:

Over

16

million

users

and

nearly

160

million pages viewed o

n average per m

onth.

Internet Business

Clarín

has

a

s

trong

share

in

every

large

digital

platfor

m

and

all

o

f

its

pro

ducts

follow

an

innovative

communication

strate

gy.

In

this

way,

it

has

achieved

a

leading

pos

ition

in

social

med

ia

and

in

Internet

in general.

16

Clarín.com

a

ddresses

the

significant

c

hanges

der

ived

from

th

e

Internet

in

the

w

ay

people

cons

ume

news

and

infor

mation.

The

webs

ite,

with

a

large

dis

play

of

images,

sect

ions

and

a

str

ucture

that

reconfigures

the

tra

ditional

news

categor

ies,

is

const

antly

up

dated

throug

h

an

i

ntegrated

newsroom

that

works

aroun

d-

the

-cl

ock,

365

days

a

year.

In

addition,

Clarin.com

has

several

v

ersions

for

mobile

devices

through

we

b

applic

ations

that

all

ow

us

ers

of

mobile

pho

nes

and

tab

lets

with

any

operating

system to access th

e site.

During

2021,

Clarin.com

r

eached

a

m

onthly

high

of

66

m

illion

unique

br

owsers

and

more

th

an

3

38

million

page

v

iews.

In

2017,

Clarín

became

t

he

first

Arg

entine

n

ewspaper

to

launch

a

digital

subsc

ription

system.

As of

December 2021,

it exceeded

430,0

00

subsc

riptions,

with

more than

4,000,00

0

registered

users.

With

its

sites

“Argenprop”

and

“E

mpleos

Clarín”;

the

company

h

as

a

strong

pres

ence

in

th

e

on

-

line

classified ads for real esta

te and jobs.

El

Gr

an

DT

is

t

he

most

po

pular

game

in

Argentina

a

nd

ha

s

engaged

over

6

million

peop

le

in

its

2

7

editions.

With

a

fri

endly

produc

t,

a

powerful

brand,

a

c

ommunity

of

more

than

300,000

us

ers

an

d

a

business mode

l based on

digital su

bscriptions (with

mor

e than 50,0

00 customers

), Gran

DT continues

its mission to

be

a

football-

linked ent

ertainment s

pace.

Without do

ubt,

a s

uccess

story for

its dura

bility

and popularity.

School Editorial Content

Tinta

Fresca publishes

textbooks, educational

content

s

and children's

and

you

th

literature for

all

stages

of

the

Arg

entine

educat

ional

system,

in

printe

d

and

d

igital

f

ormat.

It

also

offers

a

portfolio

of

world

-

leading, high-impac

t digital educat

ion solutions, includi

ng learning systems,

books, and digit

al content.

During

the

first ha

lf

of

the

2021

acade

mic

year,

Ti

nta

Fres

ca

co

ntinued t

o

suffer

t

he

c

onsequences

of

the restr

ictions on

face

-

to

-f

ace classes

at

schools.

Thi

s context

deepened

the

fall

in t

he sale

of

copies

of sc

hool

textbooks

to

a rec

ord lo

w o

f

one

million

co

pies

in

the

nationa

l

school

book

market.

However,

this situation significantly strengthened the use and

sa

le of digital

solut

ions, and Tinta Fresca achieved

a 77% increase in un

its sold over the previ

ous year.

Tinta Fresca develop

ed 2 new collections tar

geted at stude

nts in the last two ye

ars of primary sc

hool.

It

ma

intains

its

investment

in

Ríos

de

Tinta,

founded

in

2007

and

engaged

in

the

production

o

f

books

and educ

ational

materials

i

n Mexico.

In 2021,

privat

e

sales

continued

to

be

affect

ed by

th

e CO

VID

-

19

pandemic. In contrast, p

ublic sales grew

by 20% comp

ared to

2020.

Impripost

Impripost Tecnologías S.A. is a

company mainly engaged in production and variable printing, including

invoices,

advert

ising

broc

hures,

forms,

labels,

and

ca

rds.

It

a

lso

provid

es

envelo

pe

-stuffing

services.

Today,

it

is

one

of

the

m

ai

n

companies

in

t

he

market

of

variable

data

pr

inting

and

f

inishing

in

large

volumes.

During

2021, I

mpripost

con

tinued

to

lead

the

market

w

ith custo

mers

such

as

Telec

om Arg

entina

S.A.,

AMX Argentina S.A. (Claro), Directv

Argentina S.A., Litoral Gas S.A.,

Met

rog

as S.A., Naturgy Ban

S.A.

(Gas

Natural),

Empresa

D

istribuidora

La

P

lata

(Edelap),

CMR

Fa

labella

S.

A.,

Municipal

idad

de

Rosar

io,

Aguas Santafesinas

S.A., and Aguas

Bonaerenses S.

A. (ABSA).

The

commerc

ial

agre

ement

signed

with

Rico

h

posi

tioned

the

company

favora

bly

in

order

to

address

the challenging outl

ook for the industry.

17

Cúspide

Cúspide is one of the main Argentine companies engaged in the distribution and sale of books. Today,

it has

three bus

iness are

as: The f

irst on

e is a

retail

business,

with

3

0

branches

loc

ated throu

ghout the

country, and a

digital c

hannel, cús

pide.com. The

second

one is enga

ged in wh

olesale distr

ibution with

over 500 customers. And the third

one manages the revenues generated by the franchises. Today, the

company has 16 franch

ised locat

ions.

Cúspide

owns

a

2,500-

square meter

warehouse to

stor

e

and

supply

its own

branches

and

its

wholesale

customers.

The

co

mpany

p

articipates

in

th

e

Book

Fa

ir

and

in

the

C

hildren's

Book

Fair,

wh

ich

will

b

e

resumed in 2022.

Compañía Inver

sora en Medios de Comun

icación (CIME

CO) S.A.

CIMECO

was

organized

in

1997

wi

th

the

a

im

of

acq

uiring

equity

interests

in

Argentine

and

foreign

newspapers,

seek

ing

to

preserv

e

the

regio

nal

journalis

m

industry,

b

lending

expe

rience,

synergy

and

economies

of

scale

,

pres

erving

its

ed

itorial

principles.

CIME

CO

holds

a

majority

interest

in

two

of

the

three

largest

regiona

l

newspapers

i

n

Argentina:

La

Voz

del

Interior

(Córdo

ba)

and

Los

Andes

(Mendoza).

La

Voz

de

l

Interior

S.A.

(LVI)

leads

the

print

a

nd

digital

market

in

the

central

r

egion

of

t

he

co

untry.

Its

newspaper, La Voz de

l Interior, has a s

ignificant marke

t share in the province o

f Córdoba.

In

2021, LV

I focused

its

e

ditorial

policy

on

c

onsolidating

a

multiplatform

strategy by

adjusting

th

e

pri

nted

and dig

ital pro

ducts

to

new

trends

in

the

consum

ption

o

f

news.

In

this

s

earch, d

uring f

iscal

year

2021,

the company imp

lemented proj

ects that had

an impact on

the commun

ity, such as

the broad covera

ge

of the congressional e

lections, its impact

on the provinc

e, and the national econ

omic situation.

The

“digital

first”

process

was

also

co

nsolidated

to c

ontribute

more

value

to c

ontents

across

all

d

igital

platforms.

CIMECO

also ow

ns

Los

Andes

newspaper,

which

has

been

reporti

ng M

endoza’s

news

since

1882.

In

that

year,

the

Calle

f

amily

found

ed

one

of

the

o

ldest

jour

nalistic

compani

es

in

the

country.

Los

An

des

is a benchmark brand

in the market.

During

2021,

Los

Andes

focus

ed

on

ma

intaining

its

leadership

position

b

oth

in

its

prin

t

and

d

igital

versions.

Los Andes

Pass

,

the

newspap

er’s

loyalty program,

re

ached

18,320

subs

cribers in

December.

The p

ercentage

of

r

eaders

subscribed

to

this progra

m

represented

46% of

the

net

month

ly

circulation

at year-end. Los An

des Pass

was incorporated into the BI

MO e

-wallet.

In

August

2020,

the

newspaper

launch

ed

the

digita

l

s

ubscriptio

n,

w

ith

great

r

esults.

In

add

ition,

Los

Andes

granted

access

to

the

Digital

Subscription

t

o

all

the cus

tomers

that

were

already

s

ubscribed

to

the

Digital

Kiosk

service,

which

provides

access

to

the

printed

edition

of

Los

Andes

in

PDF.

The

company

implemented

a

digital

subscription

system

with

a

model

that

sets

limits

on

the

number

of

articles per month an

d on premium cont

ent.

During

2021,

Los

A

ndes’

newsr

oom

achieved

a

stro

ng

acceleratio

n

of

its

digita

l

transformation

a

nd

strengthening of

its brand

presence

in

t

he

new content distribution

platforms, as well

as its

c

ommitment

to service the commun

ity.

Editors,

j

ournalists

a

nd

employees i

n

g

eneral

deepened

the

strategy

of

refocusi

ng

audience

targets

and

working both

for mass audiences -which

allowed to

channe

l new

revenu

es- and

for loyal audiences,

for

whom

different

proposals

of

paid

co

ntent,

newsletters,

audiovisua

l

productions,

or

print

editions

were

developed; that is, in ne

w and tradition

al formats that

were focused on qu

ality.

18

In

this

sense,

it

s

hould

be

noted

t

hat

the

avera

ge

number

of

unique

users,

measured

in

Google

Ana

lytics

dashboards, reac

hed about

8.5 million p

er month,

while

–

on the ot

her hand

–

mo

re than on

e hundred

exclusive contents for s

ubscribers were pro

duced and

published per mo

nth.

Among the

d

istinctions received, it

is worth

mentioning the recognition

given by

the Lower House

of the

Argentine Congress to

the project “Los A

ndes Podcast”, which involved 15

j

ournalists

from

t

he editorial

staff,

and

the

year

before

it

had

receive

d

an

award

fro

m

INMA

in

Paris.

The

photo

grapher

Ig

nacio

Blanco

was

also

recognize

d

for

t

he

coverage

of

stor

ies

and

situations

re

lated

t

o

the

impact

of

the

pandemic

on

the

daily

l

ives

of

the

inhabitants

of

M

endoza.

One

of

those

pr

izes

was

grante

d

by

the

Argentine Associati

on of Journalistic

Entities (Adepa).

Comercializadora de

Medios del Inte

rior S.A (CMI)

CMI

is

engaged

in

publishing

a

nd

in

the

c

ommercial

representa

tion

of

media

outlets

located

in

the

provinces. It

manages the news site

Ví

a País.

In addition, it

publis

hes and sells

the magazine Rumbos,

distributed

by

8 newspa

pers,

and holds

the com

mercial

represe

ntation

of

40 m

edia

outlets

across

the

country.

During

2021,

CMI continued

to

consolidat

e

itself

as the

most important

network

in

the

provinces

.

During

the

year,

the

c

ompany

intensified

t

he

adap

tation

of

its

traditional

bus

inesses

to

new

technologies,

preserving

its

business

model.

In

th

is

way,

it

continued

to

focus

its

businesses

on

the

digital

area.

In

2021, for the first time, t

otal digital reve

nues exceeded

t

hose of the pri

nted busines

s.

Among the

h

ighlights of

digital developments, the

c

ompany consolidated the

site Vía

País.

Its main aim

is to build the largest news network in the country covering all the provinces of Argentina. At the end of

2021,

the

audi

ence

reached

13.9

million

unique

us

ers,

wh

ile

its

turnover

repr

esents

18% of

the

company's

total

revenues,

with

58

active

nodes

(Vía

Argentin

a,

B

uenos

Aires,

Córdoba,

Mendoza,

Rosario, Neuquén, Rí

o Cuarto, etc.).

Revenues fro

m C

MI’s digit

al activities

accou

nt

ed for

6

2% of

its

aggregate

adverti

sing revenu

es, bei

ng

each year more releva

nt.

Finally, the

Magazine Rumbos celebrated its 18-year anniversary in the market, be

ing

, as from

December 2019, t

he only Sunday

magazine in the pro

vinces.

Papel Prensa

Papel

Prensa

S.A

.I.C.F.

y

de

M.

is

the

first

produc

er

of

newsprint

that

is

wholly

owned

by

Argentine

capital.

Currently,

it

also

w

orks

on

the pr

oduction

of

paper

used

for

printing,

wr

iting,

and

p

ackaging.

It

is c

urrently th

e l

argest

Argentine

prod

ucer

of news

print,

with

an

annual pro

duction

capacity

of

approximately 112,

000 tons.

Papel

Prensa

seeks

contin

uous

improvement

in

oc

cupational

health

and

safety.

In

this

regard,

it

has

implemented

s

everal production

po

licies

base

d

o

n

o

btaining

str

a

tegic

supplies

with

out

depleting

natural

resources,

using

materials

that come

fr

om s

ustainable

fores

t m

anagement

proces

ses,

and

recov

ering

raw

materials

by

recycling

returned

newspa

pers

which

are

used

to

reduce

the

us

e

of

virgin

fiber.

On

the

other

hand,

it

c

ontinued

to

focus

on

cons

olidating

the

conservation

awareness

and

the

eff

icient

of

the use of the resourc

es involved (espec

ially fiber, water, and

energy).

Oportunidades S.A

Oportunidades (OSA), incorporated on

M

ay 26,

2003, is engaged

in several

act

iv

ities including, among

others, t

he

exploitati

on

of

advertisin

g c

ompanies;

edit

ing,

publishing,

distribution,

import

and

export of

magazines,

and

books.

In

2012,

and

together

with

Fe

rias

y

Exposiciones

Argentinas

SA

(FE

ASA)

the

Company

incorporated

a

c

orpor

ation

called

+Mas

Log

ística

S.A.

Said

company

is

mainly

engaged

in

the

tr

ansportation

and

distributio

n

of

publications.

Op

ortunidades

ho

lds

a

95%

equity

interes

t

in

that

company.

19

In Decemb

er 2017,

Oportunidades

acqu

ired a

rotary

printing

press

and a

digita

l one,

used f

or He

atset

and

Coldset

printing,

which

involve

two

types

of

treatme

nts

for

commercial

brochures

and

books

,

magazine, and cata

log publications.

With re

gard

to

dig

ital

printing,

duri

ng

2021,

it

forma

lized

a

strat

egic

alliance

w

ith

Ricoh

Arg

entina

S.A.

to

incorporate

variable

data

tec

hnology

in

publications

,

which

has

allowed

the

i

ncorporation

o

f

new

customers.

Billetera Móvil S.A. (“

BIMO”

)

On

October

1

3,

2020,

AG

EA

and

Botón

de

Pago

S.A.

incorporat

ed

a

com

pany

under

the

corporate

name

B

illetera

Móvil

S.A.

(

“BIMO”),

which

is

mainly

e

ngaged

in

th

e

pr

ovision

o

f

electronic

payment

services. AGEA holds a

50% interest i

n the capital stoc

k and votes of

BIMO.

BIMO

offers

the

possibility

of

registering

cards

in

the

app

to

pay

through

the

QR

technology

at

the

stores

that

accept

this

payment

m

ethod,

and

also

to

pay

bills

and

recharge

the

card

SUBE

(a

tra

nsportation

card),

and

to

rech

arge

data

for

mobi

le

lin

es.

In

addition,

t

he

comp

any

integrat

ed

into

the

sy

stem

the

platforms

of

365

(Diario

Clarín),

Club

La

Voz

del

Interior

(La

Voz)

and

Los

Andes

Pass

(Los

Andes),

which allows users to

access

the benefits offered by these pro

grams.

4.2.2.

BROADCASTING

AND PROG

RAMMING

Grupo

Clarín

is

a

major

pla

yer

in

the

Argent

ine

audiovisual

broadcasting

and

programmin

g

segment.

Through

Artear,

it

ex

ploits

t

he

license LS85

TV

Canal

13

Buenos

Aires,

o

ne

of

th

e

t

wo

lar

gest

bro

adcast

television

chan

nels

in

Argentina

in

terms

of

advertisi

n

g

and

aud

ience

share.

I

t

al

so

has

a

presence

in

broadcast

telev

ision

stations in

Córdoba (Telecor).

G

rupo

Clarín also

pro

duces

cable television

signals.

Its

role

in

the

produc

tion

of au

diovisua

l

contents includes

agreements

and

eq

uity

interes

ts

in

benchm

ark

TV

and

f

ilm

prod

ucers,

such

as

Pol-K

a

Produc

ciones

and

Patago

nik

Film

Group.

Grupo

Cl

arín

a

lso

owns

prom

inent

rad

io

stati

ons,

s

uch

as

Mitre

AM

790,

La

10

0

(FM

99.9),

both

in

Buenos

Aires,

an

d

Mitre AM 810

in the province of

Córdoba.

In addition, the

Grou

p has a

strong stake in sports

commercialization and

broadcasting rig

hts, directly and

through joint ventures.

ARTEAR

Artear

o

wns

E

l

Tr

ece,

one

of

the

main

broadcast

c

hannels

in

Buenos

A

ires.

Eltrece

combines

f

iction,

news and entertain

ment, with a vari

ed offering. It a

lso owns TN, a lead

ing 24/7 news s

ignal, and cable

tv signals.

During

2021, Artear

rati

fied i

ts audience

p

erformance in

its broadcast

and

cabl

e

signals

and in

its digital

platform. After

2020, a y

ear mark

ed by the pa

ndemic,

during 2021

Ar

tear

graduall

y resumed

the usual

programming with the return of Marcelo Tinelli and the daily

fiction “

La 1

-5/1

8: Somos uno

.” As always,

eltrece reaffirmed its co

mmitment to informat

ion, with its

four daily newscasts

.

In

2021,

the

da

ily

audience

r

ating

ac

hieved

was

v

ery

similar

to

th

at

achieved

in

2020

with

6.1

points

against

6

.0.

In

the

afterno

on

sl

ot,

the

rati

ng

ac

hieved

was

identical

to

that

of

2020,

with

5

.4

annual

average

ra

ting

points.

Pr

ime

Time

sho

wed

a

4.2%

growth

over

the

From

7.2

to

7.5

on

an annual basis.

During

202

1,

“Eltrec

etv.com.ar”

was

the

most

visited

portal

a

mong

the

Argentin

e

broadcast

stations.

This s

ite

includes

the

live

stream

ing

of th

e s

ignal,

in

addition

to

all

the

progra

mming,

full

episodes,

T

V

listings

and

informa

tion

about

all

its

pro

ducts.

Th

e

site

can

be

access

ed

t

hrough

Faceb

ook,

Twitter,

Instagram,

and, most

recen

tly,

YouTube. During

the

pandemic, eltrecetv.com.ar

made available

a large

portion of its library

of fictions.

In

the

cable

TV

s

egment,

Artear

offers

informative

an

d

entertainment

signals.

The

Spanish

languag

e

music

signal

“Qui

ero

Músic

a

en

mi

Idioma”

was

quick

to

lead

audience

r

atings

in

the

music

ge

nre.

“Volver”

offers

the

best

of

c

lassic

and

vintage

Argentine

films

a

nd

television

s

hows.

In

addition,

C

anal

20

(á), a signal that offers arts, c

ultural and show business

programs, mainly in Bu

enos Aires, is operated

by Artear.

Artear

owns

TN

(Todo

Notic

ias),

t

he

most

prest

igious

24/7

cable ne

ws

s

ignal

in

Argentina.

TN

is a

news

signal and its programmin

g is based on ongo

ing news programs and a var

ied general interest

programming

c

omprising

society,

politics,

economy,

internationa

l,

crimes,

investigations,

sports

,

entertainment, techno

logy, and agricultura

l topics.

In

2021,

TN

led

audience

ratings

in

all

mont

hs

and

positioned

itself,

onc

e

again,

as

the

most

viewe

d

cable

sig

nal

of

the

ye

ar,

outperforming

its

loca

l

an

d

international

competitors

by

a

wide

difference.

According

to

Kantar

Ibope

Media,

the

cumulative

av

erage

rating

during

the

year

-

from

Monday

to

Sunday

from 7a

m to

12

am

-

was

2.10

points.

C5N

achieved

an averag

e

of 1.7

5 points

, Cr

ónica 1.15,

A24 1.13, LN+ 1.0

9, Canal 26 1.0, a

nd IPTV 0.05.

In

a

year

mark

ed

by

th

e

congress

ional

elect

ions,

TN

added

to

its

us

ual

pro

gramming

the

pr

oduction

and broadcast of

debates

between

candidat

es for

the representation of the

City of Buenos Ai

r

es and

of

the

Province

of

Bue

nos

Aires

.

Both

ha

d

a

w

ide

reperc

ussion

and

achieved

unprecedented

audience

ratings for

cab

le televis

ion,

outperforming

4

of

the

6 br

oadcast

tv

cha

nn

els. In

add

ition, it

was

the

only

signal

that

managed

to

gather

the

candi

dates

that

headed

the

lists

of

all

the

political

parties

that

competed in the prim

ary elections.

On

the

e

lection

day,

TN

m

ade

a

d

uplex

broa

dcast

wi

th

eltrece

t

hat

aver

aged

9.

3

rati

ng

points

and

achieved

the

high

est r

ating

on

that

day.

The

coverage

included

18

outside

broad

cast

units,

10

mo

bile

broadcast devices, and

4 motorbikes to fo

llow the candidat

es.

Besides

the

special

coverages,

millions

of

Argentines

chose

to

watch

the

compan

y's

newscasts

and

programs

throu

ghout

the

year

to

learn

about

what

is

happen

ing

in

t

he

co

untry

a

nd

in

the

wor

ld.

TN

is

the

signal

with

the

lar

gest

number

of

in

ternational

c

orrespondents

and

outside

broadcast

un

its

in

the

Argentine territory.

In

addition,

T

N

was

the

mos

t

chosen

signal

for

streaming

news

and

its

YouTube

channel

exc

eeded

2

million

subscribers

.

Its

social

media

community

c

onsolidated

itself

as

th

e

largest

of

a

Lat

in

American

medium. On

Instagram, it

re

ached a

record high

of 4.6 mi

llion followers

an

d on

Tik Tok

it ha

s more

than

1 million.

In

a

year

mark

ed

by

a

w

ide

range

of

journalistic

topics

and

a

hu

ge

volume

of

political

o

pinion,

Todo

Noticias expanded its leadership without modifying the DNA that identifies the

signal: a huge display of

production, coverage,

ongoing live broa

dcast, engage

ment with the audi

ence and analys

is.

Ciudad

Magazine,

also

ow

ned

by

Artear,

is

another

cable

signa

l

that

aros

e

from

the

merger

of

tw

o

leading

me

dia

in

show

business,

Magazine

and

Ciudad.com.

This

merger

levera

ged

th

e

best

of

e

ach

and their

potential to provide the

a

udience with broader news

c

overage, more entertainment and be

tter

connection.

Quiero,

the

Spanish

langua

ge

music

signal,

is

also

owned

by

Arte

ar.

A

leader

in

its

category,

it

offers

varied

programmi

ng

c

omprising

national

and

Latin

-A

merican

rock,

hip

hop,

re

ggaeton,

alterna

tive

music, pop, and me

lodic music, among

others.

Artear

also

produces

Canal

(á),

a

24/7

si

gnal

focuse

d

on

culture.

A

c

hannel

tha

t

gathers

all

genres

linked to art and

culture un

der the premise

of a plural

approach.

A signal with an

avant

-

garde look and

feel that set a trend am

ong its peers

.

The signal

Volver preserve

s Argent

ine television

history

and owns th

e largest

national

film library.

The

programs

broadcast

by

Vol

ver

are

recognized

by

the

pub

lic

as

genuine

manifestations

of

“th

e

b

est

of

our culture”.

Cucinare is

the local

signal for ga

stronomy

l

overs. Cuisine

fans can fi

nd easy

recipes and

sophisticated

dishes

w

ith

the

prem

ise

of

providing

easy-

to

-prep

are

recipes.

A

100%

digital

brand

i

n

i

ts

origin

which

grew until achieving a

360° format wit

h presence on te

levision and off

-

line.

21

América

Sports

is

the

s

ports

signal

that

offers

2

4

h

ours

of

passion

cov

ering

all

sp

orts.

With

a

s

pecial

focus

on

motor

rac

ing,

turf,

hunting,

fish

ing,

kitesurf,

and

extrem

e

and

non

-co

nventional

sports

in

general.

In the

dig

ital f

ield, 2

021 w

as

a

year

of

great

evolution

in

terms

of

innovati

on a

nd c

ollaboration

with

the

different

platforms

with

whi

ch Artear

si

gned

agreemen

ts

for the

distri

bution

of

its

contents.

In

addition

,

Artear

foc

used

on analyzing the da

ta gathered to

better

po

sition its

contents in ea

c

h of

t

hose

platf

orms.

Among

the

most

demandin

g

d

igital

proj

ects

was

the

coverage of

t

he

elections

for different

digital media.

TN

developed

real

-time

data

mod

ules,

infograph

ics,

maps,

and

new

content

formats

to

enrich

and

complement

news.

The

website

was

positioned

over

the

last

m

onths

of

the

year

in

the

top

5

of

news

sites in Argentina and th

e brand is an absol

ute leader i

n social media.

Eltrece

decided

to

make

posts

in

soc

ial

media

in

l

ine

with

th

e

contents

broadcast

in

tv,

confirming

its

leadership

in

this

m

edium,

whi

le

d

uring

the

sec

ond

half

of

the

year

it

s

ustained

its

g

rowth,

largely

leading

the websites of broadcas

t c

hannels.

Ciudad Magazine incorporated new talent and,

w

ith a sol

id strategy focused on web content and

social

media,

conso

lidated

its

elf

as

the

leading

brand

in

Ar

gentine

ent

ertainment,

ac

cording

to

C

omScore

rankings.

Artear

is

no

longer

just

a

broadc

aster,

it

has

b

ecome

a

content

generator

for

multiple

distribution

platforms. Thus,

Artear was

forced to invest

in more

and better techn

ology. Among

the most import

ant

technical

invest

ments

were

robotic

ca

meras

for

TN,

th

e

incorporat

ion

of

v

irtual

s

ets,

and

aug

mented

reality.

Artear

is

the

controlling

company

of

Canal

12

of

Córdoba,

which

invests

heavily

in

journalist

ic

a

nd

entertainment

contents,

with solid

aud

ience

shares

an

d a

good outlook.

I

n 2

021,

Artear

so

ld

its e

quity

interest in Canal 6 of

Bariloche.

Ar

tear

also

holds

a

n

equity

interest

in

Pol

-ka, which

duri

ng

2

021

c

ontinued with

the

operational

restructuring

p

lanned

i

n

20

20.

Pol

-ka

was

able

to

com

plete

the

filming

of

the

single

ep

isodes

of

Tigre

Veron

II,

which

had

b

een

interrupted

d

ue

to

the

pandemic.

D

uring

2021,

Po

l-ka

produced

for

Artear's

prime

ti

me

a dail

y

fiction

call

ed

“

La

1-5/18

Somos

Uno

,” the

highest

-rated

program

of

the

year in

eltrece.

In addition, it

made an eight-

chapter biographical document

ary series for HBO,

“

Maria Marta, el crimen

del country

”.

IESA

Inversora

de

Eventos

S.A.

continued

to

exploit

the

sports

audiov

isual

cont

ent

generation

business

through its subsidi

aries Tele Re

d Imagen (own

er of 50% of

the signa

l TyC Sports

), Televisión

Satelital

Codificada

S.A.

a

nd

Auto

Sports

S.

A.

-

Carburando

S.A.

The

last

two

compan

ies

ex

ploit

the

comprehensive

mot

or r

acing

business

in

Argen

tina

and

are

also

ho

lders

of

the

rights

to

broadcast the

SUPER

TC2000

an

d

TC20

00

s

ports

categories

.

In

addition,

Inversora

de

Eventos

owns

25%

of

the

shares of Canal Rura

l, a local cable signa

l that produces

audiovisual content rel

ated to the agricu

ltural

sector.

During

20

21,

t

hrough

Tele

Red

Imagen,

it

i

ncorporated

several

international

sporting

events,

such

as

the

2

021

America

Cu

p

and

the

2022

W

orld

C

up

playoffs

,

along

with

t

he

m

ain

local

co

mpetitions

in

motorsport, basket

ball, volleyball, box, a

mong others.

Mitre

Radio Mi

tre S.

A. prov

ides

sound br

oadcasting

services

through M

itre A

M 79

0

(amplitude

modulation),

La

100

(99.9)

(frequency

modulation)

in

the

city

o

f

Buenos

Aires,

and

Mitre

AM

810

and

FM

102.9

in

the province of Córd

oba.

22

Mitre A

M 790

focuses

its programming

on

strong journalistic

productions supported

by the

high

credibility

and

professionalism

of

its

team.

The

first

morning

radio

ta

lk

show

is

hosted

by

Marcelo

Longobardi

and the

team of

Cada

Mañana,

from 6

AM

to 10

AM.

It has

maintaine

d its

leadership,

with

around

4

5

points.

In

November

20

21,

Marcelo

Longobardi

decid

ed

to

en

d

his

c

ycle

as

host

and

the

team

c

ontinued

with

the

pr

ogram,

hosted

by

Willy

Kohan

and

J

orge

Fernandez

Díaz

until

February

2022. On Fe

bruary 7, 202

2, Mitre launche

d

Alguien T

iene que Decirl

o

, hoste

d by Eduard

o Feinmann,

along wit

h María

Isabel

Sa

nchez, R

olo Vi

llar, Lean

dro Bu

onsante,

and

Alberto C

ormillot,

among

other

columnists.

After

that

show,

Radi

o

Mitre

airs

Lanata

sin

Filtro

from

10

AM

t

o 2

PM,

hosted

by

Jorge

Lanata

an

d

a

team of

sp

ecialists, which lead

audience shares.

T

he program

can also be

watched in

high

-definition at

radiomitre.cienrad

ios.com.

In

additio

n,

Encendidos

en

la

tarde

,

hosted

from

2

p

m

to

4

pm

by

Marí

a

Isabel

Sánchez

and

Ro

lo

Villar,

is a

fun

af

ternoon

show

th

at

comb

ines

information, h

umor,

and

interviews. The show

also leads its time s

lot.

From

4

pm

to

5

pm,

Dieg

o

Le

uco

and

his

team

h

ost

Diego

a

la

tarde

,

a

mag

azine

that

combi

nes

information,

hum

or,

intervi

ews,

and

even

concerts.

The

program

remained

a

leader

in

its

time

slot

throughout the year, w

ith around 35

audience share po

ints.

From 5

pm to

7 pm, Alfredo

Leuco hosts

Le doy

mi palabra

.

His editorials

ar

e

very

po

pul

ar and

achieve

high audience leve

ls of around 35 points. Fr

om 7 pm to 8 p

m, Pablo Rossi a

nd Laura Di Marco hoste

d

Volviendo

a

Casa

,

a

s

how

with

all

th

e

necess

ary

information

for

those

who

return

to

the

ir

homes.

In

2022, that show is h

osted by

Tato Young and Eleon

ora Cole.

The

evening slot

starts at

8 pm

w

ith

Jorge Fernández

Díaz hosting

Pensándolo

Bien

.

At

11 pm,

Cr

istina

Pérez

and

her

team

hosted

a

show

that

ended

in

December.

Finally,

at

midnight,

Gabriel

Anello

and

his team host the s

ports program Su

per Mitre Deporti

vo.

During

weekends,

Mitre

has

different

propos

als.

On

Saturdays

from

7 to

10

am

Marcelo

Bonelli

hosts

Sábado

Tempranísim

o

,

wit

h

more

than

30 years

on the

air, with

audienc

e

levels

of more

than 40

points.

From

10 am

to

12

pm Magdalena

Ruiz

Guinazu

along

with

Nico

las

and

Mig

uel

Winaz

ki

hosted

Magdalena y

la Noticia más

Deseada

, a

summary of the

mos

t relevant ne

ws of the

week. At noon,

also

exceeding

40

points,

Polino

Auténtico

proposes

a

fun

approach

t

o

the

most

important

show

busin

ess

news.

On the other hand,

Mitre Informa

Primero

is st

ill the mos

t awarded radio news serv

ice of Argentina.

La 100 closed the year 2021 leading a

udience shares, with almos

t 20 points, which was a record hi

gh.

Its programming combines famous artists and a

mix of music and innovative contents. During the

year,

Santiago de

l Moro

l

ed

morning audience

ratings, from

6

AM to

10 AM,

wit

h

El

C

lub del

Moro

,

a program

co

-hosted

by

M

aju

Lozano.

The

program

reached

an

unprecede

nted

audience

ratin

g

of

nearly

27

points.

Guido

Kaczk

a

and

C

laudia

Fontá

n

host

No

está

t

odo

dich

o

,

from

10

AM

t

o

2

PM.

Th

e

program

consolidated

its

pos

ition

in

its

slot

and

had

months

with

more

than

20

points,

dou

bling

its

closest

competitor.

In

2020,

Mari

ano

Peluffo

and

Ju

lieta

Prandi

host

Sarasa

in

La

10

0,

from

2

PM

t

o

5

PM,

a

casual radio mag

azine. The pro

gram reached

over 20 points f

or several

months, lead

ing the segme

nt.

Then,

Sergio

Lapegü

e

hosts

Atardecer

de

un

d

ía

agitado

.

From

8

pm

to

1

2

am,

the

program

Románticos

remains

the

leader

in

its

slot.

During

Saturday

m

ornings,

Guillermo

López

host

s

Rank

ing

Yenny,

a

program

th

at

comb

ines

mu

sic,

hu

mor,

show

bus

iness

and

general

information.

Mariano

Peluffo

hosts

Abierto los doming

os

from 10 am to

2 pm.

Mitre 810 of the

province of

Córdoba

remained the

second most list

ened radio s

tation in that

province,

with

a

perm

anent

s

taff

in

th

e

city

and

a

n

ews

serv

ice

of

its

own,

c

alled

Mitre

Informa

Primero

.

It

develops

a

compre

hensive

coverage

of

news

in

C

órdoba,

Argentina

and

wor

ldwide.

The

most

prominent

hosts

are J

orge

“Pete

te”

Martíne

z

(Monday

to

Friday

from 6

am

to

11am),

Laura

Gonza

lez w

ith

her

pr

ogram

Mediodía

,

and

Omar

Perey

ra

with

Sies

ta

Animal

.

From

Mond

ay

to

Frid

ay

fro

m

8

p

m

t

o

12

am

J

uan

Alberto Mateyko hosts

La mov

ida de la noche

, a clas

sic in Córdoba.

Cienradios

maintains

its

p

osition

with

the

m

ost

important

radio

and

online

c

ontent

menu

in

Latin

America, with

a great

diversity

of radios, vi

deos, spec

ial reports,

shows,

contests,

and premium

sound

23

quality.

Cienrad

ios

is

the

larges

t

m

usic

porta

l

and

recommender

of

the

reg

ion

and

the

first

one

in

Argentina, with almost 1

5 million uniqu

e browsers by the e

nd of 2021.

4.2.3.

OTHER

Services

Gestión

Co

mpartida

is

a

company

engaged

in

prov

iding

compr

ehensive

solutions

to

meet

the

management

and operatio

nal needs

of compan

ies, whi

ch allows

its customers

to focus

their efforts

on

the

activities

that

represent

their

cor

e

b

usiness.

Each

area

has

prof

essional

and

techno

logical

resources

and

operates

in

Argentina

and

several

c

ountries

of

South

America,

with

a

working

team

of

more

than

450 professionals.

Today, GC Gestión Com

partida serves over

100 companies

from different industr

ies,

size, and origin.

Also

during

the

year,

c

ommercial

alliances

were

executed

with

important

compani

es

and

consultin

g

firms that

wil

l allow

to

accel

erate reg

ional ex

pansion

and

offer

high

quality

solutio

ns. Dur

ing 2021

, G

C

Gestión

Com

partida

focused

on

meeting

a

set

of

goals

concerning

digital

transform

ation

and

acceleration of growth.

Among the highlights was

the launch of RISKO, an i

ns

urance services brand. It

also launched ENEAS,

a company positioned to

enter the health mark

et.

Ferias y Exposiciones

Exponenciar

S.A.

has

am

ong

its

m

ain

ac

tivities

the

organization

of

Expo

agro.

The

fa

ir

h

as

been

h

e

ld

once a year in the Ci

ty of San Nicolás

at a fixed locati

on for 15 years.

For

reasons

linked

to

the

COVID

-19

pandemic,

th

e

c

ompany

could

not

hold

Expoagr

o,

Edición

YPF

Agro

, or the 16

th

edition of

Caminos y Sabor

es.

In

March

2021,

Exponenci

ar

launched

Expoagro’s

v

irtual

p

latform

“di

gital.expoagro.com.

ar”

with

free

access that

links

the agricultural industry

throu

ghout

th

e

year

prov

iding

informa

tion, tools, and

business

networking for better d

ecision-

making.

The

portal

c

onsolidates

its

elf

as

a

soc

ial

net

work

that

is

an

ongoin

g

source

of

consultation

f

or

prod

ucers,

contractors,

advisors,

and

technicians

of

the

agricultur

al

industry

who

i

nform

themselves,

learn

about

climate

news,

obtain

adv

ise

and

train

ing

through

we

binars

org

anized

by

tec

hnicians.

The

sit

e

offers

streaming and live broa

dcast of traini

ngs and events.

By

mid

-year,

it

launche

d

its

livestock

auct

ion

platform

www.r

emataronline.co

m

i

n

partnership

w

ith

t

he

ROSGAN livestock

market.

From October 24 to 29, the unprece

dented event

Expos

ición Nacional de Razas

was held in Sociedad

Rural

i

n

C

orrientes. E

xhibiti

ons

of

th

e

Braford,

Brangus

,

Brahman

y

Cabal

los

Cr

iollos

breeds

were

held.

There

were

h

undreds

of

breeding

animals

of

very

high

genetic

level

i

n

21

hect

ares

of

exhibition.

T

he

event

was

broadcast

o

n

the

digital

p

latform

expoagro

.com.ar

a

nd

was

viewe

d

by

20,000

connected

users from Argentin

a and the world.

During

2022,

the

company

will

hold

Expoagro

edición

YPF

Agro

from

Marc

h 8

to

11 at

Predio

Ferial

y

Autódromo in San

Nicol

ás. The

participatio

n of more than 600

companies has already been confirmed.

In July, Exponenciar wi

ll hold the 16

th

edition of

Cam

inos y Sabores

in La Rura

l.

4.3.

AWARD

S AND R

ECOGNITIONS

During

2021,

Grupo

Clarí

n

and

its

med

ia

c

ontinued

to

be

amon

g

the

c

ountry's

most

award-winning

media in their respective ca

tegories. These awar

ds include:

24

Diario Clarín

7 ADEPA awards a

nd special mentions

3 EIKON awards

2 journalists recognize

d with the Lola

Mora Award of the Govern

ment of the C

ity of Buenos A

ires

1 journalist recogn

ized with the Acc

enture award in th

e category inn

ovation and inc

lusion

Todo Noticias (TN)

3 Martin Fierro de Ca

ble Awards

Radio Mitre

Finalist in the New

York Festival Awards

TyC Sports

Embassy of Peace

Award

La Voz del Interior

4 ADEPA awards

1 FOPEA award

3 Eikon Awards

1 Mention in INM

A Global Media Awards

1

st

Fundación Avina Aw

ard for the Res

ilient Cities Re

gional Initiative

1 South American Aw

ard to Journalism on

Migration

–

Fundación Gabo

Los Andes

1 ADEPA Award Me

ntion

1 Aconcagua award

Eldoce

Recognition at the Co

nference on Sports

Journalism of Instit

uto Mariano More

no

5.

FINANCIAL POS

ITION AND RESU

LTS OF ITS OPE

RATIONS

Total

Rev

enues

reached

$

40,1

49

million

in

2021,

a

dec

rease

of

0.2%

from

$

40,

210

million

in

2020.

Advertising

reven

ues

incre

ased

by

18

.6%

in

r

eal

terms,

ma

inly

due

to

a

recov

ery

of

t

he

Advertisin

g

Industry

as

a

c

onsequence

of

the

recovery

of

Argentine

G

DP

and

a

mor

e

attractive

content

proposal

with

the normalization of

activity after

the lockdowns imposed during

2020. Circulation sales

decreas

ed

by

7.7%

in

rea

l

terms,

mainly

due

to

lower

printe

d

circ

ulation,

in

line

w

ith

the

industry

trends,

partia

lly

offset

by

higher

digital

s

ubscriptions.

Additionally,

Sales

of

Logi

stics

Services

dec

reased

by

61.4%,

mainly due the deconso

lidation of UNIR.

Cost of sa

les (Exclu

ding Deprec

iation and

Amortizati

on) reac

hed $ 2

2,540 m

illion in 2

021, a

decrease

of

4.0%

from

$

23,488

million

reported

in

2020

due

t

o

the

deconsolid

ation

of

UNIR,

partially

offset

by

higher

cos

ts

in the

B

roadc

asting

and

Programming

segments

due

to

a

more

appeal

ing

co

ntent

pro

posal

with

the

return

of

fiction

while

the

measures

impose

d

during

2

020

in

an

e

ffort

to

c

ontain

the

spread

of

Covid-19 had dramat

ically change

d the content on air.

Selling

and

Adm

inistrative

Expe

nses

(Excluding

D

epreciation

and

Amort

ization)

reache

d

$

11,369

million

in

2021,

a

decrease

of

3.8%

from

$

11,823

mil

lion

in

2020.

T

his

drop

was

mainly

due

to

lower

distribution

costs and

bad

debt in

the

Printed and

Digital

Publicatio

ns

segment, partially

of

fset

by higher

costs in Broadcasting

and Programming.

Adjusted E

BITDA reach

ed $

6,240

million i

n 2021,

an i

ncrease of

27.4%

from $

4,899

million

reported

for

2

020,

m

ainly

driven

by

hig

her

advertising

revenue

s

in

Broadc

as

ti

ng

and

Programmin

g

a

nd

c

osts

reductions

in

real

terms

greater

than

the

decrease

in

rev

enues

in

the

Digital

an

d

Printed

Pu

blications

segment.

25

Financial

results

n

et

totaled

a

l

oss

of

$

2,673

million

in

2021

compared

to

a

loss

of

$

1,528

mi

llion

in

2020.

The

increase

of

the

negative

f

inancial

res

ults

w

as

mainly

due

to

the

increase

of

th

e

loss

on

net

monetary

position

an

d

n

egativeresults

from

operations

with

notes

and

bonds,

pa

rtially

offset

by

lower

negative foreign exc

hange loss and inter

ests as a result o

f the d

ecrease in financ

ial debt.

Equity in earnings from

associates in 202

1 totaled a gain of $ 4

48 million, com

pared to $ 875 m

illion in

2020.

Other Income and exp

enses, net reached

a gain of $ 12 millio

n in 2021, comp

ared to a loss of $ 1,843

million in 2020 (see N

ote 6.6 to the F

inancial Stateme

nts).

Income tax as of 2021 re

ached a loss of $

1,200 million in 20

21, from $ 1,058

million in 2020.

Gain

for

t

he

ye

ar

2

021

to

taled

$

1,065

million,

an

increase

of

251.7%

fro

m

t

he

l

oss

of

$

702

mi

llion

reported

in

2020.

Gain

attr

ibutable

t

o

Sh

areholders

of

the

Parent

Co

mpany

amounted

$

1.039

million

in 2021, an increase of

350,9% from the loss of

$ 414 million in

2020.

Cash us

ed

in

acquisitions

o

f

property,

plant

and

equ

ipment (

CAPEX)

totale

d $

965 million

i

n

2021,

an

increase

of

43.5%

from

$

673

million

reported

in

20

20.

Out

of

tot

al

CA

PEX

f

or

2021,

8

0.6%

was

allocated

towards

the

Broadcasting

and

Program

ming

segment,

14.

1%

to

the

Print

and

Di

gital

Publications segment

and the remainin

g 5.3% to other

activit

ies.

Debt profile

(1): Debt coverage ratio

for the year

ended December 31, 2021

was 0.42 and

the Net Debt

(2) at the end of th

is year totaled $ 2,593

million.

Grupo

Clarín

S.A.

is

still

controlled

by

GC

Dominio

S.A.,

which

holds

64.2%

of

its

voting

rig

ht

s.

Balances

and transactions with re

lated parties are deta

iled in Note 15 to th

e Consolidated F

inancial Statem

ents.

(1)

Debt

Coverage

Ratio

is de

fined

as Total

Fina

ncial

Debt

divided

by

Adjusted

EBITDA.

Total

Financial

debt

is

defined

as

f

inancial

loans and debt

for acquisitions, inc

luding accrued interest

.

(2)

Net Debt is de

fined as Total Fin

ancial Debt less Cash

and Cash Equivalent

s.

6.

CORPORATE GOVERN

ANCE, ORGANIZATION, AND

INTERNAL CONTROL

SYSTEM

Grupo

Clarín's

Board

of

Di

rectors

is

responsible

for

t

he

C

ompany's

ma

nagement

and

approves

its

policies

and

overall

str

ategies.

Pursuant

t

o

the

By

-laws,

the

Board

o

f

Direct

ors

is

composed

of

ten

permanent directors and ten alternate directors who are elected at the Ordinary Shareholders

' Meeting

on

an

annual

basis.

Four

of

them

(

two

permanent

and

two

alterna

te

members

)

are

required

to

be

independent directors, a

ppointed in ac

cordance with t

he requirements prov

ided under th

e CNV rules.

Members of the Boa

rd of Directo

rs

Grupo

Clarín's

Board

of

Directors

is

c

omprised

by

the

fo

llowing

memb

ers,

app

ointed

at

th

e

Annual

Ordinary Shareholders' Me

eting and Spec

ial Meeting per Clas

s of Shares, held o

n April 30, 2021:

Rendo, Jorge Carl

os

Chair

Aranda, Héctor Mar

io

Vice Chair

Aranda, Alma Rocío

Permanent Director

Noble Herrera, Felip

e

Permanent Director

Magnetto, Horac

io Ezequiel

Permanent Director

Pagliaro, Francisc

o

Permanent Director

26

Driollet, Ignacio Ro

lando

Permanent Director

Calcagno, Lorenzo

1

Permanent Director

Riportella, Andrés Gabri

el

1

Permanent Director

Quiros, Horacio Edu

ardo

Permanent Director

Colugio, Patricia Miri

am

Alternate Director

Acevedo, Francisco Ivá

n

Alternate Director

Etchevers, Martín Go

nzalo

Alternate Director

Sosa Mendoza, Eugenio Eduardo

Alternate Director

Boncagni, Marcelo F

ernando

Alternate Director

Rebay, Carlos

1

Alternate Director

Fernández, Luis Germá

n

1

Alternate Director

Puente Solari, Lucas

Alternate Director

Kahrs, Alfredo Enrique

Alternate Director

Marina, Alberto Pedro

Alternate Director

1

Independent Direc

tor

Grupo

Clarí

n

also

has

a

Supervisory

Comm

ittee

comprised

of

3

perman

ent

m

embers

and

3

alternate

members,

who

are

a

lso

appointed

on

an

annua

l

basis

at

the

Or

dinary

Shareholders'

Meeting.

The

B

oard

of Directors, through an Au

dit Committee, is in charge of the

ongo

ing oversight of all matters

related to

control

information

system

s

and

risk

management,

and

iss

ues

an

annual

report

on

these

topics.

The

members

of

the

Company's

Audit

Committee

may

be

nominated

by

any

member

of

the

Board

of

Directors and

a majority of

its members must

meet

the independence requirement provided under

CNV

rules.

Supervisory Committe

e

The

Comp

any's

Su

pervisory

Committee

is

compose

d

of

the

following

member

s,

app

ointed

at

the

Annual

Or

dinary

Shareholders'

Meeting

a

nd

Special

Meeting

p

er

Clas

s

of

Shares,

held

on

April

30,

2021:

Piano, Adriana Estela

1

Permanent Member of t

he Supervisory

Committee

Di Candia, Carlos

Alberto Pedro

1

Permanent Member of t

he Supervisory

Committee

López, Hugo Ernesto

1

Permanent Member of t

he Superv

isory Committee

Tedín, Silvia Andrea

1

Alternate Member of t

he Supervisory

Committee

Mazzei, Miguel Ang

el

1

Alternate Member of t

he Supervisory

Committee

De la María Martin

ez de Hoz, J

orge J.J

1

Alternate Member of t

he Supervisory

Committee

1

Independent

Audit Committee

Calcagno, Lorenzo

Chair

Riportella, Andrés Gabri

ela

Vice C

hair

Aranda, Héctor Mar

io

Permanent Memb

er

Acevedo, Francisco Ivá

n

Alternate Member

Rebay, Carlos

Alternate Member

Fernández, Luis Germá

n

Alternate Member

27

The

overa

ll

criteria

used

t

o

appoint

managers

are

b

ased

on

t

he

b

ackground

and

exper

ience

in

the

position

and

t

he

industr

y,

companies

they

hav

e wor

ked

for,

age,

professional

and

moral

compe

tence,

among other factors

.

In

ord

er

to

i

dentify

opportunities

and

stream

line

stru

ctures

and

sy

stems

with

the

aim

of

i

mproving

processes and m

aking informed

decisions, G

rupo Clarí

n sets forth sever

al proced

u

res and

policies for

controlling the Co

mpany's

operations. Th

e areas resp

onsible for the

Company's

internal contro

ls, both

at the Comp

any level a

nd at the l

evel of its

subsidiar

ies

and affiliat

es, contr

ibute to

the safe

guardin

g of

shareholders'

eq

uity,

the

reliability

of

financial

infor

mation,

and

the

complian

ce

with

laws

and

regulations.

Compensation of the M

embers of the Bo

ard of Dir

ectors and Senior

Management

Compensation

of th

e me

mbers

of th

e Board

of

Directors

is

decided

at

the

Shareholders' M

eetin

g

after

the

c

lose

of

each

fiscal

ye

ar,

considering

the

cap

est

ablished

by

Article

261

of

Law

No.

19,5

50

and

related regulations of

the CNV.

All

of

Grupo

Clarín's

subsidiaries

have

com

pensation

arrangements

with

all

their

officers

in

executive

and mana

gerial

positions,

which c

ontemplate

a

fixed

and v

ariable

remuneration

scheme.

Fixed

compensation

is

tied to

the

level

of

resp

onsibility

att

ached

to

each

position,

prevailing

m

arket

salar

ies

and

performa

nce.

The

annual

variable

component

is

tied

to

performance

during

the

fisc

al

year

based

on

the

objectives

set

a

t

the

beg

inning

of

th

e

year.

G

rupo

Clarín

does

not

have

any

s

tock

option

plans

in place for its personn

el.

As ment

ioned i

n Note

18

to

the C

onsolidate

d Financ

ial

Statements,

on

January

1, 20

08

, Grupo

Clarín

began

to i

mpl

ement

a

long

-term

savings

plan

for

certain

ex

ecutives

of

Gr

upo

Clarí

n

and

its

subs

idiaries.

Executives

who

adhere

to

such

plan

regularly

contri

bute

a

limited

portion

of

their

salary

to

a

fund

th

at

will

allow

them to

inc

rease

their income

at

the retirement

age.

Furthermor

e,

each

c

ompany ma

tch

es

the

sum

contribut

ed

by

such

executives.

This

matching

c

ontribution

is

added

to

the

fund

r

aised

by

the

employees.

U

nder

certa

in

conditio

ns,

employe

es

ca

n

access

such

fund

upon

retirement

or

upon

termination

o

f

their

employment

relationship

with

Grupo

Cl

arín.

This

long-

term

benefit

has

a

strong

withholding

component

and

is

cons

idered as

an

integral part

of

the

em

ployee's

total

compensatio

n for

comparative purposes w

ith prevailing m

arket salaries. Durin

g

2013, certain c

hanges were m

ade to the

savings

sys

tem,

although

its

operation

mechanism

a

nd

the

main

characteristic

s

with

regard

to

the

obligations undertake

n by the company w

ere essential

ly maintained.

The

parameters

used

in f

ixing

compensat

ions

are

in

line

with

c

ustomary

market

practices

fo

llowed

by

companies

of the s

cale of

G

rupo Clarín.

To t

his end,

the Co

mpany ass

esses the

r

elative weight

of th

e

different

positions

within

the

company,

as

well

as

the

performance

of

the

emp

loyee

that

hol

ds

the

position. In order to

assess positions and compare salaries in

differ

ent markets, the Company uses

the

services and reports

of prestigious HR c

ompanies at t

he national and int

ernational levels.

Annual Shareholders'

Meeting

Grupo

Clarín

he

ld

its

Ann

ual

Ordinary

Shareholders'

Meeting

on A

pril

30,

2

021.

On

this

occasion, t

he

shareholders

reviewed

and approved

the

accounting records

for fi

scal year

No. 22

ended

on December

31,

2020

and

the

performa

nce

and

comp

ensation

of

t

he

m

embers

of

the

Board

of

Directors

and

the

Supervisory

Committee.

Among

other

things,

they

elected

the

permanent

me

mbers

a

nd

alternate

members of the Boar

d of Directors

and the Supervisory

Committee for the

year 2021.

Dividend Policy

Grupo

Clarín

do

es

not

h

ave

a

form

al

dividend

policy

governing

th

e

amount

and pay

ment

of

d

ividends

or

other

distributions.

According

t

o

its

By

-laws

a

nd

the

Argentine

Corporate

Law,

Grupo

Clarí

n

may

lawfully pay

and make

declarations of

d

ividends only

out

of

the

retained earnings

stated

in the

28

Company's

annual

Financi

al

Statements

prepare

d

in

accordance

wit

h

Argent

ine

GAAP

and

CNV

regulations and approved a

t the Shareholders' Meeting

. In such case, dividends must be paid on a pro

rata basis to all hold

ers of shares of co

mmon stock as

of the relevant recor

d date.

Set-up of Reserves

Pursuant

to

the

Arge

ntine

Corporate

Law

an

d

CN

V

r

esolutions,

Grupo

Clarín

is

required

to

s

et

up

a

legal reserve of no less than

5% of each year's retained earnings until such res

erve reaches 20% of its

outstanding

cap

ital

stock

p

lus

the

corr

esponding

adjustment.

The

lega

l

reserve

is

not

available

for

distribution to shareho

lders.

Code of Corporate Go

vernance

In

addition

to

th

e

aforeme

ntioned,

an

d

in

co

nformity

with

R

esolution

N

o.

70

7/2019

iss

ued

by

the

Argentine Securities Commission, the

Company prepared the Report

on the Code of Corporate

Governance

in accordance

with

Exhibit

III, Title

IV

of Chapter

I,

Sec

tion

I

of

the

Rule

s,

which

is

attached

as an exhibit to this

Annual Report.

7.

SUSTAINABILI

TY

7.1.

SUSTA

INABILITY STRAT

EGY

Grupo Clarín has undertaken the commitment to work responsibly

in order

to contribute to the

sustainable

deve

lopment

of

the c

ountry

from

its

role as

a

media c

ompany.

Since

it

s

foundation,

it

has

foc

used

on

fulfilling

a

nd

con

solidating

the

citizens’

right

to

informat

ion,

with

a

compr

ehensive

journ

alistic

and

entertai

nment

offeri

ng,

based

on

accuracy

,

credibility,

free

dom

of

expression

and

interaction

w

ith

the audience.

As

part

of

this

commitm

ent,

the

Corp

orate

S

ocial

Re

sponsibility

Policy

proposes

different

forms

of

engagement that

allow the com

pany to h

ave a pos

itive impact on th

e development

of society.

Sustainability

is a

t

the c

ore

of

the C

ompany’s

daily

acti

ons and

all the

business

un

its and

areas

of

the

Group focus on four l

ines of action:

•

Creation of responsib

le contents

•

Sustainable managem

ent acr

oss all business units.

•

Transparent commun

ication

•

Promotion of divers

ity

7.2.

VALUE

CREATION MOD

EL AND FRAM

EWORK OF T

HE INTEGRATED RE

PORT

The

follow

ing

infographic s

hows G

rupo C

larín’s v

alue

creation m

odel

created

in a

ccordance w

ith “

The

International <IR> Fr

amework

” developed by the Internati

onal Integrated

Reporting Counci

l (IIRC).

1

This

integrated

reporting

framework

es

tablishes

the

six

cap

itals

a

pproach

based

on

which

the

organization

can

c

reate

value

over

the

short,

medium,

and

long

term.

These

c

apitals

are:

Financial,

Manufactured,

Intellectual,

Human,

Soc

ial

and

Re

lationship,

a

nd

Natural.

T

he

value

c

reation

mode

l

shows

how

the

Company

g

enerat

es

value

for

its

audiences

through

assets

and

inputs

and

manag

ed

activities

and

topics.

It

a

lso

pres

ents

the

relationsh

ip

with

and

contribut

ion

to

the

United

Nat

ions

Sustainable Developme

nt Goals (SDGs).

MODEL FOR THE CREATION, PRESERVATION OR EROSION OF VALUE OVER THE LONG TERM

1

Version released

in January 2021.

29

Value

Creation

Process

Capitals of the Integrated Reporting Framework

Financial

Manufactured

Intellectual

Human

Social and

Relationship

Natural

Inputs

Assets and

inputs of the

organization

Equity capital.

Investments.

Net Income

from Prior

Years.

Printing plant

s:

Zepita in Capital

Federal (35,000

m

2

) and AGL in

Santa Fe (3,000

m

2

).

Presence in 19

provinces of the

country.

Television

studios.

Multiplatform

Content Center.

Cúspide’s

warehouse

(3,200 m

2

).

Brand

credibility.

Editorial

Independence

Content

quality.

Ethical

Standards and

Editorial

Guidelines.

Freedom of

Expression.

Innovation,

convergence

and

technology.

Role of the

gender editor.

Professionals,

journalists and

correspondents

.

Employer

brand.

Self-

management

platform.

Committees:

Diversity;

Wages and

contributions.

Benefits;

Hygiene and

Safety; Social

Observatory.

Sustainability

Strategy.

Fundación Noble.

Private social

investment

strategy.

Suppliers.

Alliances with

civil

society

organizations.

Readers and

audience.

Customer bene

fit

programs.

Diario Clarín’s

Environmental

Management

System.

Production

Inputs and

office

supplies.

Water.

Fuels and

electrical

energy.

Activities

Management

of the most

relevant

topics to the

business and

to

stakeholders

Reference:

Material

Topics under

the

Materiality

Assessment

Revenues.

Costs.

Investments in

new

businesses.

Transparency.

Accountability.

Editorial

Independence

Ethics and

Integrity.

Printing at

plants.

Production and

distribution of

books.

Transmission of

broadcast

television

channels and

radio.

Boost to digital

subscriptions.

Opening of new

branches,

offices and

franchises.

Logistics

services.

Creation of

responsible

content

(journalism,

fiction and

entertainment)

.

Freedom of

Expression.

Responsible

Dissemination

of Contents.

Vulnerable

Audiences:

Accessibility

and

protection.

Creation of

content with

social and

environmental

contribution.

Incorporation

of new

technologies.

Promotion of

Public Debate

and Civic

Involvement.

Interaction with

the Audience.

Ideological

Diversity.

Promotion of

Journalistic

Excellence.

Generation of

Employment.

Training and

Professional

Development

for Employees.

Gender

Diversity.

People with

Disabilities.

Age Diversity.

Benefit

Program.

Internal Opinion

Survey

Management of

employee

health and

safety.

Media Literacy.

Dissemination of

public service

ads

campaigns.

Contribution to

Education and

Culture.

Volunteer progra

m.

Actions in alliance

s

with CSOs.

Promotion of

responsible

adv

ertising in the

value chain.

Customer and

audience loyalt

y

initiatives.

Customer Pri

vacy.

Responsible

management

of materials.

Paper

recovery and

recycling

process.

Energy

Efficiency.

Raising

awareness on

environmental

protection.

Creation of

Value

2021 Results

and

performance

Profit of

$1,064.7

million

$ 40,149.3

million in net

sales.

$ 6,239.9

million in

adjusted

EBITDA.

$1,690.8

million total

financial debt

+430,000 digital

subscriptions to

Diario Clarín,

15,000 since the

launch of Los

Andes and

71,887 of La

Voz del Interior.

27,572 hours o

f

entertainment.

3,074

hours of

fiction.

28,014 hours o

f

news.

Content

created

together with

our audiences.

Promotion of

freedom of

expression.

Contribution to

public debate.

Training

programs.

Recognitions

from ADEPA,

FOPEA, Lola

Mora, Martín

Fierro,

4,519

employees.

40,688.5 hours

of training.

Embassy of

Peace Award to

TyC Sports.

Fundación

Avina Award for

the Resilient

Cities Regional

Initiative and

the South

American

Journalism

Award for

Awareness

campaigns and

free access arti

cles

on the COVID-

19

pandemic.

Members of the

Latin American

Information

Alliance (ILA).

99,200 subscriber

s

to Club La Vo

z.

563,943 teacher

s

trained with the

program “

Los

Medios de

Comunicación en

17,427.31

tons of CO

2

equivalent

emissions

(scope 1 and

2)

42.30

megaliters of

discharges.

808.78 tons of

non

-revalued

waste.

142.03 tons of

recycled or

donated

paper.

30

Accenture,

Eikon, INMA,

Aconcagua,

and at the

Conference of

Sports

Journalism of

Instituto

Mariano

Moreno.

Migration to La

Voz del Interior.

la Educación

”

delivered by

Fundación Noble

since the beginn

ing

of the progra

m.

3,701 active

suppliers.

100% suppliers

committed to

sustainability.

Contribution

Leadership in the Argentine media industry.

Contribution to the Sustainable Development Goals

–

2030 UN Agenda:

7.3.

INDE

PENDENCE, T

RANSPAR

ENCY, AND

INTERNAT

IONAL GUIDELINE

S

Editorial independence is at the

core of Grupo Clarín’s activities. It

is essential to guarantee freedom in

the

exercise

of

th

e

journalis

tic

role

and

to

prom

ote

the

s

trengthening

of

Argentine

democracy.

We

undertake

edit

orial

indepe

ndence

as

a

responsi

bili

ty

to

exerc

ise

and

guarantee

rig

hts

and

a co

ndition

required to ensure s

ustainability from th

e organization'

s standpoint.

The Group implements a s

eries of me

asures conducive to unc

onditioned reportin

g. First, Grupo Clarín

has a

diversity of revenue sources

. In

addition, the administrative and editorial functions are

conducte

d

separately

to

avoid

c

onflicts

of

int

erest

in

the

cre

ation

of

contents.

Each

of

its

media

m

akes

a

firm

distinction

bet

ween

advert

ising

a

nd

edit

orial

cont

ent.

To

such

end

,

there

is

a

s

pecialized

team

that

manages

sponsore

d c

ontents

and

oversees t

hat

the

s

ponsor

is

mentio

ned

in

the

corresponding

news

reports.

For

examp

le,

on

th

e

Clarín.co

m

homepa

ge

ther

e

is

a

s

ection

called

Brand

Studio,

and

sponsors

are c

ommercially

tagged

in

social

med

ia

posts.

In

this

way,

the

reader

ca

n

simply

visualize

that

th

is is

a paid collaboration.

The Gr

oup h

as bee

n l

isted

on

the st

ock

exchanges

in

Buenos

A

ires

and

London f

or

13 y

ears

and t

his

encourages

it

to

continuous

ly

focus

on

r

eporting

tr

ansparent

corpor

ate,

economic,

social,

a

nd

environmental

information.

At

the

local

level,

the

Com

pany

presents

on

an

annu

al

basis

the

An

nual

Report

and the

Fin

ancial S

tatem

ents,

which include

the

Code of

Corporat

e

Governance required

by

the

Comisión

Nac

ional

de

Valores

(A

rgentine

Securities

C

ommissi

on,

CNV,

f

or

its

Spanish

acronym).

Since

2015,

the

Group

h

as

published

its

Annual

Sust

ainability

Report.

It

is

the

o

nly

journalistic

company

in

Argentina

to

do

so,

leading

the

way

tow

ards

transpar

ency

and

sustainabi

lity

in

the

s

ec

tor.

With

this

commitment a

nd following

best prac

tices

in accountab

ility at the

global

level, for

the first

time

this year

both documents were i

ntegrated

into this single public

ation called “Integrate

d Annual Report”

.

In

order

to

standardize

the

reporti

ng

on

its

c

orporate,

social

and

environmental

performa

nce

and

to

show

its

contribution

t

o

sustainable

development

in

a

transparent

and

accurate

manner,

the

Group

follows various intern

ational guidelines:

a.

“The

Interna

tional

<IR>

Framework”

developed

by

the

International

Integrated

Reporting

Cou

ncil

(IIRC)

for the preparat

ion of the Integrated

Annual Rep

ort.

b.

The Global Reporting Ini

tiative (GRI) s

tandards.

c.

The

content

of

this

report

was

subject

to a

mat

eriality

as

sessment

follow

ing t

he

rec

ommendation

of

international

standards

to

identify

an

d

prioritize

the

sustainability

topics

t

hat

are

m

ost

relevant

and significant to our

business strategy and to

our stake

holders

.

d.

It presents

its contri

bution t

o the

ful

fillment

of the Un

ited Nat

ions Susta

inable Dev

elopment Goa

ls

(SDGs).

31

e.

The Company has

remained com

mitted to the

United Nati

ons Global Comp

act and rep

orts on the

progress made

concer

ning the

fulfillmen

t

of the

10 guiding

pr

inciples

on human

rights, labor ri

ghts,

the environment, and a

nti-c

orruption practices.

f.

The

Company

adopts

the

princip

les

and

guidelines

established

by

the

I

SO

26000

:2010

International Social R

esponsibility Standard.

All the inform

ation is

availa

ble on the we

bsites of gr

upoclari

n.com and of

the CNV

. The Comp

any also

makes available d

ifferent channels f

or communication

and interaction w

ith our stakeholders.

7.4.

DIALO

G AND ALLIANCE

S

Grupo Clarín

also p

articipates

in national

and

international

initiatives

and spaces

for

dialog to

promote

sustainable

develo

pment

and

corporat

e

transparency.

They

include:

Argentine

In

stitute

f

or

Business

Development

(IDE

A),

Pacto

G

lobal

Argenti

na

(Argentina

Gl

obal

Compact),

C

onsejo

Empresar

io

Argentino

para

el

D

esarrollo

Sost

enible

(Argentin

e

Business

Counc

il

for

Sustai

nable

Developmen

t,

CEADS),

Instituto

Argentino

de

RSE

(C

SR

Argent

ine

Institute),

Red

de

Empres

as

por

la

Diversid

ad

(Network

of

Companies

For

Diversity)

of

Univers

idad

Di

Te

lla,

Grupo

de

Fundaciones

y

Empresas

(Group

of F

oundations

and

Com

panies,

GDFE),

Re

d

de

Empresas

contra

el Trabajo

Infant

il

(Network

of

Companies against

C

hild

Labor)

of

the

Argent

ine

Ministry

of

Labor, Employment

and

Social Security,

Consejo Publicitario A

rgent

ino (CPA), Me

sa de

D

ivers

idad Empresarial de

Instituto Nacional

con

tra

del

Discriminación,

Xe

nofobia

y

el

Racismo

(

Business

Div

ersity

Council

of

the

Nati

onal

Institute

a

gainst

Discrimination, Racism

and Xenophob

ia).

8.

RESPONSIB

LE CREATION AND D

ISTRIBUTION

OF CONTENTS

8.1.

ETHIC

S AND EDITORI

AL GUIDELIN

ES

Grupo

Clarín

has

severa

l

ethical

manuals

and

ed

itorial

guidelines

that

direct

the

daily

work

of

its

journalists

and

r

eflect

its

main

journa

listic

va

lues:

Profess

ionalism,

s

earch

for

tr

uth,

r

espect,

independence, qua

lity, rigor, and r

esponsibility.

These

d

ocuments

ensure

compliance

wi

th

ethical

standar

ds

in

all

the

Group's

med

ia

and

include:

Journalistic

style

ma

nual

in

the

newspaper

C

larín,

La

Voz

del

Interi

or

and

Radi

o

Mitre;

we

b

content

practices

ma

nual

in

Clarín;

guide

for

the

jo

urn

alistic

work

in

social

med

ia

in

Clarín

and

La

Voz

d

el

Interior, wording f

or outside

broadcast units

in La Voz del Int

erior; and a

decalogue of

operation in

Los

Andes.

The

Group

implements

specific

guidelines

to

address

topics

freedo

m

of

expression,

search

for pluralism, verification of i

nfor

mation, preservation of the

identity of journalistic sources, protection

of

children

a

nd

a

dolescents

in

the

informative

c

ontext,

protection

of

witnes

ses

and

ac

cusers,

prohibition

of

explicit

imag

es

of

v

iolent

s

ituations

and

bu

llying,

prior

itization

of

the

institutio

nal

order

in

c

ase

of

soc

ial

turmoil,

and

c

ooperation

in

th

e

s

earch

for

people

and

visibility

of

aid

services

,

in

co

mpliance

with

effective

legisla

tion.

The

Group

al

ways

ensures

the

p

rivacy

of

sourc

es.

In

audiovisual

terms,

o

n

all

platforms,

different

technical

resources

are

used

if a

n intervi

ewee

requires

protec

tion (blurred

ima

ges,

voice deformation, etc

.).

In

a

ddition,

the

newspapers

Clarín,

L

os

Andes

and

La

V

oz

del

I

nterior,

as

well

as

the

webs

ite

TN

.com.ar,

adhere

to

the

D

ecalogue

of

the

Argentine

Press

of

the

Ass

ociation

of

Arge

ntine

Journalistic

Entities

(ADEPA),

and

th

e

Letter

of

As

pirations

of

the

Int

e

r

American

Press

Association

(IAPA).

Th

e

news

director

o

f

La

Voz

del

Interior

chairs

I

APA’s

Committ

ee

o

n

Freedom

of

the

Pres

s

and

Inf

ormation,

engaged

in

ensuri

ng

t

he

saf

eguarding

of

these principles

in

the

continent.

In

addition,

we

have

an

active

participation

in

the

other

press

associations

that

are

part

of

Gr

upo

Clarín

(Argentine

Association

of

Broadcasters

(ATA),

Argentine

Association

of

Advertising

(AAP),

Argent

ine

Asso

ciation

of

Mark

eting

(AMM),

Arge

ntine

Direct

and

I

nteractive

Marketing

As

sociation

(AMDIA),

Argentine

Association

of

Private Broadcasters

(ARPA), Association

of Media

Professionals

(APM), Argentine Chamber

of Media

32

Agencies

(C

AAM),

Ar

gentine

Chamber

of

Advertiser

s

(CAA),

Argenti

ne

Cha

mber

of

E

-Commerc

e

(CACE),

Interac

tive

Advert

ising

Bureau

(I

AB),

M

obile

Marketing

Association

(MMA),

and

International

Broadcasting

Association

(AIR).On

the

other

hand,

it

s

hould

be

noted

that

since

2020

eltrece

an

d

TN

have

joined

the

Lat

in

Ameri

can

Information

Alliance

(AIL).

Formed

by

more

than

20

leading

T

V

n

etworks

in Latin

America

and

the

Caribbean

that

share

the i

deal of

commitm

ent to

infor

mation

and trut

h, tod

ay

it

is the

c

ontinent's

lea

ding

information organization.

Being a

memb

er

of

the Alliance

is

vital for

ensuri

ng

a

broad

coverage

in

the

re

gion

in

times

of

pandemic

and

allows

eltrece

and

TN

to

work

side

by

side

with their Latin America

n peers.

During

20

21,

meetings

wer

e

held

w

ith

ed

itors

and

the

different

areas

of

the

bus

iness

units

that

make

up

the Group to

continue working on the

approach to

the

se guidelines. In

a vertiginous and

chal

lenging

information

context

marke

d

by

the

second

year

of

the

CO

VID-

19

pandemic,

th

e

focus

remained

on

verifying

information.

Screening

proc

esses

were

streamlined

to

preve

nt

t

ampering

or

being

v

ictims

of

fake news, and th

us avoid confusin

g audiences on su

ch a sensitive iss

ue as health.

We

added

more

spec

ialists

to

the

Adv

isory

Council

on

Health,

created

by

th

e

newsc

asts

eltrece

and

TN

in

202

0,

to

ensure

a

co

mmitment

to

disseminate

clear,

respo

nsible

and

transparent

in

format

ion

to

society.

It

continued

to

verify

and

contextualize

the

informat

ion,

wit

h

differe

nt

typ

es

of

approach

an

d

points

of

view,

and

to

interview

hea

lth

a

uthorities,

prom

inent

phys

icians

specialized

in

infectious

dise

ase

and other

medica

l s

pecialties.

This council p

layed

a

key

role in

identifyi

ng usef

ul,

accurate,

and t

imely

information to contrib

ute to public health.

The

Task

Force

of

Artear’s

Multipl

atform

Content

Cen

ter

handled

the

informat

ion

received

minute

by

minute,

to

check

it

with

s

pec

ialists

and

experts,

ens

uring

that

t

he

audience

received

accurate

and

relevant data. We c

ontinued w

ith the commun

ication c

ampaign #Fijate

EnLaVoz against th

e fake news

the

COVID-19

pandemic.

We

lau

nched

the

c

ampaign

#

ActitudParaCuidarnos

under

the

motto

“Let’s be responsible,

not the ones respons

ible” to raise awaren

ess about the ca

re and protocols to

be

met

i

n

the

context of

a

pandemic. Los

And

es

led

the

campa

ign

“

Do

not

bel

ieve

i

n

rumors. Always

inform

yourself in your trusted

media” in conj

unction wit

h other mem

bers of ADEPA.

At all times, the ident

ity of persons with CO

VID

-19 was pr

otected and per

manent contact w

as

maintained

with

heal

th

a

uthorities

to

re

port

on

the

pa

ndemic's

develop

ments,

protocols

and

act

ions

taken. With

the comm

itment to

keep th

e

audience

informed,

Clarín,

La Voz

del Int

erior and

Los

Andes

continued to

grant

free

access

to co

ntent

linked t

o the

Coronav

irus ta

g as

a s

ervice to

the

community,

and enhanced the use o

f newsletters

to keep subscribers

informed.

8.2.

DIGITA

L PLATFORMS A

ND

TECHNOLOGY

During

2021,

we

cont

inued

to

enhanc

e

the

synergy

be

tween

tradit

ional

media

and

te

chnology

platforms,

expanding

the

r

each

of

d

igital

audienc

es

and

off

ering

a

broad

multiplatform

cov

erage

with

nov

el

formats. To this end, tra

ining our t

eams was ke

y.

We

enhanced the

Com

pany's presence

in

the eight

s

ocial

media seeking

to

rea

ch the

y

ounger

audiences:

Fac

ebook,

Twitter,

Ins

tagram,

YouTube,

TikTok,

Linke

dIn,

T

elegram,

and

Spot

ify.

With

more than 6 million fol

lowers, Facebook con

tinued to b

e the channe

l with th

e largest commu

nity.

Diario

Clarín

migrated

to

t

he

Au

th0

platform

to

o

ptimize

the

technology

and

user

registration

process.

In

ad

dition,

it

redesigne

d

its

website

to

improv

e

u

pload

spee

d

and

generate

a

value

proposition

for

digital

subscription.

And

there

was

a

permanent

section

with

updated

statistics,

reports

and

ne

ws

related to coronav

irus.

TN's

YouTube

channel

was

Argentina's

f

irst

news

channel

to

reach

two

million

subscr

ibers,

consolidating

its

leadership

in

that

platform

a

nd

becomi

ng

the

c

o

untry's

larg

est

new

s

community.

During

the year, it reached more

than 470 mi

llion views.

33

To

expand

the

content

prod

uction

an

d

istribution

strategy

and

attract

younger

audiences,

TN l

aunche

d

three programs o

n YouTub

e, Twitch and Fac

ebook: “

A

Lo Grandi

”

, remotely

hosted and se

lf

-mana

ged

by

Jimena

Grandinetti,

through

a

camera

and

software

operated

by

herself.

It

is

a

format

similar

to

a

home

streaming

p

latform.

“

Retro

Futuro

”,

hosted

by

Jayson

Mane

and “

Si llegast

e

hasta

acá

”,

h

osted

by

Fernand

o

Mo

linero

and

Guido

Mart

inez,

are

aire

d

fr

om

the

multiplatform

news

room

w

ith

a

mix

of

broadcasting.

In

other

words,

they

have

professional

cameras,

a

small

s

tudio

and

a

producer

that

operates the switcher.

Thus,

it

se

eks

to

reac

h

age

segments

and

au

diences

t

hat

TN

does n

ot

usually

reach

on

its trad

itional

platforms

on

T

V

or

on

the

web,

s

eeking

to

g

enerate

content

in

an

innovative

way.

“

A

Lo

Gran

di”

addresses topics beyo

nd the more traditiona

l news agenda suc

h as sexuality, astrology,

and customs

;

“Retro

Fut

u

ro

”

focuses

on

the

t

echnology

associated

with

every

day

life;

and

“

Si

llegaste

hast

a

acá

”

delves into the content o

ffered on televisi

on.

Eltrece

strengthened

the

area

of

Videolab,

which

produces

high

-qua

lity

audiovisual

pieces

for

the

different screens whe

re news

is

broa

dcast.

Eldoce

appointed

a

new

di

gital

contents

manager

and

expanded

the

digital

equip

ment.

It

focused

on

the

produc

tion

of

exc

lusive

contents

for

digital

platform

s

(YouTube

a

nd

I

nstagram) an

d

the

first

program

was

broadcast

exc

lusively

by

str

eaming

from

Córd

oba.

On

the

occasion

o

f

the

s

ixth

an

niversary

of

ElDoce.tv, it made special reports ab

out stories that we

re born in the web and had prov

incial and even

national

repercussion.

Sp

ecial

pro

ductions on

stories

from

remot

e

locations in

Córdob

a

w

ere

present

ed

in

the

sec

tion

“Life

in

the

c

ountryside”.

Dur

ing

2021,

there

was

also

a

prominent

section

with

all

the

information related

to COVID

-

19.

La

Voz

del

Interior

enh

anced

the

Digital

Firs

t

m

odel

to

create

a

customer

-centric

experience

and

c

reated

the

new

Digit

al

Co

mmunities

team.

It

launched

the

new

ARC

news

publisher,

which

is

part

of

a

Washington Post

t

echnology

toolkit to

innovat

e an

d improve

digital platforms. Under

the

project

Google

Showcase,

the

company

d

eveloped

visu

al

stories

d

uring

the

ye

ar

using

t

he

MakeSt

ories

app,

integrated

into

t

he

site

Lavoz.c

om.ar.

La

Voz

de

l

Interior

enabled

a

ccess

to

the

digital

version

for

all

th

e

subscribers

of

the

print

edition.

With all

these

initiatives,

there

was

a

significant

growth

in

d

igital

subscr

iptions

(83%),

also driven by a strong

boost in corpor

ate subscription

s.

Los

Andes

delivered

train

ing

to

journalists

an

d

editors

on

SEO

(Se

arch

Engine

Optimi

zation),

and

it

developed

a

plan

t

o

engag

e

audiences:

A

proj

ect

con

sisting

of

newsletters

targeted

at

unsubsc

ribed

recurring

users,

whic

h

was

nom

inated

a

nd

reco

gnized

by

Face

book

and

INMA

(Internatio

nal

News

Media Association).

Radio

Mitre continued

to del

iver trai

ning on

transformation and

new

technologies applied

t

o the

dissemination

of

the

progra

ms,

it

renewe

d

the

w

ebsite

la100.com

.ar,

and

consolidated

the

cr

eation

of

new

con

tent

focus

ed

on

au

diovisual

topics.

It

c

reated

t

he

s

pecial

sections

“Corona

viru

s

”

and

“Vacc

ines”

to

keep

us

ers

inform

ed

of

the

latest

developments.

In

addition,

Radio

Mitre

consolidate

d

La

10

0

Live,

with

24

hours

of

live

tr

ansmiss

ion

via

its

official

Yo

uTube

chann

el,

using

cutting

-edge

tools

s

uch

as

Restream

.

TyCSports

successful

ly

implemented

a

new

version

of

the

Frontend

of

its

website

to

improve

the

interaction

with

users.

Together

with

a

new

audience

strategy,

it

led

to an

average gr

owth

of

approximately 89% i

n users, 42% in ses

sions, and 51% in vi

ewed pages.

8.3.

OUT

STANDING INV

ESTIGATIONS AND CO

NTENTS

During

2021,

the

Company

enhanced

the

coverage

of

the

pandemic,

with

a

focus

on

the

vacci

nation

campaign and the gra

dual return t

o the “new normal.”

34

The

investigat

ion made

by the journalists

Federico Mayol

and Ignacio

O

rte

lli about

the case

of the V

IPs

with

government

connections

who

received

v

accines

a

head

of

the

general

population

wo

n

the

firs

t

place

in

the

category

Political

Journal

ism

of

the

awards

granted

by

A

DEPA.

The

investigation

revealed

h

ow

officials and fr

iends

of the g

overning party

had b

een vac

cinated in a

secret

operation

at the M

inistry

of

Health while much of the

Argentine

population had not even

received the first dose. Clarín's scoop had

a high political impact. After the dissemination of the news, the then Minister of Health Ginés Gonzalez

García resigned.

It is also wor

th mentio

ning the

special report

made by

Diario Clarí

n about

social w

elfare progra

ms and

how to ge

t out

of the

maze

in

Argentina w

ithout a

job.

And Clarí

n’s spec

ial report

“Coronavirus,

a year

that changed us forev

er”.

On

the

o

ther

h

and,

the

journalistic

investigation

a

bout

the

p

urchases

made

by

the

provincial

governments

without

the

mandatory

te

nder

during

the

pandemic,

carried

out

by

the

journalists

of

La

Voz

del

I

nterior

Edgar

do

Lit

vinoff

and

Sergio

Carreras,

won

t

he

most

important

pri

ze

for

an

Argent

ine

journalistic

investigation

at

the

Forum

of

Argentine

Journa

lism

(

FOPEA).

And

Mariana

Otero,

of

the

Section Citizens, won the

Gabo Foundation's

scholarship for journalistic production

on migration with a

focus

on

sustainable

development, as

p

art

of

t

he award

organize

d

by

the

regional office

of the

International Organizat

ion for Migrati

on for South Ame

rica.

In addition, it he

ld the first e

dition of the c

ycle “The Nex

t World: keys

to the

future”, in which eco

nomic,

business, third sector, and

media leaders discuss

ed the changes faced by society

. The cycle was held

in

a virtual

form

at

and

w

as broadcast

free

of

charge on

Clarín's website,

s

ocial

media, and

in

the printed

edition of the newsp

aper.

Eltrece

ma

de

a

n

i

nternational

coverage

with

a

netw

ork

of

more

than

2

0

journalists

who

made

special

reports

from

the

United

States,

Ita

ly,

S

pain,

England,

Brazil,

and

Chile,

a

mong

others.

In

add

ition,

on

February

1

7,

L

uciana

Geuna

a

nd

Diego

Le

uco

b

e

came

the

new

hosts

o

f

th

e

legendary

n

ewscast

Telenoche.

At

Eldoce,

Claudio

Fant

ini,

a

journalist

sp

ecialized

in

internat

ional

politics,

interv

iewed

experts

and

people who were born in C

órdoba and curre

ntly live in different countries o

f the world, and some

of his

columns got record h

igh views in the

YouTube channel.

On the

first ann

iversary

of

Marad

ona's d

eath,

the

docuweb

"M

aradona's

First

De

ath"

was

launched.

It

as

a

12

-minut

e

documentar

y,

hosted

by

Nelson

Cas

tro,

that

pre

miered

in

Tn.com

an

d

was

subsequent

ly

aired

in

Telen

oche

and Tn

Central.

H

e

interviewe

d

Dr. Jorge

Ro

mero in

Uru

guay, a

doctor who

h

ad just

graduated in January

2000

and

had saved Maradona's life at

t

hat time, and

Dr. Carlos Alvarez, the

first

cardiologist

that

diagnosed

Maradona’s

heart

c

ondition

and

tre

ated

hi

m

until

his

death.

Both

doctors

spoke for the first time for

an Argent

ine medium.

Other

notable

cov

erage

included

t

he

denunciation

of

a

network

of

midwives

that

commercial

ized

b

abi

es;

and

th

e

fundamental

ro

le

that

Venezuel

an

citizens

pl

ay

in

the

fight

agains

t

the

pandem

ic

and

in

the

economies of Latin A

merican countries.

In Radio Mitre, one of t

he highlights was a s

pecial report on the occ

asion of the 2

0

th

anniversary of the

attack to

the Tw

in T

owers.

It was

a

joint

work

between

the are

as of

artistic

produc

tion a

nd audiov

isual

contents,

which

was

aired

toget

her

w

ith

a

sp

ecial

re

port

hosted by

th

e

j

ournalists

Jorge

Fernández Díaz

and

Miguel

Wiñazki

on

the

wo

rld

news

of

the

last

two

decades

from

a

geopolitical,

social,

eco

nomic,

religious,

a

nd

even

cu

ltural

point

of

v

iew.

In

ad

dition,

trailers

were

published

in

soc

ial

media,

which

generated great expect

ations amo

ng the followers

.

8.4.

INTERACTIO

N WITH AUD

IENCES AN

D READ

ERS

35

With

a

long

track

record

of

engagement

with

its

audie

nces

an

d

readers,

the

Group

fosters

spaces

for

the participation of the audience

that promote freedom of expression, respect for diversity, and

pluralism.

We interact with our audiences on a daily basis, be it through

soc

ial media, live surveys, emails, letters

from

readers,

or

teleph

one

calls.

As

t

he

main

or

s

econdary

source,

we

conduct

a

v

erification

process

to avoid the dissem

ination of fake news.

During

2021,

it

co

ntinued

with

the

w

eekly

edition

of

Clarín’s

newsletter

“

Nuestr

a

palabra

”

,

which

reaches

a

base

of

20

thousand

su

bsc

ribers

and

addresses

the

main

news

th

e

Group's

media

an

d

subsidiaries. The news

letter No. 492 was

published in the

last week of the year.

The

company

carried

out

a

series

of

w

eekly

virtu

al

interviews

with

intellectuals

and

guests

from

Argentina

and

the

world,

in

the

form

o

f “di

alogs”

available

for

registered

users

and

s

ubscribers.

It a

lso

continued w

ith the

“comme

nts” s

ection in

the sp

ecial r

eports a

bout

politics f

or rea

ders to

express

their

views

on

t

he

subjec

t.

Wit

hin

the

framework

of

the 25-year

an

niversary

of

LaVoz.c

om.ar,

s

everal

initiatives

were

carrie

d

out;

and

the ne

wsp

aper

Los

Andes continued

with

t

he

section “

Histori

as

de

vida

”

which was

consolidated

during 2021

with the

publicatio

n of stories

of peop

le who o

vercame dif

ficulties

and stories about fam

ily and social efforts

.

The Company c

ontinued t

o promot

e through T

N.com.ar

and social

media the

generation

of comme

nts

in

public interest

news

and

then

share them

in

the different

se

gments of

the

newscas

ts.

When reporting

the news,

the

hosts

mentio

n the

comments

rec

eived,

making

it cle

ar that

thos

e c

omments

were ma

de

by

the au

die

nce.

The most

r

epresentative comments

are

highlighte

d,

through spec

ific tools

and graphic

support generated for t

hat purpose.

During 2021,

Dr. Nelson

Castro,

in the sec

tion “

El c

onsultorio de

Nelson

”

broadca

st by

Telenoche and

reproduced

on

YouTube,

responded

t

o

all

t

he

in

quiries

from

t

he

aud

ience

about

COVID

-19.

At

t

he

same

time,

the

program

Arri

ba

Córdoba

aired

by

Eldoce

maintained

a

live

interaction

with

t

he

audience,

showing

p

osts

mad

e

by

TV

viewers

on

social

media.

Every

day,

th

e

secti

on

“

Historias

que

Suman

”

presented

inspiring

and

tou

ching

stories,

wh

ich

generated

a

chain

reaction

of

s

olidarity.

“

El

Show

de

l

Lagarto

”,

a

daily

morn

ing

magaz

ine

where

neighbors

present

the

ir

problems,

c

oncerns

and

ventures

and get help thanks to the dissemination, offered the s

ections the “Neighbor's line”

(via telephone) and

the “Neighbor's corner”

(physical space).

Radio

La

1

00

contin

ued

to

receive

specialists

from

different

areas

to

give

informa

tion

to

the

audience

from

the perspective of recognized professionals in

t

heir fields.

In the program “

D

erecho en

Zapati

llas

”,

attorney

Sergio

Mohadeb

prov

ided

tools

to

address

lega

l

issues

an

d

respo

nds

to

inqu

iries

from

th

e

audience.

R

omina

Pereiro,

a

nutritio

nist,

h

eld

a

weekly

column

in

t

he

program

Sarasa

to

keep

the

population

informed

a

bout

healthy

eating a

nd

nutrition

habits,

and

to

ans

wer

que

stions fr

om

listeners

.

And

Dr.

G

uillermo

Capuya addressed

healt

h-related

is

sues

in

th

e

program

Atardecer

de

un

Día

Agitado

and in audiovisual caps

ules uploaded to th

e YouTube channel.

In ad

dition,

with

a

strong

comm

itment t

o

the

development

of loc

al content,

Gru

po

Clarín

seeks

to

give

voice

to

its

c

ommunities

thr

ough

reg

ional

supplem

ents,

sites,

bro

adcast

TV

channels,

an

d

radio

stat

ions

throughout

the

country.

C

larín

p

ublishes

reg

ional

supp

lements

that

offer

con

tents

r

elated

to

30

locations

in the

surr

oundings areas of the City of Buenos Aires, focused on showing the identity and local issues

of

each city. In

addition, the Group ha

s two of

the most important regional

newspa

pers of Argentina,

La

Voz

del

Interior

in

the

province

of

Córdoba,

and

Los

An

des

in

th

e

province

of

Mend

oza.

It

also

has

broadcast

ch

annels

in

Buenos

Aires,

Bahía

Blanca,

a

nd

Córdob

a.

I

n

add

ition,

T

N

offers

nat

ionwide

coverage and is presen

t at significant even

ts that take place in ev

ery province of

Argentina.

The most important issues in all

the communit

ies of Argentina are

reflect

ed both by people interviewed

live

and by

the correspondents

of

Rad

io

Mitre all

over the

c

ountry: Mi

tre Córdoba,

Mitre

Mendoz

a,

Mitre

Santa

Fe,

Mitre

Rosario,

Mitre

Mar

del

Plata,

and

hu

ndreds

of

r

epeat

ers

in

Argentina.

In

2021

,

after

being

a

r

adio

repeater

for

Radio

Mitre

for

m

ore

than

15

years,

Mitre

Santa

Fe

(FM

99.3)

launched

for

36

the first

time

its

loca

l pro

gramming.

This

radio

station

launched

the

program

“

Hoy

por

Hoy

”,

hosted

by

the

reno

wned

journalist

Ju

an

Carl

os

del

Missier

and

two

local

j

ournalists,

Jesica

Yribas

and

Federico

Romagnoli, to inform a

nd enterta

in the inhabitants of

Santa Fe.

8.5.

SOCIAL CO

VERAGE

During

2021,

Grupo

C

larín

focused

all

the

journalist

ic

products

and

platform

s

on

str

engthening

the

vaccination

campaign,

cons

tantly

providing

v

aluable

informat

ion

to

th

e

audiences.

In

addition,

we

m

ade

an

extensive

coverage

of

the

eco

nomic

crisis

and

the

c

hallenges

faced

by

the

education

s

ystem,

especially the return of

children a

nd adolesc

ents to the classrooms.

The ed

itorial con

tent

of

Diario

Clarín’s

Society

sectio

n

prioritized

issues

the

health

situati

on,

the restr

ictions,

and

the

economic

consequences.

I

n a

ddition,

the

increase

in

violence

was

addres

sed

through chronicles

and testimonies.

Los Andes

’ Soc

iety sec

tion also

reinforced

its

purpose

to reflect

community

problems. A

team

developed

the

sp

ecial

mu

ltiplatform

rep

ort

“

Grito

e

n

el

campo

”

showing

the si

tuation

of

workers

in

the

vegetable

production

belt

of

the

surrounding

area

of

the

City

of

Mendoz

a,

with

proven

cases

of

labor

exploitation, especia

lly, of Bolivian citizens.

TN made an extensive coverage of the protest in Formosa for the return to Phase 1, the strictest stage

of

the Mandatory and

Preve

ntive Social

Isolation. And

the ordeal of

47 people with coronavirus

isolated

against their will by the

provincial gover

nment, without

hot water or heatin

g.

In

Telenoche,

Daniel

Malnatti

host

ed

a

section

in

which

he

show

ed

incredibl

e

stories

in

Argentina

.

As

was

th

e

case

of

the

c

losure

of

the

r

ural

s

chool

in

El

Turbio,

14

kilometers

away

fr

om

La

go

Puelo

in

Chubut, w

hich

led

many

vi

llagers

to

leave

because

their children

wer

e

left

without

educat

ion.

We

also

sought

to

s

how

the

r

ichness

of

Arge

ntina's

cultur

al

diversity.

The

journ

alist

travel

ed

to

Salta

to

show

how peopl

e live

in a

Wichi

c

ommunity,

with extre

me h

eat, withou

t light

or

water.

He a

lso staye

d with

a

Guarani community i

n the jungle to learn

about their customs an

d experienc

es.

Hosted

by

Pa

ula

Be

rni

nip,

“

El

último

r

incón

del

país

”

showed

st

ories

of

Ar

gentines

living

in

the

most

hostile

or

complicated

p

laces

of

the

country.

Stories

o

f

sacrifice,

of

overc

oming

and

also

of

isolation.

For

example,

the

sacrifice

of

living

an

d

working

in

t

he

middle

of

t

he

sn

ow

in

Varvarc

o,

a

town

in

Ne

uquén

of just 585 inhabitants w

here there is n

o m

obile teleph

ony or Internet

.

Radio Mi

tre had

tw

o

renowned doctors

as

stab

le

columnists: Dr.

Alberto

C

ormillot and

Dr. Daniel

López

Rosetti.

We

aired

a

s

pot,

p

romoting

c

are

a

nd

r

esponsibility

w

ith

each

other:

caring

for

oneself

to

care

for one another.

On the soc

ial media of

the radio

station La 1

00, in the

section “

Historias c

ompartidas

” Sergio L

apegüe

presented

a

cy

cle

consist

ing

of

fortnig

htly

vide

os

with

stories

of

life,

sacrifice,

and

lessons

t

hat

the

audience shares with him. TN conti

nue

d to

draw attention to multiple social problems in the

pro

gram of

“

Esta

es

mi

v

illa

”

in

TN,

hosted

by

Julio

Bazán

,

who

v

isit

ed

slums

and

shanty

t

owns

to

c

over

stori

es

about people that

overcame obstac

les in the cont

ext of extreme poverty

.

8.6.

PROMOT

ION OF DIVERSI

TY

In

2017,

Grupo

Clarín

adhered

to

the

Women's

Emp

owerment

Principles,

devel

oped

by

UN

Women

and the United Nations G

lobal Compac

t to guide bus

inesses in promot

ing this issue

.

Reinforcing

the

commitment

to

contribute

to

the

eradication

of

gender

inequa

lities

a

nd

to

create ge

nder

-

sensitive

co

ntent,

the

main

med

ia

of

the

Group

a

dhered

to

The

Step

it

U

p

for

Gender

Equality

Media

Compact from

UN

Women.

This initiat

ive brings

toge

th

er a broa

d coa

lition of

media

outlets from

every

region

to

ensure

wi

de

reac

h

and

robust

efforts

towards

women's

rights

and

gender

equ

ality.

The

37

Compact

functions as

an alliance

of media

org

anizations

committed to

playi

ng

a

n

active

role

in

promoting gender

issues within the fram

ework of the S

ustainable Developm

ent Goals.

As part

of th

is commit

ment,

the Gr

oup comm

itted itse

lf to

addressi

ng news

with

a

gender p

erspective,

adding more women

as journalistic sourc

es, and interv

iewing women lea

ders from differ

ent sectors.

Among

the

initiatives

carried

out,

of

part

icular

note

is

the

role

of

th

e

gender

editors,

who

provide

guidelines

to

address

news with

gender pe

rspect

ive

and

avoid

the

reproducti

on

of

stereotypes. In

2021,

the

j

ournalist

Mar

ina

Abiuso

was

appoi

nted

gen

der

editor

of

th

e

newsrooms

of

TN

and

eltrece.

S

he

became

the

first

person

to

hold this

position

in an

Argenti

ne

audiovisual

medi

a a

nd th

e s

econd

one

in

Grupo Clarín (in 2019

, Diario Clarín w

as a pioneer in Latin

America by appoi

nting Mariana Igles

ias).

The

Gover

nment

of

the

City

of

Buenos

A

ires

reco

gnized

Mari

na

A

biuso

w

ith

the

Lola

Mora

Award

for

her

work

as

gender

editor

t

ogether

with

t

wo

journ

alists

from

C

larín:

Mar

iana

Iglesias

and

Lucia

Merle

(photo

editor

of

C

larín).

Th

e

Lola

Mora

recogn

izes

those

who

sh

ow

a

positive

i

mage

of

wome

n

that

breaks with gender ster

eotypes and prom

otes equal o

pportunities and the

ir rights.

During

th

e

ye

ar,

M

ariana

Iglesias

and Ma

rina

A

biuso

p

articipated

in

the

first

network

of

Argentine

media

gender editors. It is an initia

tive of the United Nations P

opulation Fund (UNF

PA) that seeks to promote

the

r

ole

that

women

editors

play

in

the

m

ain

digital,

print,

televisio

n,

and

radio

media

o

utlets

in

the

country,

and

to

sy

stematize

collective

experiences

and

learning.

Cla

rín

sends

to

its

subsc

ribers

a

weekly

newsletter

developed

by

its

gender

ed

itor.

TN.co

m.ar

created

a

fixed

ad

hoc

section

where

ev

ery

Thursday the gender

editor publish

es a column addres

sing different t

opics.

In

addition

,

the Company

continued

to

foc

us

on

achievin

g

gen

der

parity

in

the

work

teams.

Durin

g

2021,

La

V

oz

del

Inter

ior

continued to

work on

the Project

50

-

50

to

achieve gender-equity in

sources following

UN

Women's

reco

mmendations.

Throu

gh

daily

monito

ring

and

monthly

dissemination

of

stat

istics,

w

e

work

with

the

Ge

nder

Task

Force

at

the

newsroom

to

disseminate

d

ata,

highlight

examples,

and

promote

the

improvement

of

this

index.

The

Gender

-Sensi

tive

Social

Media

Content

Management

Guide was

also

present

ed t

o the

entire

editorial

staff.

Radi

o Mitre

continued

to

apply

the

Style

Manual

that contemplates t

he gender perspective

and special attention is

drawn to wome

n's rights.

Eltrece

form

alized

and

promoted

consu

ltation

mechan

isms

for addressing

var

ious

coverage

issues

with

a

gender

perspective

,

and

specific

training

was

developed

for

professionals

in

v

arious

areas

(hosts,

journalists,

prod

ucers,

cam

era

operators

,

editors

,

etc.

archive

staff)

t

hrough

the

Spotlight

init

iative,

an

alliance between the

European Union and t

he UN to er

adicate gender

-based violence.

To

commemor

ate

the

I

nternational

Women's

Day

,

a

s

pecial

report

was

made

highlighting

five

women

who

pave

d

the

way

in

thei

r

fields

an

d

joined

others

in

fighting

for

equ

ity:

A

P

aralympic

swimmer,

a

transgender

teac

her,

a

Plus

Size

model,

a

young

deaf

feminist

,

and

a

r

obotics

sp

ecialist

talke

d

abo

ut

how they seek to chan

ge reality and generat

e opportun

ities.

Throughout

the

year,

the

aim

was

to

make

visi

ble

the

work

developed

by

women

academics,

inviting

specialists

to

write

stori

es

in

tn.c

om.ar.

F

or

exampl

e,

the

op-ed

by

G

uillermina

Tiramonti,

F

lacso

researcher

and

mem

ber

of

Club Político,

on educational

ag

ony,

the

future and

poli

tical

d

iscourse.

Thus,

the aim is to help eradic

ate everyday

social prejudices

that minimize the aca

demi

c

work of wome

n.

As

always,

in

all

our

p

latforms,

we

continued

to

d

isseminate

information

a

bout

the

serv

ices

av

ailable

:

144

for

victi

ms

of

ge

nder-b

ased

violence

a

nd

137

for

cas

es

of

gender

-based

violence

and

abuse.

I

n

addition, we

interv

iewed th

e women

wh

o

answer

the

calls

to

line 14

4 and

listen

to an

d sup

port victims

of gender-based vi

olence.

We also continued to se

ek to shed light on viol

ent contexts that pr

eceded actual situat

ions of violence,

in

order

to

a

lert

potential

victims

and

to

try

to

help

iden

tify

t

hese

s

cenarios.

Journalists

and

news

presenters are enco

uraged to pro

mote responsib

le consumption and d

ebate on eac

h of these topics.

38

Within

this

framework

,

specific

daily

cases

of

g

ender

violence

were

re

ported

to

shed

light

on

t

he

magnitude

of

th

is

dramatic

s

ituation,

and

c

ases

of

“celeb

rities”

to

show

that

gender

v

iolence

is

a

pro

blem

that can occur in any soc

ial stratum.

In

additio

n,

Clarín

and

the

Spotlight

Initiative

carri

ed

out,

for the

second consecutive

year,

the

campa

ign

“Gender

Obituaries”,

which

publishes

the

obituaries

of

the

victims

of

femicides

that

took

place

during

the

ye

ar,

t

o

bring

to

light

the

stories

behind

t

he

news.

On

the

occasion

of

#25N,

the

Day

for

the

Eradication

of

Violence

against

Wo

men,

La

Voz

del

Interior

carried

out

ac

t

ions

jointly

with

Colegio

Universitario de Peri

odismo.

In

addition,

throughout

the

year

and

w

ith

the

aim

of

s

howing

new

family

models,

the

stories

of

the

section

“

Somos

familia

”

in

TN.com.ar

continued

to

c

ontribute

to

spreading

t

he

struggles

of

sex

ual

mi

norities

for

the

ir

rights.

The

c

ompany

created

t

he

community

“

Todes

Nosotres

”,

which

celebra

tes

diversity and inclus

ion.

Coverages

a

lso

em

phasized

r

espect

for

sexual

diversi

ty.

On

June

28,

when

Pride

Day

is

c

elebrated

around

the

world

and

the

i

mportance

of

an

inclus

ive

and

egalitar

ian

society

is

being

r

eaffirmed,

the

Group's media

c

onducted multiplatform coverage to

bring to

light stories of

LG

BT people

and to

spread

their realities

and exp

ectations. Throu

ghout t

he day,

Clarín.co

m dedicated

a s

pecial s

ect

ion to p

ublish

special reports and int

erviews aimed

at promoting respect an

d fighting disc

rimination.

Under th

e s

logan “

What

are

you

proud

of

?” T

N diss

eminated

testimon

ies of

people who

succeed

ed

in

breaking

down

prejud

ices

and

live

their

id

entity

with

f

reedom.

Olé

rep

orted

stories

of

LGBT

ath

letes

from various sports

and it joined

the social

media campaign

#JugaConOrgu

llo, which seeks t

o

implement

m

easures

to

er

adicate

d

iscrimination

based

o

n

sex

ual

orientation

and

gend

er

iden

tity

in

sports. Also t

hrough

soc

ial med

ia, La

100

posted

informative

videos

an

d chang

ed its

logo

to

show t

he

colors of the rainbow.

On

the

other

hand,

during

2021,

we

contin

ued

to

diss

eminate

inspiring

stories,

s

uch

as

that

of

Silvia

Linari,

the

captain

of

the

A

rgentine

adapted

bas

k

etball

team;

and

cha

llenging

sit

uations

such

as

the

dramatic situati

on of fam

ilies waiting

to get vacc

ines

against coronavirus

for their c

hildren w

ith

disabilities. In

the program

Arriba Córdoba

,

a section was

created to address

the problem of

vulnerable

people, in many cas

es with disabilit

ies, to help them g

et assistance.

Finally,

Radio

La

10

0

produced

exc

lusive

audiovisual

content

for

special

d

ates

such

as

“World

AIDS

Day,”

where

testimon

ial

inte

rviews

were

conducted

to

p

eople

with

HIV

seekin

g

t

o

raise

awaren

ess

about

AIDS.

8.7.

CIVIC

INVOLVEMENT

AND PUBLIC DE

BATE

Debate

and

civil

i

nvolvement

are

fundamental

pillars

of

democracy.

In

order

to

p

romote

these

pillars,

the

journalist

ic

media

of

the

Group

ho

ld

debates

about

v

arious

topics,

covering

political,

econom

ic,

social,

education

al,

and

health

iss

ues,

among

others.

We

a

lways

seek

to

ensure

fre

edom

of

expres

sion,

provide

b

ackground an

d

factual info

r

mation,

and

ha

ve

a

multip

licity

of opinions

for audiences

to

generate their own pers

pectives.

Du

ring 2021, one of the focal points of the journalistic coverage was the congressiona

l election

s

with a

multi-platform journalistic production.

T

he eleven

candidates who

headed all

the lists for

deput

ies

in the

City

and

Province

of

Buenos

Aires

wer

e

intervi

e

wed

at

Clarín's

newsroom.

Each

candidate

answ

ered

a questionnaire

on their

own on the

issues

that it

would be

up to

them to le

gislate if

they took a

seat

in

Congress. Thus, the

electorate was abl

e to hear the v

iews of all candida

tes on equal terms.

Every day, until the elector

al ban, an interview was po

sted by Clarín.com, its c

hannel on YouTube and

social

media,

including

unp

ublished

material

and

the

behind

the

sc

enes o

f eac

h

interview.

In a

ddition,

the highlights were p

ublished in the printe

d edition of

the news

paper.

39

On

the

ot

her

hand,

La

V

oz

del

I

nterior

pub

lished

the

tax

returns

of

th

e

candidat

es

of

the

dif

ferent

pol

itical

parties

that

ran

i

n

Córdo

ba.

In

addition,

it

mon

itored

t

he

expen

diture

i

ncurred

in

election

campa

igns,

and

c

onducted

a

debate

of candidates

for

national

dep

uties

wit

h

st

udents

in

the

la

st

y

ear

of high

scho

ol

.

In a

ddition

to

provid

ing

extensive

covera

ge,

Los

Andes

joined

the

campaig

n for

the

implemen

tation

of

the Single Ballot tog

ether with Red

de Acción Polít

ica.

TN

also

held

cycl

es

of

interv

iews

w

ith

the

candid

ates,

wit

h

a

broad

mu

ltiplatform

production

that

culminated

in

TN’s

pr

ogram

“

A

d

os

voces

”,

which

o

nce

again

led

t

he

political

debate.

F

irst,

T

N

organized

and

aired

a

debate

in which

can

didates

for

deputies

for

the

C

ity of

Bu

en

os

Aires

were

able

to

discuss

their

propos

als.

A

we

ek

l

ater,

and

a

f

ew

days

bef

ore

the

con

gressional

elections,

candidates

for

the

representation

of

the

prov

ince

of

Buenos

Aires

met

for

the

first

time

to

h

old

a

debate.

Bo

th

debates

totaled

more than

10 hours

of

live broadcast

th

at

were followed

by

millions of

peopl

e

in

multiple screens

and

formats.

Each

debate

aired

in

TN rea

che

d

unusual audience

r

atings

for

c

able

televis

ion,

surpas

sing

by a wide margin al

l news signals and 4

of the 6 broad

cast television

c

hannels.

On

social

media

there

were

differe

nt

l

ive

broadcasts

and

sp

ecial

content

on

Fac

ebook,

I

nstagram,

Twitter,

Twitch,

and

TikTo

k

with

specific

producti

ons

for

each

of

t

he

platforms.

There

were

77,000

interactions

in

Faceb

ook

and

more

than

88,000

si

multaneous

concurr

ent

viewer

s

in

YouTube.

There

were 7 live broadcas

ts in Instagram throu

ghout the tra

nsmission.

In

addition,

with

the

aim

of

further

engaging

the

audience

in

the

debate,

the

content

offered

was

addressed

from

differe

nt

ang

les,

throug

h

rou

nd

ups

and

humor.

We

focused

on

using

accessible

approaches

to

c

omplex

iss

ues,

with

new

attractive

formats.

In

additio

n,

TN

was

present

in

rem

ote

locations

of

Argentina

where

logistics

are

more

complicated,

such

as

Mo

lulo,

a

moun

tain

vi

llage

4

0

kilometers from Tilcara, i

n the province of

Jujuy. Journalists accompanied the Army off

icers

who

had to

carry the ballot boxes

on a mule ride, t

housands of me

ters high.

Also,

co

mmemoratin

g

th

e

20

years

of

the

Argentine

c

risis

of

200

1,

a

n

exclusive

documentary

was

produced, with

testimonies

of the

protagonists

and an

unpublished

archive of

the

most traumatic

crisis

in Argentina. TN brought together the main political figures of

the debacle that the country experienced

two decades ago.

8.8.

ACCE

SSIBILITY AND

PROTECTIO

N OF VULNERA

BLE AUDIENCE

S

The

Group’s

audiov

isual

compa

nies

s

eek

to

ensure

that

all

the

aud

iences

can

have

acc

ess

to

their

contents through tech

nology. In this sense, e

ltrece uses

subtitling, audio descr

iption, audio description

interpretation, and s

ign language. In ad

dition, both eltr

ece and TyC Sports

offer closed capt

ion.

In

addition,

t

he

audiov

isual

cont

ent

shared

on

the

social

media

of

Cienradios

includes

written

descriptions to facilitate

access to the conte

nt without the need for a

udio.

At

the

same

time,

the

Company

focuses

on

ensuring

that

children

can

only

acce

ss

contents

that

are

suitable

for

their

age.

The

Group

complies

with

the

la

ws:

At

10

pm

w

e

s

how

a

safe

harbor

sign

and

include warnings provided

by the

National Institute of Fi

lm and Audiovisual Arts, INCAA,

for its S

panis

h

acronym, that state the

age

suitable for

vi

ewing contents, and we also include warnings when contents

are not suitable for c

hildren and adolescents,

among o

ther practices.

In

order

to

preve

nt

stigmatization,

w

e

avoid

conducting

interviews

to,

showing

images

of

or

revea

ling

the

identity

of

m

inors,

unl

ess

it

is

a

topic

that

promotes

positive

values.

In

addition,

close

-ups

are

avoided when talking

about poverty, dru

g addiction, chi

ldren, and adolesc

ents at risk

.

In

2021,

TN

s

tarted

a

multidisciplinary

w

ork

to

generate

an

image

bank

that

allow

s

the

ong

oing

illustration

of

compl

ex

themes

in

au

diovisual

formats

.

Those

working

in

t

he

productio

n,

e

diting,

and

archiving

areas

and

camera

operators

worked

toge

ther

to

ens

ure

that

cle

ar

accurate

images

on

a

bstract

subjects are always

available where faces c

annot be

shown or pr

otagonists can

not be identified.

40

9.

CUSTOMERS

AND SUPPLIERS

9.1.

CUSTO

MER SERVIC

E AND SATISFACTION

In

2

021,

the Group

contin

ued

to

incorporate

communicat

io

n tools

a

nd

channels with

the aim

of

maintaining a close r

elationship with cust

omers.

The

Custo

mer

Serv

ice

Ce

nter

of

La

Voz

del

Inter

ior

i

s

c

ertified

under

the

intern

ational

stand

ard

I

SO

9001:2015 and

rec

eived 73,465

calls

and 10,226

contacts

to

the chatb

ot.

It

ac

hieved a

service

satisfaction

rate

of

95%.

In

2021,

it

conducted

surv

eys

using

NPS

method

ology

to

assess

customer

satisfaction regarding

their subscriptions. Los

Andes implemented an

inte

lligent chat

to expedite orders

or customer complai

nts.

In addition, the

company continued to offer the

benefit programs: Clarín 365 and

Club La Voz

incorporated

for the

ir us

ers the

benefit

of

paying

with

BIMO, an

e

-

wallet,

which

allows t

hem to

use

the

program

wit

hout

the

physic

al

card.

Los

An

des

Pas

s

imple

mented

the

delivery

of

cards

throu

gh

the

newsstands, which i

mproved timing and su

bscriber satisfac

tion.

During

2021,

Gestión Compartida

launched Napsis,

a tool

used to

dig

itize

h

uman

re

sources

process

es,

developed

based

on

customer

needs.

The

latest

annual

custome

r

satisfact

ion

survey

returned

an

overall average of 8.4

9 points out of 10.

In

addition

,

Clarín,

La

Voz

del

Interior

and

Los

Andes

continued

to

focus

on

s

afeguarding

privacy

in

applications

and

we

bsites.

To

this

end

,

they

use

h

igh

security

s

tandards

and

made

improvem

ents

to

procedures

that

safegu

ard

pers

onal

and

sensitive

information:

authenticati

on,

user

expiration,

password rotation a

nd encryption, roles, an

d profiles.

41

9.2.

VALUE

CHAIN

In

the

understanding

that

i

ts

commitment

to

sustainable

management

al

so

enc

ompasses

its

v

alue

chain,

Grupo

Clarín

promotes

the

applicat

ion

of

principles

of

economic,

social

and

environmen

tal

responsibility among i

ts suppliers.

100%

of

Grupo

Clarín's

ac

tive

s

uppliers

receive

an

d

sign,

throu

gh

Gest

ión

Co

mpartida,

a

Letter

o

f

Commitment

to

Sust

ainability

within

the

purc

hase

orde

rs.

Thus,

they

are

commi

tted

to

managing

th

eir

business with a focus

on sustainability: Com

pliance with effective l

egislation; resp

ect for human rights;

good w

orking c

onditions

and

equal

labor

opport

uni

ties;

eradication

of

forced

or

child

labor;

freedom

of

association;

prop

er

handling

of

information

and

data;

f

ight

against

c

orruption;

and

respect

for

the

environment. In

addition, th

e interaction

with our

suppliers

is

channeled throug

h the Cus

tomer Serv

i

c

e

Center, which receive

d 872 calls per mo

nth, with an av

erage resolutio

n rate of 90%.

10.

OUR PEOPLE

10.1.

T

EAM MANAGEM

ENT

Grupo

Cl

arín

p

lays

an

active

role

in

the

economic

gro

wth

and

develop

ment

of

Argentina,

with

a

team

of

4,519 employe

es

in differ

ent provinces of the co

untry.

Thanks

to

the

advances

in

vacc

ination

schemes

against

CO

VID

-19,

the

year

2021

w

as

charac

terized

by

the

progr

essive

implementat

ion

of

th

e

return

to

f

ace

-

to

-face

work

an

d,

in

s

ome

cas

es,

by

the

combination

of

face-

to

-face

work

with

re

mote

work.

At

the

same

t

ime,

prevention

measures

were

deepened

and

protocols were

intensified to

contin

ue

ca

ring

f

or

peop

le.

The Committee,

made up

of

two

infectious

d

isease

physicians

and

mem

bers

of

the

Corporate

Human

Resource

s

team,

continue

d

to

hold

meetings

every

15

day

s.

All

th

e

recomm

endations

disseminated

by

o

ur

med

ia

were

also

applied

in our facilities.

The

p

andemic

forced

the

intensive

use

of

virtual

and

shared

tools

by

the

differe

nt

work

t

eams,

which

helped

opt

imize

an

d

ref

ine

ex

isting

workfl

ows,

c

reate

new

work

flows,

and

rev

iew

journalistic

criteria.

Some of these proces

ses will remai

n in place

due to effici

ency and agility in d

ecision

-making.

Employees by Gend

er

2020

2021

Women

1,351

1,390

Men

3,424

3,129

Total

4,775

4,519

Business units surv

eyed: AGEA; Cúspide; Au

tosports; Artear C

anal 13; Canal 12; Pol

-ka; CI

MECO; CMI; Ges

tión Com

partida; La Voz del Interi

or;

Los Andes; Radi

o Mitre; TyC Sport

s; and Grupo Clar

ín.

Employees by Age

2020

2021

Women

Men

Total

Women

Men

Total

Up to 30

295

372

667

341

358

699

Between 31 and 50

862

2,040

2,902

847

1,795

2,642

Over 51 years old

194

1,012

1,206

202

976

1,178

Total

1,351

3,424

4,775

1,390

3,129

4,519

Business units surv

eyed: AGEA; Cúspide; Au

tosports; Artear C

anal 13; Canal 12; Pol

-ka; CI

MECO; CMI; Ges

tión Compartida;

La Voz del Interior;

Los Andes; Radi

o Mitre; TyC Sp

orts; and Grupo Clar

ín.

Suppliers

2020

2021

Number of calls per mo

nth

2,600

872

Number of cases creat

ed

1,738

1,199

Average percentag

e of resolution rates

90%

42

Employees by type of

employment

2020

2021

Women

Men

Total

Women

Men

Total

Part-time

(1)

63

116

179

78

142

220

Full-time

(2)

1,288

3,308

4,596

1,321

2,987

4,299

Total

1,351

3,424

4,775

1,390

3,129

4,519

Business units surv

eyed: AGEA; Cúspide; Au

tosports; Arte

ar Canal 13; Canal

12; Pol-ka; CI

MECO; CMI; Ges

tión Compartida;

La Voz del Interior;

Los Andes; Radi

o Mitre; TyC Sport

s; and Grupo Clar

ín.

(1)

A certain number of

hours less tha

n two thirds (2/3) of

the regular

working day

.

(2)

An 8-hour working

day or a maxim

um of 48 hours

per week.

Business units surv

eyed: AGEA; Cúspide; Au

tosports; Artear C

anal 13; Canal 12; Pol

-ka; CI

MECO; CMI; Ges

tión Compartida;

La Voz del Interior;

Los Andes; Radi

o Mitre; TyC Sport

s; and Grupo Clar

ín.

Employee Turnover

Ratio 17.2%

2

Rate of new hires 16

,3 %

2

23.2% of employees

perform journalist

ic functions

3

10.2.

INT

EGRITY PROGRA

M

4 pillars Make Up the Gro

up's Diversity

Program

Grupo

Clarín

promot

es

diversity

and

does

not

tolerat

e

any

type

of

d

iscrimination

o

gender,

disability,

age,

ideo

logy,

culture,

phys

ical

appeara

nce,

health,

sexu

al

orientat

ion

and

gender

identity,

religion,

socio-economic

vulnerability,

family

situation,

or

civil

s

tatus.

This

applies

to

both

work

teams

and content generatio

n

4

.

The

Gro

up's

Diversity

Program

consists

of

fo

ur

main

p

illars:

gender

diversity,

people

with

d

isabilities,

age

diversity

and

ideological

diversity.

In

addition,

it

proposes

8

d

imensions

on

which

focus

is

made:

communication;

awarenes

s;

pay

eq

uity;

recru

iting

and

hiring;

leadership

training;

profession

al

promotion

an

d

deve

lopment;

work

-life

balanc

e;

work

place

and

sexu

al

harass

ment

an

d

viole

nce

and

working conditions.

The

Group's

main

media

have

adhered

to

the

UN

Women

Step

It

Up

for

Gender

Equality

Media

Compact and, at t

he corpor

ate level, to Wom

en's

Empowerment

Principles (W

EPs) established by U

N

2

Business units surveyed: AGEA;

Cúspide; Autosports; Artear Canal

13; Canal 12;

Polka; CIMECO; CMI; Gestión

Com

partida; La

Voz del Interior;

Los Andes; Radi

o Mitre; TyC Sport

s; and Grupo Clar

ín.

Employee turnove

r rate = Departu

res / Total Employ

ees as of Dec

ember 31 (for eac

h cate

gory)

New Hire Rate = New

Hires / T

otal Employees

as of December

31 (for each c

ategory)

3

Business units su

rveyed: AGEA; C

anal 12; CMI

; La Voz del In

terior; Los Ande

s; and TyC Sports.

4

For

more information see the section “Promoti

on

of

Diversity” under

“

Resp

onsible Creation and Distributio

n of

Conten

ts

” in this integrated Annual

Report.

Local Employment

Generation

2021

AMBA and the Prov o

f Bs As.

3,954

Córdoba

349

Mendoza

152

Santa Fe

31

Río Negro

-

San Juan

14

Tucumán

5

San Luis

6

Santiago del Estero

4

Salta

1

La Pampa

1

Chubut

1

Misiones

1

43

Women.

In

add

ition,

t

he

Gr

oup

is

part of

th

e

Net

work

of

Companies

for

D

iversity

(R.E.D.)

of

Univers

idad

Torcuato Di Tella.

In 2021, Grupo Clarín im

plemented the Lab

or Violence Prot

ocol for which it trai

ned

Hu

man Resourc

es

representatives

from

all

bu

siness

units,

in

alliance

with

the

orga

nization

ELA

–

L

atin

American

Justice

and

Gend

er

Team.

Pol-k

a

deve

loped

an

internal

pro

tocol

on

gender

-base

d

viol

ence

and

execute

d,

together

with

the

Argentine

Chamber

of

In

dependent

Pr

oducers,

an

“Agreeme

nt

to

guarantee

Violence

-

Free Workspaces in Th

eater and Audiov

isual Activities

”.

In

additio

n,

we

co

ntinued

delivering

training

on

diver

sity

in

all

our

business

unit

s.

Diar

io

Clarí

n

h

eld

three talks that were part

of the cycle of Human

R

ights Talks where

jour

nalists were trained in: gender-

sensitive

elections,

keys

to

covering

v

iolence

from

a

gender

persp

ective

and

introduction

to

m

edia

violence.

Artear's

j

ournalistic

teams

participated

in

tra

ining

on

g

ender,

d

iversities

a

nd

huma

n

rights

delivered

by

Unicef

and

Iniciativa

Spotlight.

In

a

ddition,

Grupo

Clarín

r

eceived

a

recogn

ition

for

affirming

its

commitment

to

building

a

diverse

and

plural

city,

since

the

Group,

Gestión

Compart

ida

and

Radio

Mitre

participated

in

sensiti

zations

on

D

iversity

and

Inclusion

del

ivered

by

t

he

Under

-Secretariat

for

Human Rights and Cul

tural Plural

ism of the Governm

ent of the City o

f Buenos Aires.

The

Grou

p

contin

ued

to

pr

ovide

several

benefits

suc

h

as

breastfe

eding

rooms,

extended

maternity,

pat

ernity

and

adoption

leaves

,

and

flexib

le

return

to

wo

rk,

not

only to

promote

the welfare

of

employees,

but also to contribute to

the construction of a d

iverse work

force.

We

also

continued

to

incorporate

young

people

as

their

first

work

experience.

At

eldo

ce,

professional

internships wer

e carried

out in

alliance

with Unive

rsidad Sigl

o 21

and Co

legio Un

iversitario d

e

Periodismo.

10.3.

CO

MMUNICATION AN

D DIALOG

In

2021,

our

com

munication

and

cl

imate

ac

tions

were

focused

on

acco

mpanying

the

work

teams

in

a

context

w

here

the

COVID

-19

pandem

ic

cont

inued

to

take

center

stage.

Interna

l

communication

was

based on the o

ngoing disse

mination of hea

lth protocols

, follow

-up

of confirmed c

ases, and a

wareness

of personal care.

Grupo

Clarín

continued

to

promote

and

stren

gthen

the

use

of

the

m

ain

internal

communicat

ion

t

ool,

Teams, with the partic

ipation of seven bus

iness units.

In

ad

dition,

the

Group

continued

to

pro

mote

spaces

for

seamless

communication.

Virtual

mee

tings

between

the

General

Manager

and

t

he

emp

loyees

w

ere

held

in

La

Voz

del

I

nterior

a

nd

in

Gestión

Compartida.

In

2

021,

Grupo

Cl

arín

dev

eloped

t

he

Internal

O

pinion

Survey

for

the

entire

group.

It

achieved

a

response

rate

of

76%,

with

employees

from

14

com

panies

and

a

satisfact

ion

rate

of

72%.

The

best

results

were

achieved

in:

Res

ponse

to

COVID-

19

(70%

favorability)

and

Immedi

ate

Supervisor

(69%

favorability).

65%

5

of the emp

loyees are

covered by

collective b

argaining agre

ements. In th

is context, Gr

upo Clarín

promotes

the

freedom

of

as

sociation

a

nd

trade

re

pres

entation

of

employees

a

nd

holds

reg

ular

meetings

with the unions.

5

Business units

surveye

d:

AGEA; Cúspide; Autosports;

Artear Canal 1

3; Canal 1

2; Pol-ka; CIMECO;

CMI; Gestión

Co

mpartida; La

Voz del

Int

erior;

Los Andes; Radi

o Mitre; TyC Sport

s; and Grupo Clar

ín.

44

10.4.

WORK

-LIFE BALANC

E AND BENEFIT

S

Grupo

Clarín

pro

motes

a

work

environmen

t

where

th

e

welfare

o

f

the

employe

es

and

their

f

amilies

is

paramount. Some exam

ples of be

nefits in different bus

iness units are:

•

Flexibility:

Flexible

work,

home

office,

flex

Fridays,

day

off

on

birthday,

vacation

d

ays

in add

ition

to those provided by l

aw, and personal days

.

•

Family:

Reimburs

ement of

daycare fees for

the childre

n of our employe

es, virtual

events with the

children

of

our

e

mployees, be

nefits

for

the

fam

ily

of

our

employees

(health

c

are

a

nd

fitness

cente

r),

breastfeeding rooms

in our

offices, parental

leave beyond

the term

provided by

law, gradual

r

eturn

to

work

after

the

parent

al

l

eave,

ad

option

leave,

s

pecial

leaves

for

pre

mature

children,

wedding

policy,

extra

h

alf

hour

for

breastfeeding mothers

b

eyond

the

period established

by

l

aw

and

additional

days of

sick l

eave to

provide care

for a

sick dependent.

For example,

D

iario

C

larín

of

fers

an

extended maternity leave

of

30 days

in

add

ition to

the 90

days provided

by law

and

14 calendar

days for paternity le

ave and the same

benefit in case

of adoption.

•

Health

and

Care:

o

nline

fitness

class

es,

talks

with

infectious

disease physicians,

telephone

assistance,

delivery

o

f b

oxes

containing

h

ousehold

clean

ing an

d

personal

hy

giene

products,

and

bereavement works

hop for

those who suffered

the loss of a f

amily member.

•

Other

V

alue

Propositions

:

The

card

Cl

arín

365,

v

irtual

English

c

lasses,

preferential

prices

on

Internet

services

,

mobile

telephony

and

cable

TV,

lunch

,

discounts

on

pro

ducts

and

s

ervices,

policy

for recognition of values, financial assistance, agreements with universities and long

-term savings

plan

for executives,

items

needed

for those

working

remotely (technological

equip

ment,

ergo

nomic

chairs, and genera

l advice), events f

or teams workin

g remotely.

In

2021, 46

women and 52 me

n took the parental l

eave

, of whi

ch 88% and 96% returned

to work at the

end of the leave, res

pectively

6

. The retention rate

was of

7

91% in women and

75% in men.

In

additio

n,

Gru

po

Clarín

granted

salary

increases

tha

t

were

ab

ove

t

he

gen

eral

market

average

and

also

above

t

he

industry

av

erage.

In

addition,

s

ome

bus

iness

units

have

implem

ented

perform

ance

-

based bonuses.

10.5.

PRO

FESSIONAL DE

VELOPMENT

9 hours of training per

employee

8

40,689 hours of training

8

With regard to

the development of the employees, Grupo Clarín

contin

ues to

drive the Management by

Objectives s

ystem as

a performance

monitoring s

ystem.

In 2021, t

wo com

panies s

tarted to

implement

it

and

now

there

are

eight

busin

ess

units

that

already

use

this

m

anagement

system.

W

e

continue

d

to

make

Internal

J

ob

Postings

with

t

he

aim

of

promoting

int

ernal

mobility.

In

a

ddition,

th

e

Leadership

Model

remains in place and

a Mentoring program

was carried out at

Ty

C Sports.

The

challenges

of

digital

tr

ansformation

are

driving

Grupo

Clarín

to

offer

a

wide

range

of

tr

aining

courses:

digital

tools

f

or

journal

ism;

digital

mark

eting;

digital

bus

inesses;

user

e

xperience;

big

d

ata;

data

science;

digital

immers

ion

for

human

reso

urces.

This

was

complemente

d

b

y

trainings

delivered

6

Busin

ess

units surveyed:

AGEA; Cúspide;

Autosp

orts;

Artear Canal

13; Canal

12;

Pol

-ka; CIMECO;

CMI; Gestión

Compartida;

La

Voz del

I

nterior;

Los Andes; Radi

o Mitre; TyC Sport

s; and Grupo Clar

ín.

14 women and 2

men were still on

parental leave a

s of Decembe

r 31, 2021.

7

Percentage of peopl

e who retur

ned to work aft

er the parental le

ave and staye

d in the Company

12 months.

8

Busin

ess

units surveyed:

AGEA; Cúspide;

Autosports

;

Artear

C

anal 13

; Canal 1

2; Pol-ka; CIMECO;

CMI; Gestión

Compartida;

La

Voz del

Interio

r;

Los Andes; Radi

o Mitre; TyC Sport

s; and Grupo Clar

ín.

45

together

with

G

oogle,

Digit

al

House

and

IT

BA.

In

addition,

Diario

Clarín

continued

its

partnership

with

Universidad de San

Andrés to offer th

e Master's Degre

e in Journalism, a

leader in Latin Am

erica.

Finally,

Grupo

Clarín

contributes

to

people

in

se

arch

for

their

firs

t

job

through

internship

pro

grams.

Radio

Mitre,

for

example,

consolidat

ed

its

Young

Professionals

Program

t

ogether

with

U

niversidad

Católica Argentina and

Universidad del Sa

lvador

, in which 20 y

oung people part

icipated.

10.6.

HEALT

H AND SAFET

Y

During

2

021,

we

continu

ed

to

promote

t

he

Health

and

Safety

Link,

which

bri

ngs

t

ogether

all

the

b

usiness

units,

with

th

e

objective

of

generating

a

p

lace

to

s

hare

and

draw

conclusions,

as

well

as

establishing

an integral vision tha

t considers the real

ities of each

business unit

.

During

the

year,

the

medic

al

team

provided

assistance

to

empl

oyees

in

cases

of

infection

or

close

contact. And int

ernal comm

unications were d

isseminated w

ith informat

ion

on CO

VID-

19 protocols a

nd

prevention.

Phased

return

was

implemente

d at

t

he

offices. T

o

this

end,

work

spaces

were

reo

rganized

to

maintain

the

preve

ntion

measures

; acrylic separators

were installed between

t

he nearby

work

stations; individual

care

kits

were

delivered

to

each

employee

,

t

he

protocols

for

dist

ance

and

cle

aning

were

established,

and improvements were made to the ventilation systems. At Grupo Clarín, a test site was set up

for six

months to perform

swab

tests

to all employ

ees once a

week. We

also

maintained

the care proc

edures

and protocols for the e

mployees that wor

k outdoors.

In

other

res

pects,

G

rupo

Cl

arín’s

emp

loyees

were

offered

the

annual

medica

l

check

-up

and

influenza

vaccination, and sever

al editions of the

CPR course w

ere carried out in

different business units.

11.

SOCIAL DEVELOP

MENT

11.1.

PRI

VATE SOCIAL INV

ESTMENT STRAT

EGY

Grupo

Clarín

implements

a

private

socia

l

investment

strategy

with

a

focus

on

the

donation

of

advert

ising

spaces; media literacy

, education, culture, a

nd local de

velopment.

Contribution to th

e Community

2020

2021

Social Investment in

Programs (in Argenti

ne

Pesos)

12,234,941

17,435,455

11.2.

CO

MMUNITY ENGAG

EMENT AND

SOCIAL ADVERT

ISING

With

reso

urces,

ti

me

an

d

advertis

ing

sp

ace,

the

Group

s

upports

social, civ

ic,

and

environmental

projects

in

which

various

civ

il

society

organizati

ons

wor

k.

In

some

cases,

Radio

Mitre

offers

the

serv

ices

of

its

announcers

,

editors

and artistic

prod

ucers to

work

on

the

spots, and

the

adv

ertising teams

receive

the materials and give

them the same

treatment as tr

aditional advert

ising.

46

Donation of Advertising

Space

Unit

2021

2020

Donation in

television or

radio

(1)

Donation of Free Advertising spaces

of which we are members (Chambers

and Foundations)

(2)

Seconds

20,922

583,600

Seconds

Argentine

pesos

(3)

16,201,171

Advertising space donated to public

welfare entities of which we are NOT

members (Foundations, Associations,

Cooperatives, Institutions, other).

Seconds

734,344

Argentine

pesos

(3)

346,088,051

Public welfare campaigns organized

by Grupo Clarín

Seconds

55,591

Argentine

pesos

(3)

35,569,857

Donation of

Advertising in

Print Media

(4)

Donation of Free Advertising spaces

of which we are members (Chambers

and Foundations)

(2)

Pages

(5) (6)

6.3

156

pages

Argentine

pesos

(7)

819,412

Advertising space donated to public

welfare entities of which we are NOT

members (Foundations, Associations,

Cooperatives, Institutions, other).

Pages

(6)

258.3

Argentine

pesos

(8)

33,675,262

Donation of

advertising in

digital media

(9)

Donation of Free Advertising spaces

of which we are members (Chambers

and Foundations)

(2)

Online Banners

3,508,116

326,554,220

Printed

banners

Argentine

pesos

641,897

Advertising space donated to public

welfare entities of which we are NOT

members (Foundations, Associations,

Cooperatives, Institutions, other).

Online Banners

73,682,588

Argentine

pesos

(10)

23,470,718

Total Amount of Peso

s Donated

456,466,368

286,445,987

(1)

Business units surveyed:

Artear Can

al 13; Cana 12; Ra

dio Mitre and TyC S

ports.

(2)

Fundación Noble is incl

uded.

(3)

These are estimated valu

es based o

n the rate per s

econd per sign

al to add up to t

he total amount.

(4)

Business units surveyed:

AGEA Tacuar

í; La Voz del In

terior; and Los

Andes.

(5)

For La Voz del Interior, th

e centimeters a

re calculated on

the basis of t

heir equivalent in mo

dules.

(6)

Pages were calculated on

the basis of t

heir equivalent in

centimeters.

(7)

Estimated values based o

n average

rates to add up to t

he total amoun

t. For the dona

tions to Fun

dación Noble's C

ampaigns, AGEA

T

acuarí

considered estima

ted values base

d on average c

entimeters p

er page and ann

ual sales of pri

nt advertising/ tot

al annual sal

es pages of print

advertising. La Voz

del Interior consi

dered centimete

rs calculated

on the basis

of their equivale

nt in modules. E

stimated bas

ed

on the price pe

r

even page, based

on day of publicati

on and with 4

0% discount for l

ocal custom

ers.

(8)

Values were estimated bas

ed on ave

rage centimeters p

er page and a

nnual sales of pri

nt advertising / to

tal annual

print advertisin

g s

ales

pages.

(9)

Business units surveyed:

AGEA Tacuarí; La Vo

z del Interior

; Los Andes; Ra

dio Mitre; and TyC S

ports.

(10)

T

he values

to

add

to

the

total

amount

were

estim

ated

based

on

the

average

centimete

rs pe

r p

age, CP

M (c

ost

per

thousand

impressio

ns)

and

rate by device typ

e and size.

Some

of

th

e

org

anizations

that

received

advert

ising

spaces

to

spread

their

causes

were:

UNICEF,

Cáritas

Argentina,

Consejo

Publicitario

Argent

ino,

F

undación

Kónex,

Techo,

Banco

de

Alimentos,

Asociación

Luch

emos

por

la

V

ida,

La

Casa

de

Ronald

Mc

Don

ald

Asoc

iación

Argentina,

ACNUR,

Fundación Huésped, Escleros

is Múltiple Argentina (

EMA), Asociación Síndro

m

e de Down de l

a

República Argentin

a, AMIA, Fundac

ión Natalí Drexler,

and Dale Vida, amon

g others.

11.3.

T

HE ROLE OF THE

MEDIA IN EDUCAT

ION

Fundación

N

oble

continued

to

drive

the

initiative

“

Los

medios

de

comunicación

en

la

educac

ión

”

w

ith

the aim

of promoting critical and creative reading of media

conten

t. This

pr

ogram, which has been held

for

more

tha

n

30

y

ears

and

is

internationally

recognized,

consists

of

the

development

of

pedagogical

contents

for

t

eachers

a

nd

students

of

t

eacher

training

careers.

Since

its

creation,

563,943

teach

ers

have participated.

During

2021,

Fundación

Noble

offered

24

free

virtual

c

ourses

in

its

camp

us,

wit

h

the

participation

of

over 3,900 teachers. The c

ourses have ongo

ing tutors that facilita

te the understandi

ng and appli

c

ation

of various didactic strategie

s. The following topics were

addressed:

How to identify

reliable information

on

the

Internet.

How

to

produce

a

digital

medium

at

school.

M

edia

and

ICT:

How

to

work

by

projects.

How

to

use

mobile

d

evices

in

the

classroom.

How

to

use

technologies

to

tell

sto

ries.

How

to

produce

podcasts in the classroom

. What we can d

o about cyberbul

lying.

47

In

addition, the

co

mpany launched

the second

season of

t

he

podcast

“

Los Medios

de Comunicación

en

la

Educación

”

,

a

proposal

for

the

e

ducational

comm

unity

that

seeks

to

address

the

c

omplexity

of

distance teaching a

nd learning.

The

seventh

edition

of

the

ph

otography

c

ontest

#sos

VOSenlared2021

was

h

eld

and

more

than

400

st

udents part

icipated.

The

contest seeks

t

o

encourag

e cr

itical

thinking

abou

t t

he

ways

in

which

you

ng

people build their identity

in social media

and in the cultural co

ntexts in which t

hey interact.

Simultaneously,

the

second

part

of

the

f

irst

postgraduate

cohort

in

Educ

ation,

Media

an

d

ICT

was

delivered in

conjunction

with

Universidad

Católica

de

Buenos Aires,

which

grants

teaching s

cores a

nd

has the

approv

al of

the

Min

istry

of Educat

ion of

Argent

ina. Th

is

postgraduate

course

aims

to

enhance

the knowledge about innovative methodolog

ies that integrate the media and ICT into teaching and that

allow the development

of the digital ski

lls of teachers a

nd students.

During

this

perio

d,

a

new

content

secti

on

was

launched

for

T

ik

Tok

and

Instagram

“How

does

a

newspa

per

work?”,

which

provides

information

on

journalistic

coverage,

the

functioning

of

inte

grated

newsroom, the printing

and distribution of th

e print news

paper.

In

20

21,

t

hrough

Fundación

Noble,

Grupo Cl

arí

n

a

lso

donated

magazines

and

books

to

vario

us

institutions and spons

ored the 19

th

Reading Mara

thon of Fundació

n Leer.

Los

Andes offers

the educational program

Medios en

la Educación

, which

p

romotes actions

for

teachers,

students,

a

nd

t

he

educational

co

mmunity

of

Mendoza.

Nine

virtual

meetings

w

ere

held

and

then made availab

le on the YouTube

channel, with

a total of 3,000 p

articipants.

11.4.

F

OSTERING EDUCAT

ION

In 2021, Clarín and Zurich organized the first edition of

the initiative

“Teachers that inspire,”

a tribute to

the most

outs

tanding

teachers

in

our

country

.

The init

iative

seeks

to

mobilize

the

entire co

mmunity

for

a better educ

ation, s

preadi

ng the inspir

ing stor

ies of thos

e excepti

onal educ

ators who l

eave a dec

isive

mark on their stude

nts.

More

than

3,000

applicatio

ns

were

rec

eived

from

all

provinces

of

the

country.

After

three

r

igorous

selection stages, with the participation of Fundación Vark

ey and 7 other education organizations and a

Grand Jury of

13 recognize

d academic and scientific individuals, in a

special TN program the stories of

the

6

finalists

were

reported

and

the

Ins

piring

Teacher

of

the

Year

was

recognized

with

$600,000.

At

the same time, two other

teachers

who obtained an honorable mention received $200,

000 each. The 6

finalists

r

eceived

a

schola

rship

to

p

ursue

the

postgr

aduate

degree

in

Educat

ion,

Media

and

ICT,

organized by Fundac

ión Noble and Un

iversidad Católic

a Argentina.

Fundación N

oble

continued

to

sponsor

Escue

la N°

11 “Dr.

R.

Noble”

of

Villa

Balle

ster,

Escuela N

°457

“Dr.

R. Noble”

of A

ve

llaneda, Escuela

Téc

nica N°

5

“Dr. R.

No

ble”

of San

Justo, and

Escuela N°

91

“Dr.

R. Noble” of Senil

losa, Neuquén.

Also,

during

this

per

iod,

th

e

comp

any

sponsore

d

the

XII

Forum

on

Educati

onal

Q

uality

and

Equit

y,

organized

by

EDUCA

R2050.

With

th

e

s

logan

#Ah

oraAprender,

the

company

address

ed

the

learning

crisis that the pandem

ic situation caused

in children and young p

eople.

TyC Sports received

an award for its program

“

J

ugando es Mejor

” as

Embassy

of

Peace, whi

ch means

emphasizing

the

signal's

commitm

ent

to

d

isseminate

content

p

eace

and

n

on

-

violence

i

n

sports.

This

new

recog

nition

empowers the

signa

l

to use

the

i

nternational flag

of peace

at i

ts offices

and

in activities.

48

The

news

paper

Los

Andes

c

ontinued

to

recognize

ac

ademic

ex

cellence

with

the

Scholarship

Adolfo

Calle

w

hich

distinguishes

a

student

amon

g

Mendoza

primary

sc

hool

graduates

to

provi

de

f

inancial

support for five years. In addition, the Elvira Calle Excellence Scholarship was renewed at U

n

iversidad

Juan Agustín Maza for s

tudents of the

1

st

year of the U

niversity Degree T

echnician in Journa

lism.

Every

Thursday

of

September

2021,

Fundac

ión

Noble

published

in

co

njunction

with

Educar205

0

a

special

section

in

Diario

Clarín

an

d i

n c

larin.com

w

here

differen

t

specialists

analyz

ed and

reflec

ted

on

various

challenges

facing

Argentine

education:

the

return

to

face

-

to

-face

classes,

how

to

recover

the

learning

c

ontents

that

coul

d

not

be

taug

ht

in

virtual

class

es,

the

use

of

technolo

gy

in

the

c

lassroom

,

among others.

In

line with

the

importance tha

t

Grupo

Clarín

attaches

to

ed

ucation

as

a driver

of the

country’s

development,

during

this

period,

different

journalists

fr

om

Los

Andes,

La

Voz

del

Interior,

Clarín,

and

TN carried out the sp

ecialization in J

ournal

ism and Education at

Universidad Torc

uato Di Tella.

Eldoce

iss

ued

a

s

pecial

program

that

summarized the

touring initiative

“

Cruce

por

l

a E

ducación

Argentina

”,

which

c

overed

2,200

kilom

eters.

Under

t

his

initiative,

s

ix

committed

c

itizens

travel

ed

t

he

country to interact wit

h primary s

chool students.

11.5.

PRO

MOTION OF CULTU

RE AND SOCIAL

DEVELO

PMENT

In

20

21,

G

rupo

Clarín

con

tinued

to

promote

the

Clarín

Novela

Award,

one

o

f

t

he

most

prestigious

literary

contests

in

Spani

sh

America

that

contributes

to

gener

a

ting

ecosystems

of

c

ulture

and

development.

In

a

ddition,

th

e

Ma

gazine

Ñ

gav

e

an

award

to

the

artist

Marta

Minujín

for

her

track

-record.

In addition, Clarín and Banco Galicia hosted the PyME awards, which recognize innovation,

resilience,

and

v

alue

creation

in

small

and

medium-s

ized

companies.

They

recognized

the

work

of

th

e

firms

Plantium, Grupo Mitr

e, El Paruco, Cazaf

ugas, and Un

itan.

Clarín

promoted

t

he

dissem

ination

of

contents

of

high

cultura

l

and

educati

onal

value

through

the

Cult

ure

Section and Magazine Ñ

in both the

print and digital versions. In

its Sunday Supplement

Número Cero,

La Voz del Interior s

preads the local c

ultural act

ivities of publishers

and artists.

Los

Andes

held the

13

th

edition

of

th

e

c

ontest

“

Contá

un

cuento

c

on

Tintero

”

for

the

production of

l

iterary

stories. In 2021, 25 ch

ildren participated

.

11.6.

AL

LIANCES WITH CI

VIL SOCIETY ORGANIZ

ATIONS

In 2021, eltrece he

ld

a n

ew edition of t

he initiative “

Un

sol para los c

hicos

”, a program a

imed at raising

funds

to

s

upport

UNICEF's

work

for

ch

ildren

and

adolesc

ents

in

Arge

ntina.

The

program

a

llowed

t

o

raise $215,970,245.

Eltrece

an

d

Fun

dación

N

oble

sponsored

the

initiative

Abanderad

os

de la

Argentina

Solidaria,

an

annual

award that r

ecognizes

Argentine p

eople that

stand

out for

their

dedication to

other

s, and d

isseminates

their

stor

ies

of

life

so

that

their

example

w

ill

i

ns

pire

t

he

rest

of

the

s

ociety.

Martín

Ferr

iera,

f

ounder

of

SonRisas,

w

as

chosen

by

the

p

ublic

as

the

winner

and received

$1,000,000

to continue

with

his

project.

Sergio

Manazzi,

t

he

founde

r

of

El

R

incón

de

Todos,

won

a

speci

al

prize

of

$500,000,

while

an

oth

er

6

finalists received $120,00

0 each.

During 2011,

Clarín

renewed its pa

rtners

hip with

Missing Children

and Red

So

lidaria to

pub

lish

photographs

of

missing

children

in

Diario

Clarí

n

and

raise

awareness

ab

out t

he ro

le of

t

he co

mmunity

in dealing with t

his

prob

lem. Clarín and

Red Solidaria

continued with th

e publicatio

n of “

Calen

dario del

Compromiso

con

la

Com

unidad

”

in

the

Magazine

Viva

as

a

s

olidarity

action

o

f

the

d

aily

agenda

of

Grup

o

Clarín's media.

49

The

G

roup

also

sponsore

d

campaigns

to

su

pport

civil

soci

ety

organizations.

Among

th

em,

Eldoce,

Radio

M

itre

and

Agustino

dissemi

nated

th

e

cam

paign

"

Todos

debemos

usar

barbijo

”

an

d

distri

buted

60,000

face

masks

to

more

than

20

0

institutions

(sch

ools,

nursing

homes,

com

munity

canteens,

and

neighborhood

ce

nters).

T

he

employ

ees

of

ra

dio

La

1

00

FM

c

ollected

don

ations

of

toys,

cloth

es,

and

food for the oncology

area of Casa Cun

a.

12.

THE ENVIRONMEN

T

12.1.

CO

NTENT THAT PROMO

TES ENVIRONM

ENTAL AWAR

ENESS

The

impact

of

global

warming

on

the

econ

omy

and

s

ocial

welfare

was

evi

dent

during

2021

and,

as

a

media

gro

up,

the

Compan

y

s

trengthened

its

commitment

to

enviro

nmental

awareness.

The

Gr

oup's

media conducted a comprehensive coverage and dissemination of the

United Nations Climate Change

Conference (COP26) fro

m Glasgow

and trans

mitted the informa

tion over multiple

platforms.

In

addit

ion,

the

Group's

media

made

speci

al

re

ports

o

n

fores

t

fir

es,

floods,

and

w

ater

em

ergencies

in

Argentina

and arou

nd the

world.

Each

medium

adapt

ed the c

ontent

to

its audien

ce, cov

ering act

ivities

to

contribute to the env

ironment and ad

dress curr

ent issues.

Clarín's

quarterly CSR

supp

lement

continued

to highlight

s

ocial

a

nd

environmen

tal

issues.

In

its section

ECO, the

magazi

ne VIV

A c

ontinued to

addr

ess the

proble

m of

environme

ntal

protection

from

dif

ferent

sources (tex

tiles, food,

construction,

and in

dustry). La

Voz de

l Interior

developed

a s

pecial channe

l on

Circular

Economy

on

its

w

ebsite

and

the

top

ic

was

discus

sed

in

its

print

editions

.

Los

Andes

held

a

campaign together w

ith the

General Irrigatio

n Department to ra

ise awareness a

bout the

desertification

process in the prov

ince of Mendoza.

TN

launched

the

s

econd

se

ason

of

“

SusTNtables”,

through

its

digital

platforms,

to

high

light

and

pr

omote

the

importance

of

env

ironmental

care in

a

ll

forms, through the

cons

cious an

d responsible

use of

natural

resources. The

program covered

from the segregation of

w

aste and

recycling to

more complex

processes

involving

i

ndustrial

production,

along

with

the

dissemination

of

stories

of

sev

eral

entrepreneurs

working

t

oward

this

pre

mise

in

Ar

gentina.

Eldoce

covered

various

environmental

care

and

protection

in

itiatives

and

created

a

special

section

on

Instagram

with

inform

ation

and

recommendations for e

nvironmenta

l care.

Radio

Mitre

conti

nues

to

di

sseminate

env

ironmenta

l

is

sues

and

sustain

ability

topics

throu

gh

its

we

b

section “

Planeta V

ivo

”. Cienradios

disseminates topic

s related to the enviro

nment and the co

existence

with nature in a sust

ainable way.

12.2.

ENV

IRONMENTAL M

ANAGEMENT AND

POLICY

The

Grou

p's

commitme

nts

are

embodied

in

its

C

orporate

Soci

al

Res

ponsibility

and

Sustainability

Pol

icy,

which

also

defines

the

environment

al

man

agement

goals.

Within

th

is

frame

work,

the

busines

s

units

focus on continuous im

provement. The Gr

oup keeps rec

ord

of the use of resource

s for its op

timization

and

r

aises

a

wareness

amo

ng

its

e

mployees

on

the

c

are

of

those

resources.

It

also

invests in

equipment

and works on adopt

ing and obtain

ing the certification

of environmenta

l standards.

The industr

ial plant

whe

re the

newspaper

Clarín

is

printed

has its

own E

nvironmental

Policy

–

r

anging

from c

ommercial

pr

inting

to

binding

–

and

an

Environmental

Managem

ent

System

certifi

ed

under

ISO

14001:2015. Training on the standard was conducted during 2021 with the participa

tion of 183

employees. The

policy is

also applicable to

su

ppliers, which must

m

ake an

annual assessment through

an environmental s

urvey.

Gestión Compartida obtai

ned the Green Seal cert

ification from the Ministry of Pub

lic Space and Urban

Hygiene

of

the

C

ity

of

B

uenos

Aires,

which

eva

luates

and

rewards

s

uccessful

pract

ices

in

waste

management at work

environments.

50

Throughout the year, the

G

roup’s business units continued

to raise awareness among their employees

on

w

aste

sort

ing

and

on

the

use

of

their

ow

n

was

hable

co

ntainers

inste

ad

of

d

isposable

ones.

TyC

Sports

partic

ipated

on

the

sensitizations

organized

by

the

International

Olympic

Committee

on

environmental actions w

ithin the worl

d of sport.

12.3.

MATERI

ALS

The

Company

always

seeks

to

make

efficient

use

of

resourc

es

in

bo

th

producti

on

areas

and

administrative tasks

.

Eldoce

delivered

to

its

employees

rechargeab

le

bat

tery

kits

with

th

eir

ch

argers

and

r

enewed

the

set

design with

LED sc

reens to

be reused

in different

prog

rams and

avoid mat

erial

disposal.

In additio

n, a

progressive

lighting

s

ystem

was

installed

in

order

t

o

pro

tect

t

hem

fro

m

power

out

ages.

L

a

Voz

del

Interior

is

conducting

a

pilot

test

to

improv

e

the

wetting

of

machine

s

heets

with

the

installation

of

a

water-powered dosatro

n pump,

which does

not require

electricity.

Consumption of the Main Materials (in tons)

(1)

2020

2021

Paper

- Printing

23,223.33

14,814.16

(2)

- Office

40.65

34.79

(3)

Ink

416.04

320.82

(4)

CTP Aluminum plates

86.24

86.99

(5)

(1)

The quantity of materials consumed in their

most releva

nt categories. Consumption of the following non-renewabl

e materials was also

me

asured

during

the

p

eriod:

wire

,

adhesives,

rubber

bla

nkets,

ne

utral

source

solution,

r

ubber

was

her,

silicon

e

emulsion,

a

d

hesive

tapes,

packing

straps

,

metal bands, plate developer, filters, polyethylene, Arabic gum, lubricating greases and oils, rubber cylinder, wrapping (film and

streech), bale wire,

batteries

(AA

and

A

AA),

9-volt

batteries,

lamps,

coaxial

c

ables,

audio

c

ables,

power

cables,

multi

pair

cables,

t

elephone

cabl

e,

network

cables,

CR2032toner but

ton battery, solv

ents, and cartri

dges.

And the following

renewable mat

erials: boxes, w

ooden pallets, a

nd cleaning cl

oths.

(2)

Includes

newsprint,

national

p

aper

and

paper

f

or

commercial

production.

Business

u

nits

survey

ed:

newsprint

:

AGEA

Z

epita;

nati

onal

paper

(newsprint):

La

Voz

d

el I

nterior

and

Lo

s

Andes

(for

Los

A

ndes,

the

consump

tion

was

estim

ated

based

o

n es

timates

of

the

w

eight

and qua

ntity

of

the different typ

es of coils used

); paper for comm

ercial production:

AGEA Zepit

a.

(3)

T

he audited

am

ounts

were:

6,

645 r

eams

of

A4

paper; 120

reams of

A3

paper;

170

reams

of

lett

er

paper;

672

rea

ms

of le

gal

paper

;

and

16.51

tons of Kraft pap

er.

Business units sur

veyed:

A4 P

aper:

AGEA

Tacu

arí,

ARTEAR

Ca

nal

13,

Canal

12

Có

rdoba,

Gestión

Co

mpartida,

LVI

(val

ue

estimate

d b

ased

on

the

num

ber of

reams

and

prints), Radio Mitr

e, TyC Sports,

Los Andes.

A3 Paper: AGEA Tac

uarí

Letter Paper: TyC

Sports

Legal Paper: AGEA Ta

cuarí, ARTE

AR Canal 1

3, TyC Sports

Kraf Paper: AGEA

Zepita

–

LVI

(4)

Includes

Coldset

ink

based

on

vegetable

oil

and

mineral

oil

base

and

Heatset

ink.

Business

units

surveyed:

Coldset

I

nk

Vegetable

Oil

Base:

AGEA Zepita, La Voz

del Interior an

d Los Andes;

Coldset ink, m

ineral oil base: La V

oz del Interio

r; and Heatset ink

: A

GEA Zepit

a.

(5)

Business units surveyed

: AGEA Zepi

ta, La Voz del I

nterior and Los A

ndes.

AGEA Zepita: The num

ber of units c

onsumed, area,

and thickness

of each plate ty

pe were consi

dered. Conversio

n factor us

ed: 2.

70 tn/M3.

LVI: An average wei

ght of 0.58 g

rams was consi

dered for a stand

ard aluminu

m sheet.

Los Andes: A unit

weight of 0.310

kg was consider

ed.

12.4.

EN

ERGY AND

EMISSIONS

6% reduction in scop

e 1 and 2 emissions

During

2021,

the

electricity

consumption

of

the

power

supply

network

repr

esented

more

than

90%

of

the

e

nergy

consumption.

The

rest

cons

ists

of

alt

ernative

generators

for

offices

and

in

dustrial

installations that run on f

uels.

La

Voz

del

Interior

continued

to

f

ocus

on

consu

mption

habits

and

behav

iors:

the

automatic

sw

itch

-o

n

of the

centra

lized services was delayed for two h

ours; the focus was on the

activit

ies carried out du

r

ing

the night shifts; and lig

hting timers were i

nstalled in cor

ridors and circulati

on areas.

At

Po

lka

there

was

an

incr

ease

in

th

e

electricity

consump

tion

d

ue

to

th

e

r

eturn

of

the

enterta

inment

productions

that

had

been

suspended in

2

020

as

a r

esult

of

the

beginning

o

f the

pandemic.

How

ever,

that

company took measures to

reduce consumption, which mainly

included the

re

placement of

51

traditional

lighting

e

quipment

by

LEDs

in

al

l

b

usiness

units,

and

the

installation

of

invert

er

-

based

air

conditioners.

Direct and Indirect Power

Consumption (i

n GJ*)

2020

2021

Electricity

126,597.86

126,639.31

(1)

Natural gas

37,943.72

37,690.83

(2)

Gasoline

695.92

1,509.89

(3)

Gasoil

1,733.77

2,404.62

(4)

CNG

-

695.23

(5)

Total

166,971.27

168,939.88

* Criteria for Con

version to GJ: Nation

al Energy Balance Da

ta, 2015.

(1)

Business units surveyed: A

GEA; Art

ear Canal 13; Can

al 12; Pol

-ka; Gestió

n Compartida;

La Voz del Interi

or; Los Andes

; Radio Mitre; an

d TyC

Sports. AGEA Tacua

rí considers its ow

n energy cons

umption and th

at of Grupo Cla

rín. Eldoce do

es not include pow

er sold to the

grid (1.674

MWh).

(2)

Business units surveyed: A

GEA; Art

ear Canal

13; Canal 12; P

ol-ka; La Voz

del Interior; Los

Andes; Radio

Mitre; and TyC Spor

ts. AGEA

Tacuarí considers its

own energy c

onsumption and

that of Grupo Cl

arín.

(3)

Includes the consumptio

n of generat

ors and outside

broadcast units.

Generators: Busin

ess units survey

ed: Canal 1

2

Outside broadcast

units: Business

units surveyed: A

GEA Zepita; Can

al 12; Los Ande

s; and Radio Mitr

e. For Los A

ndes it was wei

ghted

at 100%

(based on estim

ates, 720 liters).

”

(4)

Includes the consumptio

n of generat

ors and outside

broadcast

units.

Generators: Busin

ess units survey

ed:

AGEA - Canal 13 - C

anal 12 - Polk

a - LV

I - Los Andes - Ra

dio Mitre.

Los Andes: Weigh

ted at 100% (ba

sed on estim

ates, 150 lite

rs).

Outside broadcast

units: Business

units surveyed: C

anal 13 - Ca

nal 12

(5)

Business units surveyed:

Canal 12.

Greenhouse Gas Emis

sions

(in tons of CO

2

equivalent)

2020

2021

Direct Emissions (Scop

e 1)

(1)

2,237.07

2,366.98

Indirect Emissions (Sc

ope 2)

(2)

16,298.06

15,060.33

Other Indirect Emiss

ions (Scope 3)

(3)

4,078.76

59,759.58

Total

22,613.89

77,186.89

(1)

Business units surveyed: A

GEA; Art

ear Canal 13; Can

al 12; Pol

-ka; La Voz

del Interior; Los

Andes; Radio

Mitre; and TyC Spor

ts.

(2)

E

mission

factor

used:

0.4282

tCO2

/MWh,

accordi

ng

to

the

National

Se

cretariat

of

Energy

i

n 2

019.

Calculate

d o

n t

he

basis

of

35,171.26

MWh

of

electri

city

consumption

of

the

business

units

surve

yed.

Business

unit

s

surveyed:

AGEA;

A

rtear

Canal

13;

Ca

na

l

12;

P

ol

-ka;

Gestión Compartid

a; La Voz del I

nterior; Los Ande

s; Radio Mitre; a

nd TyC Sp

orts.

(3)

Business units

surv

eyed: Radio Mitre and TyC Sports. The variation from 2020

is due to higher long-distance air travel due to the reactivation of

the activities of the

business units

upon the end

of the mandato

ry social isolati

on.

In

or

der

to achieve more sustainable logistics, La

Voz del Interior op

tim

ized the

rou

tes by

c

onsolidating

the

points

of

s

ales.

TyC

Spo

rts

carefully

planned

the

tr

ips

of

the

camer

a

operator

s

and

produc

tion

teams

in order to reduce fue

l consumption.

12.5.

WAST

E

3.73 tons of donate

d paper

The

reduction

of

was

te

is

a

priority

in

the

manageme

nt

of

o

ur

busin

ess.

With

regard

to

hazardous

waste,

the Group works with authorized companies

for its proper final disposal. For non-

hazardous waste, the

Company assesses

the waste that c

an be reused and

the waste for final

disposal.

The

main

material

that

is

recovered

within

G

rupo

Cl

arín

is

paper,

part

of

it

is

reintroduced

into

the

production process and the rest is donated to different organizati

ons such as Fundación Garrahan and

Hospital Pedro de E

lizalde (formerly, C

asa Cuna)

During 2021,

La

Voz de

l Int

erior undert

ook the

commit

ment of r

educing

by 5%

the

waste

generated

in

its

production

pr

ocess

within

t

he

ye

ars.

As

part

of

th

is

initiative,

it

began

an

internal

waste

classification

and

paper

recycling

cam

paign,

together

with

Papelera

Cumbre,

and

distr

ibuted

contain

ers

to sort waste in differe

nt areas and sectors

of the com

pany.

52

Waste by type

(i

n tons)

2020

2021

Total Hazardous W

aste

64.766

95.49

(1)

Total urban-like or no

n-hazardous w

aste

407.732

973.95

(2)

Waste is not impor

ted or exported,

for further details see

GRI Content Inde

x, Note 17.

(1)

Business units surveyed

: AGEA; Artear

Canal 13; Gestió

n Compartida;

Los Andes; a

nd TyC Sports.

(2)

Business units surveyed

: AGEA; Artear

Canal 13; Pol

-ka; Canal 1

2; Gestión Com

partida; L

a Voz del Interior

Los Andes; and TyC

Sports.

12.6.

WATE

R AND EFFLUE

NTS

79.71

9

megaliters of water con

sumption

Within the

Gro

up, t

he

main

effluents

com

e from

the dev

elopment

processes

carr

ied

out

at th

e

printing

plants.

Before

discharged,

they

undergo

a

process

of

treatmen

t

and

me

asurements.

Diar

io

Clarín’s

printing plant re-

uses water

, which und

ergoes a treatm

ent

and the resu

lting waste

is treated acc

ording

to Law 24,051.

The

Com

pany's

office

buil

dings

a

nd

other

f

acilities

only

discharge

dom

estic

wa

stewater.

In

order

to

save water, the Com

pany has automatic s

hut-of

f faucets and

detection sys

tems installed in the

toilets.

At La

Voz

del

Interior,

wast

ewater

is trea

ted a

nd th

en r

eused

for

irrigation

at

the

company

's

premises.

The

plant

is

audited

on

an

annual

basis

by

the

Ministry

of

the

Environm

ent

of

C

órdoba

and

complies

with the chemical as

sessment provide

d by Na

tional Decree No.

847/16.

Water Discharge

2020

2021

Annual Volume Disc

harged (in megaliters

)

4.85

38.65

Business

units

s

urveyed:

AGEA

Zepita; L

a V

oz

del

Interi

or

and

Los

A

ndes.

3.65

me

galiters

were

poured i

nto

water

stress

a

reas

by

the

business

unit Los Andes. Fo

r further details, s

ee GRI Content

Index, Note 15.

13.

RISK FACTORS

As

an

Argentine

corporation,

G

rupo

Clarín

S.

A.

(the

“Comp

any”)

is

exposed

t

o

a

wide

ra

nge

of

risk

s

the

cou

ntry

and

to

its

operations.

The

Company

rel

ies

on

a

str

ong

internal

co

ntrol

system.

The

identification

o

f

r

isk

and

its

asses

sment

is

part

of

the

Company’s

business

plans

a

nd

is

also

addressed by a corpor

ate based contro

l department a

nd by the Co

mpany’s board

on a regular basis.

Risks Relating to Argent

ina

Overview

A

substantial

m

ajority

of

the

Company

’s

property,

o

perations

a

nd

customers

are

loc

ated

in

Argentina,

and

a

portion

of

its

assets

a

nd

liabilities

are

d

enominated

in

foreign

curr

encies.

Accordin

gly,

our

financial

condition, results of operations an

d cash flows depend to a significant extent on economic and political

conditions

prevailing

in

Arg

entina a

nd

on

the

exchang

e rates

be

tween

the

Argentine

peso

and

forei

gn

currencies. In

the recent past,

Argentina has experienced severe recessions,

politi

cal

crises, periods of

high

inflation

and

sign

ificant

currency

devaluat

ion.

The

Argenti

ne

economy

ha

s

been

volatile

since

2011,

with

ye

ars

of

econo

mic

growth

and

others

wi

th

recess

ion.

For

example,

Argentina’s

econo

my

grew

in

2017

a

nd

2021,

but

co

ntracted

in 2018,

2

019

and

2020.

Several

fa

ctors

have

imp

acted

negatively

the

Argent

ine

e

conomy

in

the

recent

past,

an

d

m

ay

continue

to

impact

it

in

the

f

uture,

including

among

others,

inflation

rates,

exchange

rates,

commodity

prices,

level

of

Argentine

Centra

l

Bank

(“BCRA”)

reserves

, public

debt, t

ax press

ures, tr

ade and

fiscal

balances,

government

policy, t

he

international context a

nd further deve

lopments of the CO

VID

-19 pandemic.

9

Business units su

rveyed: AGEA; A

rtear Canal

13; Canal 6; Pol

-Ka; Ge

stión Compartida

; Los Andes; TyC S

ports; and La V

oz del Interio

r

.

53

Devaluation

of

the

Arge

ntine

peso

and

for

eign

exchange

controls

ma

y

adversely

affect

our

results

of

o

perations,

o

ur

capital

e

xpenditures,

our

ability

to

procure

i

mported

g

oods

and

services and our ability

to service ou

r liabilities an

d pay dividends.

Since we

generate

a substantial

port

ion

of

our

reven

ues

in

Argent

ine

Pesos

(our

functi

onal c

urrency),

any

devaluation

may

negat

ively

affect

the

U.S.

dollar

value

of

our

earn

ings

while

increasing,

in

Peso

terms,

our

expenses

and

c

apital

ex

penditures

denominate

d

in

foreign

currency

.

The

Argentine

Peso

has

been

s

ubject

to

s

ignificant

d

ev

aluation

ag

ainst

the

U.

S.

dollar

in

the

past

an

d

may

be

subject

t

o

fluctuations

in

th

e

future.

The

v

alue

of

the

p

eso

compared

to

other

curr

encies

is

dep

endent,

amon

g

other

factors,

on

the

level

of

in

ternational

reserves

maintained

by

the

BCRA,

which

have

a

lso

s

hown

significant fluctuations in

r

ecent years. The

Argentine macroeconomic environment, in which

w

e

operate,

was

af

fected

by

the

c

ontinued

devalu

ation

of

the

peso,

wh

ich

in

turn

had

and

cou

ld

continue

to have a direct impac

t on our financial and ec

ono

mic posit

ion.

The value of the Peso has fluctuated significantly in the past. In 2021, the Argentine Peso continued to

depreciate against the U.S. dollar and other major foreign currencies. According to Communicat

ion “A”

3500 of

t

he BCRA,

the peso/dollar exchange rate

stood at

Ps. 102.75

per US$

1.00 as of

31 December

2021,

evidencing

a deva

luation

of

the

p

eso

of

ap

proximately

22.1% fro

m

its

val

ue

of

84.15

Pesos

per

dollar at

31 December 2020 (compared to 40.5%,

58.9

% and

102.2% in the years en

ded 31 Decem

ber

2020,

2019

and

2018,

re

spectively).

As

a

r

esult

of

the

Argentine

Peso’s

inc

reased

vo

latility,

the

Argentine

government

and

the

BCR

A

implemented

several

measures

to

stab

ilise

its

value,

including,

among

others,

stronger

ex

change

regulatio

ns,

an

increase

i

n

short

term

interest

rates

and

th

e

sale

of

foreign currency reserves made by

the BCRA. The continued devaluation of

the Argentine Peso during

the

past

years

has

had

an

d

continues

to

have

a

neg

ative

impact

on

the

payme

nt

of

foreign

currency

denominated

debts

by

local priv

ate sec

tor

debtors

to

u

nrelated

foreign

ent

ities,

and

has a

lso

led

to

an

increase

in

inflation,

w

hich

in

turn

has

a

direct

impact

on

real

w

ages.

The

devaluation

has

also

negatively impacted businesses whose

success is

dependent on

domesti

c

market demand, and

adversely

affected

the

Argentine

governm

ent’s

ability

to

honour

its

foreign

debt

commitments.

Any

further

depreciation

of

t

he

Argen

tine

Peso

or

our

inability

to

acquire

foreign

currency

could

h

ave

a

material adverse effect

on our financial condition and

r

esults of

operat

ions. We

cannot predict whether,

and

to

what

extent,

the

val

ue

of

the

Argentine

Peso

could

depreciate

against

the

U.S.

dollar

and

the

way i

n which any

such fluctuations could affect

demand for

our products and

servic

es. Furtherm

ore, no

assurance

can

b

e

given

that,

i

n

the

future,

no

additio

nal

currency

or

foreign

exc

hange

restrictions

or

controls w

ill

be

impose

d.

Existing

an

d f

uture

measure

s

may

negative

ly aff

ect

Argentina

’s

international

competitiveness, discouraging

fore

ign

invest

ments

and

lending

by

for

eign

investors

or

increasin

g

foreign capital

outflow which

could have an

adverse effect

on economic

activity in A

rgentina, and which

in

turn

co

uld

adverse

ly

affect

our

bus

iness

and

results

of

opera

tions.

We

cann

ot

pred

ict

how

these

conditions

will

affec

t

the

con

sumption

of

prod

ucts

and

s

ervices

prov

ided

by

our

sub

sidiaries

or

our

ability

to

me

et

our

liabilities

denominated

in

curr

encies

othe

r

than

the

Argent

ine

Peso.

Any

res

trictions

on

transferring fu

nds abroa

d i

mposed by

the govern

ment

could u

ndermine

our

ability

to p

ay divid

ends on

our

GDSs

or

make

pay

ments

(of

principal

or

interest)

under

our

outstanding

indebt

edness

in

U.S.

dollars, as well as to c

omply with any ot

her obligation

denominated in forei

gn currency

.

A

depreciation

of

the

Argentine

Peso

a

gainst

major

foreign

c

urrencies

may

a

lso

hav

e

an

a

dverse

impact

on

our

subs

idiaries’ capital

expenditure program

and increase

the

A

rgentine Peso amount

of their

trade

liabilities

and

financ

ial

d

ebt

denominated

in

foreign

curr

encies.

Certa

in

of

our

subsidiaries

seek

t

o

manage

the

risk

of

dev

aluation

of

the

Argentine

Pes

o,

by

entering

from

t

ime

to

time

into

c

ertain

DFI

agreements an

d futures

c

ontracts in

order to

hedg

e

s

ome

of

their

ex

posure

to foreign

curr

ency

fluctuations.

H

owever, they

remain

hig

hly

ex

posed

t

o

risks

associate

d

with

the

fluctuation

of

the

Argentine Peso.

In September

2019,

in light

of the

econ

omic instabi

lity and t

he signi

ficant devalu

ation that

followed

the

primary

elections

as

described

below,

the

Argen

tin

e

g

overnment

and

the

BCRA

adop

ted

a

ser

ies

o

f

measures

reinstating foreign

exchan

ge

c

ontrols,

which am

ong other

things

,

s

ignificantly curtailed

access

to

the

official

foreign

ex

change

market

(the

“FX

Market”)

by

individuals

and

entities.

Higher

54

restrictions

to

access

the

o

fficial

FX

markets

were

imposed

during

20

20,

w

ith

a

v

iew

to

reduci

ng

the

loss of international res

erves generated by a

greater demand of US

dollars by individu

als and

companies.

Pursuant

t

o C

ommunicat

ion “

A” 7

106

(as

amende

d

and

supplement

ed

from

time

to

tim

e),

the

BCRA

established

c

ertain

requiremen

ts

to

acce

ss

the

local

exchang

e

mark

et

for

purposes

of

repayment of

cross

-border financial

debts,

in

particular, for

the payment

of

principal outstanding

amounts

in

loans

and

s

ecurities

hav

ing

a

mortisatio

n

pay

ments

sc

heduled

betw

een

15

October

2020

and

31

D

ecember

2021

fo

r

principal

amounts

ex

ceeding

US$2,000,000

by

th

e

non

-

financial

private

sector

and

financial

entitie

s.

Particularly,

the

paymen

t

of

pr

incipal

amou

nts

pertaining

to

loans

and

securities

subject to

the regulation

should be

part

of a

r

efinancing

plan that

m

ust

be previously

file

d

with

the

BCRA, which

must provide

that

(i)

only 40%

of

the principal

amount owed

a

nd payable

sha

ll

be paid

through

the

local

foreign

exchange

market

on

or

p

rior

to

31

March

2021;

an

d

(ii)

the

remaining

60

%

must

be

r

efinanced

so

the

average

life

of

the

debt

is

increased

f

or

a

minimum

of

two

years

.

Purs

uant

to Communication “A” 7416, the

BCRA the requirements

set forth

by Communication “A” 7106 are also

applicable

to

amortizati

on

p

ayments

of

princip

al

ou

tstanding

amoun

ts

i

n

loans

and

securities

sche

duled

between 1 Jan

uary 2022

and 30

June 20

22. It is

not

possible to

guarantee

that t

he period covere

d by

Communication

“A”

7416

will

n

ot

be

extende

d

or

reins

tated

i

n

the

futur

e

by

the

BCRA

or

that

oth

er

regulations

with

similar

effects

will

be

issued

that

would

require

our

subsidiaries

to

refinance

their

obligations, which

in turn could hav

e a negative

impact on s

uch subsidiari

es, and in particu

lar, on their

ability to meet debt ob

ligations.

In

addition,

foreign

exchange

controls

affect

the

ab

ility

of

Argentin

e

com

panies

to

pay

for

imported

goods and services, which may affect our ability to

proc

ure essential inputs and affect our

subs

idiaries’

operations, results an

d cash flows

.

Economic

and

political

developments

in

Argentina,

and

future

policies

of

t

he

Argentine

government may affe

ct the economy as w

ell as the o

perations of the media i

ndustry.

The

Argentine

gov

ernmen

t

has

historic

ally

exerc

ised

significan

t

influe

nce

over

the

ec

onomy,

a

nd

telecommunications

companies

in

particu

lar

have

operated

in

a

highly

regulated

environment.

T

he

Argentine govern

ment may prom

ulgate num

erous, far

-reaching re

gulations aff

ecting the ec

onomy and

media companies in

particular.

In

October

2019,

Alberto

F

ernández

was

elected

president

o

f

Argentina

and

took

office

on

10

December

2019. Fernández announced and implemented a wide range of

ec

onomic and policy reforms. In Ma

rch

2020,

in

response

to

t

he

COVI

D

-19

out

break,

the

Arg

entine

g

over

nment

enforced

the

AS

PO

(Preventive

and

Mandatory

Social

Isol

ation),

w

hich

ca

used

s

ignificant

disruption

to

socia

l,

opera

tive,

economic

a

nd

mark

et

activities.

In

Au

gust

2020,

Dec

ree

No.

690/20

dec

lared

Inf

ormation

an

d

Communications

Technology

(“ICT”)

s

erv

ices

as

an

essential

public

service

and

imposed

tariff

regulations

on

such

services,

introducing

the

p

ossibility

of

invo

lvement

by

that

agency

in

the

price

negotiations betwe

en content on suc

h services a

nd signal prov

iders, such

as our s

ubsidiary ARTE

AR.

Decree

No.

690/20

has

be

en

subject

to

s

everal

legal

proceedings

challenging

its

constitutionality.

As

of

the

date

h

ereof,

the

federal

judiciary

has s

uspended

the

effects

of

Decree

No.

690/20

unti

l

21

April

2022.

As

of

th

e

date

of

these

an

nual

report

th

e

inj

unction

w

as

extended

for

an

add

itional

six

-month

period.

On 13 March 20

20, the Min

ister of Econo

my addressed a

letter to the Par

is Club

members express

ing

Argentina’s

decision

to p

ostpone u

ntil 5

May

2021 t

he

US$2.1

billion

payment

originally

due

on

5

May

2020,

in

ac

cordance

wit

h

the

terms

of

the

set

tlement

agreement

the

Republic

had

re

ached

with

the

Paris Cl

ub m

embers

on

29

May

2014

(the “

Paris

Club

2014

Settlemen

t Agr

eement”)

. In

addition,

on

7

April

2020,

the

Minister

of

Economy

s

ent

the

Par

is

Club

m

embers

a

proposa

l

to

mod

ify

the

ex

isting

terms of the

Paris Club 2014 Settlement Agreement, seeking mainly an extension of

the maturity dates

and a significant reduct

ion in the interest rat

e.

On

22

June

2021,

the

Minister

of

Economy

ann

ounced

t

hat

Argenti

na

had

obta

ined

a

“time

brid

ge”

within the framework

of the Paris Club

negotiations, cons

equently avoiding defau

lt. The understa

nding

55

provides that Argentina will have

until 31 March 2022 to reach

a restructuring agreement with the Paris

Club members, while it

continues

with i

ts efforts to reach an

agreement with the IMF for

the refinancing

of

the

debt

incurred

u

nder

t

he

S

tand

-

By

Arrangement

(“SBA”)

a

nnounced

in

Ju

ne

2018.

The

Minister

of

Economy indicated that

d

uring the

e

ight-

month time

bridge, instead

of having

to repay ap

prox

imately

US$2.4 billion

as originally scheduled, Argentina

is expected

to make payments

tot

alling approximately

US$430 million.

On 18

August 2020, Argentina offered holders of its

foreign currency bonds governed by Argentine law

to

excha

nge

such

bonds

for

new

bonds,

on

ter

ms

th

at

w

ere

e

quitable

to

the

terms

of

the

i

nvitation

made

to

holders

of f

oreign

law-governed

bonds.

On

1

8

Sep

tember

2020,

Argentina

announced

that

holders

representing 99.4% of the aggregate principal amount outstan

ding of all series of el

igible bonds invited

to

partici

pate

in

the l

ocal

ex

change

of

fer

had

participate

d.

As

a

resul

t

of

t

he

exchange

offer,

the average

interest

rate

pa

id

by

Argen

tina’s

for

eign

c

urrency

bonds

governed

by

Argentine

law

was

lowered

t

o

2.4%,

compared

to

an

aver

age

interest

rate

of

7.6%

p

rior

to

the

exchange.

In

addition,

the

exc

hange

offer extended the avera

ge maturity of such

bonds.

During

2021,

Argentina

sought

to

preserve

the

normal

functionin

g

of

t

he

local

capital

market

for

debt

denominated

in

Pesos

,

wh

ich

it

considers

a

key

fac

tor

for

the

d

evelopment

of

the

domestic

capital

market.

In

addition,

t

he

Treas

ury

expanded

its

me

nu

of

financi

ng

instruments

to

obtain

th

e

funds

needed

to cover its 2021 financ

ial needs.

As

of

th

e

date

of

the

Com

pany’s

Annual

R

eport,

th

e

A

rgentine

govern

ment

is

under

negotiations

with

the International

Monetary Fund (“IMF”

) in order

to renegot

iate the principa

l maturities of

the US$ 44.

1

billion

disbursed

between

2018

and

2019

under

an

SBA,

or

iginally

planned

for

t

he

years

2021,

2022

and

2023.

On

28

J

anuary

2022,

the

IMF

and

the

Arg

entine

authorit

ies

reached

an

understandi

ng

on

key policies

as

part of

their

ongoing

discussions

on a

n IMF

-supported

program.

On 4

March

2022,

the

Argentine Government reac

hed a staff-

le

vel agreeme

nt with the International Mone

tary Fund and a bill

was

sent

to

the

Argenti

ne

Congress.

On

17

March

2022,

C

ongress

enac

ted

L

aw

No.

27,

668,

which

supports

the

agreement

be

tween

Argen

tina

an

d

the

International

Monetary

Fund.

We

canno

t

ass

ure

whether the Ar

gentine gov

ernment w

ill be succes

sful in

the negotiations

with tha

t agency

, which co

uld

affect its ability to implement reforms

and public policies

and boost economic growth, nor the impact o

f

the result

that

renegotiation

will

have

in

Argentina’s

ability to

acc

ess internat

ional

capital

markets (a

nd

indirectly

in

our

ab

ility

to

a

ccess

those

markets).

Moreov

er,

t

he

long

-term

i

mpact

of

these

measures

and

any

future

measures

taken

by

the

Arge

ntine

g

overnment

on

the

Argentin

e

economy

as

a

whole

remains

uncertain.

It

is

possible

that

such

reforms

cou

ld

be

disruptive

to

the

economy

and

adversely

affect

t

he

Argentine

econ

omy

and,

conse

quently,

our

bus

iness,

results

of

op

erations

and

financ

ial

condition. We are also unable to predict the

measures

that the Argentine

government may adopt in the

future,

and

how

they

will

im

pact on

the

Argentine

economy

an

d our

resu

lts

of

oper

ations

and

financial

condition.

In th

e

event

of

any

economic, s

ocial

or

politica

l cr

isis,

compan

ies

operating

in

Arg

entina

may

face

the

ri

sk of

strikes, expropriation

, na

tio

nalisation, mandatory amendment of

existing contracts, and

cha

nges

in

t

axation

policies including

tax increases

an

d

retroactive tax

claims. In

a

ddition, Argentine

co

urts

have

sanctioned

modifications

o

n

rules

relate

d

to

l

abour

matters

,

req

uiring

c

ompanies

to

assume

greater

responsibility

for

the

assumption

of

costs

and

r

isks

associated

with

sub

-contra

cted

labour

and

the

calculation

of

salaries,

sev

erance

payments

and

soci

al

sec

urity

c

ontributions.

S

ince

we

operate

in

a

context

in

which

the

gov

erning

law

and

a

pplicable

regulations

change

frequentl

y,

also

as

a

result

of

changes i

n gover

nment

administrations

, it

is

difficu

lt to

predict

if

and

how

our

acti

vities wi

ll

be af

fected

by such changes.

We cannot ass

ure you that

future

economic, reg

ulatory, social and

political dev

elopments i

n Argentina

will

not

adverse

ly

affect ou

r business,

financial

con

dition

or

results of

operati

ons,

or cause

the decrease

of the market value of

our securities

.

56

Inflation

could

ac

celerate,

caus

ing

adve

rse

effects

on

the

economy

and

neg

atively

impacting

our subsidiaries’ m

argins and/or ratios.

Argentina has

experience

d r

epeatedly, inc

luding in

recent years,

periods

of

high

inflation. I

nflation has

increased

since

20

05

and

has

remai

ned

relativel

y

high

since

then.

There

can

b

e

no

assuranc

e

that

inflation

rates

will

no

t

be

higher

i

n

the

fut

ure.

F

urthermore,

the

Nati

onal

Institute

of

Statistics

a

nd

Census

(“INDEC”)

experience

d

in

th

e

past

periods

of

po

litical

interventionism

that

raise

d

serious

c

onc

er

ns

about

the

reliability

of

the

data

published

by

that

agency.

Future

pol

itical

intervent

ion

in

the

INDEC

could

jeopardise the agency

’s autonomy and

therefore affect

the reliability of the stat

istics it publishes.

The National Consu

mer Pric

e Index (“CPI

”) variati

on was of

50.9% in 202

1 and 36.1%

in 2020. Efforts

made

by

the

Ar

gentine

gover

nment

t

o

contain

and

reduc

e

inflation

have

n

ot

achieve

d

the

desired

resu

lts

and

inflat

ion

re

mains

a

s

ignificant

problem

for

the

Argentine

economy.

If

the

value

of

the

A

rg

entine

Peso

cannot

be

s

tabilised

throug

h f

iscal

and

monetary

policies,

an

increase

in

infl

ation r

ates

could

b

e

expected.

Because

th

e

majority

of

ou

r

rev

enues

are

denominat

ed

in

Pesos,

any

further

inc

rease

in

the

rate

of

inflation not

ac

companied

by

a

pa

rallel increase in

our subsidiaries’

’

prices would decrease

our

revenues

in

real

ter

ms

and

adversely

a

ffect

our

resu

lts

of

operations.

F

urther,

higher

i

nflation

rates

generally lead

to a

reduct

ion in

the purch

asing pow

er,

thus increas

ing the

likelihood

of

a

lower

level o

f

demand for our subs

idiaries’ products a

nd services

in Argentina.

The Argentine governm

ent may exer

cise greater int

ervention in private se

ctor companie

s.

In N

ovember

200

8,

Argentina

nat

ionalised

its

privat

e

pension

and ret

irement

system

,

which

had been

previously

administered

by

privat

e

p

ension

funds

(

the

“AFJPs”)

and

appointed

the

National

S

ocial

Security

Administration

(“ANSES”)

as

its

ad

ministrator.

Argentina’s

nat

ionalisation

of

its

pensio

n

and

retirement

sy

stem

const

ituted

a

signifi

cant

change

in

the

Arg

entine

govern

ment’s

approach

towards

Argentina’s main publicly traded

co

mpanies. A significant po

rt

ion of

the public float of certain A

rgenti

ne

publicly

traded

comp

anies

is

c

urrently

owned

by

th

e

Argentine

govern

ment

t

hrough

ANSES

-FGS

,

including

Grupo

C

larín.

The

Argentine

g

overnment

exercised

in

th

e

past,

an

d

may

e

xercise

in

t

he

future,

influence over

corporat

e go

vernance

decisions

of co

mpanies

in

which i

t owns

shares

by c

ombining

its

ability to

exercise its shareholder

voting rights to designate board

and supervisory committee members

with

its

ability

to

dict

ate

tax

and

regulatory

matters.

Additionally,

since

th

e

AFJ

Ps

were

sig

nificant

institutional

investors

and a

ctive mark

et traders

in

Argentina,

the

nationalisati

on o

f the

private

p

ension

and

retirem

ent

sys

tem

affected the

access

to

financing in capi

tal markets for

publicly traded

c

ompanies

as well as the liquidity

of their securities w

ithin the mark

et.

The

Argent

ine government exercised

in the pa

st, and may

exercise in the

fut

ure, decisio

ns to

intervene

private co

mpanies

in

financial

distress

. W

e c

annot pre

dict

whether

the

current

ad

ministration

or

future

administrations

will

take

similar

or

furth

er

measures,

including

nationalisation,

expropria

tion

and/or

increased

Argentine

g

overn

mental

intervention

in

companies.

Governme

nt

interven

tion

in

the

industries

in whi

ch

we

operate could create

uncertaint

ies for

inves

tors in

public companies in Argentina,

including

Grupo Clarín, as

wel

l as

hav

e a

material adverse effect on our business, financia

l condition and results

of operations.

Although Argentina’s economy grew

during

2021,

it has experienced contractions in

2020,

2019

and

20

18

and

m

ay

contract

in

the

future

due

to

internatio

nal

and

do

mestic

condition

s,

w

hich

may adversely affect ou

r

operations.

The

Argentine economy

ha

s

experienced significant

volatil

ity

in

the

past few

years

and recent

deca

des,

characterised

by

periods

o

f

l

ow

or

neg

ative

GDP

growth,

high

a

nd

variable

levels

of

inflation

and

currency

devaluation.

Argentina’s

econ

omy

grew

during

2021,

but

c

ontracted

during

2

020,

2019

an

d

2018 and the country’s economy rem

ains unstable notwithstan

ding the efforts

by the Argentine

government

t

o

a

ddress

inflation

and

t

he

co

nstraints

on

the

country’s

foreign

exchange

reserv

es

an

d

57

on

the

val

ue

of

the

peso.

Substantial

ly

all

of

our

subsidiaries’

operations,

prop

erties

and customers

are locate

d in Argent

ina, and, as

a result,

our business

is, to a

large extent,

dependent

upon

econo

mic

and

legal

c

onditions

prevailing

in

Argent

in

a.

If

economic

conditions

in

Argentina

were

to

further deteriorate, they could

have an

adverse effect on

our results

of operations, financial

con

dition

and cash flows.

Global

econom

ic

and

fin

ancial

crises,

a

nd

the

general

w

eakness

of

the

global

economy

due

to

t

he

COVID-

19

pan

demic

ne

gatively

affected

emerging

economies

like

Argent

ina’s

economy

.

Globa

l

financial

instability,

any

furt

her

economic

g

lobal

downturn

due

to

COVID

-19

and

any

fut

ure

increases

in the

interest of

the

United

States

a

nd o

ther

develop

ed countr

ies

may

impact

the

Arge

ntine

economy

and preven

t Argen

tina to

be

put

back

on track

to

grow

th or

could

aggravate

the

current reces

sion

with

consequences in the trad

e and fiscal bal

ances and in the unem

ployment rate.

Although

Argentina’s

econo

my

has

rec

overed s

ubstantially

during

202

1, Arg

entina’s

economic

growth

was

severely

impacted

as

a

conse

quence

of

t

he

CO

VID

-19

pa

ndemic.

It

might

also

be

negatively

affected

in

the

f

uture

by

se

veral

domestic

factors

suc

h

as

an

a

ppreciation

of

the

rea

l

ex

change

rate

which

could

aff

ect

its

co

mpetitiveness,

red

uctions

and

even

revers

ion

of

a

positive

tr

ade

balance,

which,

combined

with

capital

outf

lows

could

reduce

the

leve

ls

of

c

onsumption

and

investment

resulting

in

greater exchange rate press

ure. Additionally, a

brupt changes in monet

ary and fiscal policies or foreig

n

exchange regime cou

ld rapidly affect loca

l economic output, w

hile lack of appropriat

e levels of

investment

in

certai

n

economy

sec

tors

could

reduce

lo

ng

-term

growth.

Access

to

the

international

financial markets could be limited. Consequently,

an increase in public spending not correlated with an

increase in pu

blic revenues

could

affect Argentina’s fiscal results and

generate un

certainties that might

affect the economy

’s growth level.

In

addition

to

the

severe

s

ocial

and

m

arket

disrupt

ion

at

a

global

scale

durin

g

2020

ca

used

by

the

COVID 19 outbreak

, in recent years, severa

l trading partners

of Argentina (such

as Brazil, Europe an

d

China) have ex

perienced s

ignificant slowdowns

or recession per

iods in

t

heir ec

onomies. These

slowdowns

intensified du

rin

g

20

20.

While

th

e

vas

t

maj

ority

of

econom

ies

recovere

d

during

2021,

if

s

uch

slowdowns or

r

ecessions were

to

recur,

this may

impact the

d

emand for

products

coming from

Argentina

and hence

affe

ct its

economy.

Ad

ditionally, th

ere is

uncertainty

as

to

how the

trade

relationship

between

the

Mercosur

member

States

wil

l

unfold,

in

particular

between

Argentina

and

Brazil.

We

ca

nnot

pre

dict

t

he

effect

on

the

Argentine economy

and

our

operat

ions

if

tr

ade

d

isputes

arise

between Argentina

and Brazil, or in case eit

her country decided t

o exit the Merc

osur.

In

addition,

the

global

macroecono

mic

environment

is

facing

chal

lenges.

There

is

consider

able

uncertainty over

the l

ong-

term effects

of the

expa

nsionary mone

tary and

fi

scal

policies ado

pted by

the

central

banks

and fina

ncial

authorities

of s

ome

of

the

world’s

leading

econ

omies,

including the

United

States

and

Chin

a.

There

have

been

concerns

over

unrest

and

terror

ist

threats

in

the

M

iddle

East,

Europe

and

Afr

ica

and

ov

er

the

conflicts

invo

lving

Iran,

Ukr

aine,

Sy

ria

and

Nor

th

Korea.

M

oreover,

political

a

nd

soc

ial

cr

ises

a

rose

in

several

countries

of

Latin

America

during

20

19,

as

the

economy

in

much of

t

he reg

ion

has s

lowed

down

after

almost

a

decade

of

sustained

growth,

amo

n

g oth

er

factors.

There

have also

been concerns

on

the

relationship among

China and

other Asian

countries, which

may

result in or

intensify potenti

al conflicts in

relat

ion to

terr

itorial disputes, and the possibility

of a trade war

between

the

United State

s

and

China. In

addition, United

Kingdom exited

the

European

U

nion

(“Brexit”)

on 31

Ja

nuary 2020. The

medium and long-term implications of B

r

exit could

advers

ely

affect European

and

wor

ldwide economic

and market

cond

itions

and

co

uld

c

ontribute

to instability in

globa

l

fin

ancial

and

foreign exchange mark

ets.

Furthermore, in February 2

022, Russian troops invade

d Ukraine. Although the sev

erity and duration of

the

ongoing

m

ilitary

action

are

highly

unpredictable,

the

conflict

in

Ukraine,

Russia’s

prior

annexa

tion

of

Crimea,

recent

reco

gnition

of

two

separatist republics

in

the Donetsk

and

L

uhans

k

regions

of

Ukraine

and

s

ubsequent

military

interventions

in

Ukra

ine

have

led

to

sanct

ions

being

levied

by

the

U

nited

States,

the European U

nion and other c

ountries ag

ainst

Russia, with ad

ditional poten

tial sanctions thre

atened

and/or

propose

d.

Russia’s

military

incursion

and

the

market v

olatility

could

adversely

affect

the

global

58

economy

and

fina

ncial

markets

and

thus

could

affect

our

business,

fi

nancial

c

ondition

or

r

esults

of

operations.

The

extent

an

d

duration

of

the

mi

litary

action,

s

anctions

and

res

ulting

mark

et

disruptio

ns

are

impossible

to

pre

dict,

but

could

be

subst

antial.

Any

s

uch

disruptions

cause

d

by

Russian

military

action or resulting

sanc

tions may magnify the impact of other

risks described in this Annual Report and

may result in compliance

and operat

ional challenges for the C

ompany.

If

internat

ional

and

domest

ic

conditions

for

Argent

ina

were

to

worsen

d

ue

to

the

aforement

ioned

f

actors,

the

Argentine

ec

onomy

could

be

negatively

affected as

a

result

of

lower

internat

ional

dema

nd

and

low

er

prices for

its products

and

serv

ices, higher i

nternational

interest r

ates, lower

capit

al inflows

and hig

her

risk

aversion,

which

may

al

so

adversely

affect

ou

r

bus

iness,

results

of

operations,

financ

ial

condition

and cash flows.

The coronavirus and the measur

es taken or to be imp

lemented by the Argen

tine government in

response

to

the

coron

avirus

have

had

and

could

c

ontinue

to

hav

e

a

significant

adverse

effect

on our business oper

ations

In late

December 2019, COVID-19, originating from Wuhan,

Hubei province, was reported

to the World

Health

O

rganisation,

with

cases

s

oon

c

onfirmed

in

multiple

provinces

in

Chin

a,

as

well

as

in

oth

er

countries.

On

11

Marc

h

2020,

t

he

Wor

ld

Health

O

rganisation

categor

ised

COVI

D

-19

as

a

pa

ndemic.

Several

measures

have been

undertake

n

by

the A

rgen

tine

G

overnme

nt

and

other governments

around

the

globe,

including

the

use

of

quarantine,

screenings

at

airports

and

other

transports

hub,

tra

vel

restrictions,

suspe

nsion

of

visas,

nation

-wide

lockdo

wns,

closing

of

public

a

nd

private

institutions,

suspension

of

s

port

events,

restrictions

to

museums

a

nd

tourist

attractions

and

e

xtension

of

h

olidays,

among many others. However, the virus continues

to spread

globally and, as of the date of this Annual

Report, h

as

affected

most

countries

and

territories

aro

und th

e worl

d, inc

luding

Argentina.

To

date,

the

outbreak of

CO

VID-19 has caused

significant social, operational, economic and market

disrupt

ion. T

he

long-term

impact

on

the

gl

obal

ec

onomy

and

financial

mark

ets

is

still

uncerta

in,

but

is

expected

to

be

significant.

On

20

March

20

the

Argentine

government

impos

ed

a

s

eries

of

measures

aimed

at

reducin

g

the

movement

of

t

he

population,

ordering

the

ASPO,

which

only

allowed

the

mov

ement

of

individuals

involved

in

activities

considered

ess

ential

by

the

Argentine

governm

ent.

While

the

Argent

ine

government

has

determi

ned

t

hat

me

dia

serv

ices

c

onstitute

essential

s

ervices,

our

subs

idiaries’

operations were affec

ted by a decline in the sale of adv

ertising in all the media of Grupo Clarín, m

ainly

due to

cuts in our customers’ advertising budgets,

a drop in

circulation, with an impact on

subscriptions

as

from

the

second

quarter

of

the

year

and

an

increase

in

th

e

overdue

collection

of

receivab

les.

Television

audience

levels

were

affected

by

the

lack

of

production

of

certa

in

contents

for

prime

time,

which

were

s

uspended

due

to

the

p

andemic.

Our

subsidiaries

Autosports,

Pol

-ka

and

Cúsp

ide

were

forced

to

r

educe

or

suspen

d

most

of

their

op

erations

and

the

commerci

alization

of

their

products.

In

the

case

of

Pol-ka,

the

economic

impact

was

v

ery

sig

nificant.

Duri

ng

2020,

that

company

was

unable

to produce

any new

content

and

underwent

sev

ere di

fficulties

in

meeting

its

fi

nancial,

commercial

and

labour c

ommitments.

Since

then,

the

Argentine

govern

ment h

as

announced

and

impleme

nted

several

stimulus

measures

to

limit t

he

effects

of

the

COVID

-19

pandemic

on

the

eco

nomy,

which

include,

but

are

not

limited

to,

the

proh

ibition

of

the

discon

nection

of

electric

energy,

natura

l

gas,

runnin

g

water,

fixed

telephony,

mobile

te

lephony,

inter

net

and

ca

ble

television

s

ervices

du

e

to

no

n

-payment;

price

freezes

for

c

ertain

essential

goods

s

uch

as

food,

p

ersonal

care,

medic

ines

and

med

ical

products;

the

imposition

of

max

imum

prices

on

goods

and

services

acquired

by

the

federa

l

g

overnment

to

a

ddress

the emergency. The Argentine government also established a debt

r

egularization regime that will allow

self-employed

persons,

single-taxp

ayers

and

compani

es

to

access

a

pay

ment

plan

for

tax

and

soc

ial

security

debts,

sus

pended

rent

i

ncreases,

extende

d

l

ease

contract

ex

piration

dates

an

d

suspended

evictions due to non-

payment of le

ases until 31 March

2021.

Our

s

ubsidiaries

have

ha

d,

and

contin

ue

to

have

to

resolve

new

and

challenging

logistical

issu

ed

relating

to

the

co

mmute

of

employ

ees,

performers

and

journalists,

the

reconfigurat

ion

of

some

progr

ams

due

to

social

d

istancing

measures,

the

implem

entation

of

home

office

ma

inly

for

our

back

office

st

aff,

59

strict

s

anitation,

dis

infection

and

prevention

protoc

ols

at

the

various

off

ices

an

d

the

incor

poration

of

technologies required t

o ensure the virtua

l presence of talents i

n the production of

contents.

The long-ter

m effects

of the

pandemic

on the g

lob

al ec

onomy and t

he C

ompany a

re difficult

to assess

or

predict.

Although

the

C

ompany

has

devot

ed

cons

iderable

resources

to

pr

eventat

ive

me

asures

in

order

to

reduce

t

he

p

otential

impacts

of

the

CO

VID-

19

pandemic

on

its

employ

ees,

business,

s

ervice

and opera

tions,

there

can

be

no as

surance

that

these

measures

wi

ll

be ef

fective

or

that th

e

pandemic

will

not

hav

e

an

adverse

ef

fect

on

our

bus

iness,

fin

ancial

situa

tion

and

results

of

operations,

which

c

ould

result in further decline

in the market prices

of our Cl

ass B Shares

and GDSs.

Uncertain

evolution

of

t

he

COVID

-

19

pandem

ic

might

affect

employe

es’

health

and

s

afety,

generate

risks for

the deployment

of

our

subsidi

aries’

services

and

distrib

ution

of

the

ir

produ

cts,

result in

reduce

d

sales of

advertis

ing in ge

ne

ral and

reduced

sal

es

of

products in certain geographic locations,

affect our

revenues

and

result

in

a

general

economic

contrac

tion

in

Argentin

a,

which

could

in

turn

have

an

additional

adv

erse

effect

on

th

e

demand

of

our su

bsidiaries’

products

an

d

cons

equently

in

the

resu

lts

of our operations.

Any

prolonged

restrictive

measures

put

in

place

i

n

order

to

contro

l

a

new

outbreak

o

f

c

ontagious

disease

or

other

advers

e

public

h

ealth

deve

lopment

in

a

ny

of

our

targeted

m

arkets

may

have

a

material

and

adverse effect on our busin

ess operations. We may also be aff

ected by a decline in the dema

nd of our

subsidiaries’

serv

ice,

espe

cially

advertising,

as

a

re

sult

of

t

he

economic

contr

action.

It

is

unclear

whether

these

challenges

and

uncerta

inties

will

be

c

ontained

or

resolve

d,

and

what

effects

they

may

have

on

th

e

global

political

and

economic

conditions

in

the

long

term.

Additiona

lly,

we

cannot

pre

dict

how

the

disease

w

ill

evolve

(and

potential

ly,

spread)

in

Argentina

dur

ing

2021

d

ue

to

new

o

utbreaks

and

new

stra

ins

of

the

vir

us

that

have

appeared

practically

simultaneously

with

the

advance

of

the

vaccination

campaign,

nor

anticipate

what

add

itional

restrictions

govern

ments

of

other

countries

may

impose.

To

the

extent

COVID

-19

adversely

affects

our

business

and

fina

ncia

l

results,

it

may

also

exacerbate many of t

he other risks

described in this “Risk

Factors” sec

tion.

Notwithstanding

the

forego

ing,

th

e

outbreak

of

any

novel

strain

of

coronavirus

and

its

im

pact

on

the

demand of

our subsidiaries’ products and

the finan

c

ial markets,

among other factors, will

b

e

key issues

to

determi

ne

th

e

dur

ation

and

depth

of

the

economic

crisis

in

Argentin

a

an

d

worl

dwide,

as

well

as

o

n

our strategy, financial si

tuation and results of o

ur operations.

Argentina’s

abilit

y

to

obtain

finan

cing

f

rom

inte

rnational

ma

rkets

is

limited,

which

could

affec

t

its capacity to impl

ement reforms

and sustain econ

omic growth.

After

Argentina’s

de

fault

on

c

ertain

debt

paym

ents

in

2001,

the

gover

nment

successfully

restructured

92%

of

the

de

bt

thro

ugh

tw

o

debt

exch

ange

offers

in

2005

and

2010.

Nevertheless,

holdout

creditors

filed

numerous

lawsuits

ag

ainst

Argent

ina

in

severa

l

jurisdictions,

including

t

he

United

States,

Italy,

Germany

and

J

apan,

ass

erting

that

Arg

entina

failed

to

make

timely

pay

ments

of

in

terest

and/or

pr

incipal

on

their

bonds,

and

seeking

judgments

for

the

face

v

alue

of

and/or

accrued

interest

on

those

bonds

.

Judgments were issued

in numerous proce

edings in the Unite

d States, Germany

and Japan. Althoug

h

creditors

with favourable

ju

dgments did

n

ot

succeed, with

a few

minor

except

ions,

in enforcing

on

th

ose

judgments,

as

a

resu

lt

of

dec

isions

adopted

by

the

N

ew

York

courts

in

s

upport

of

those

c

reditors

in

2014,

Argent

ina

was

enjoi

ned

from

making

payments

on

its

bonds

issued

in

t

he

2005

and

20

10

exchange

offers

un

less

it

satisfied

amo

unts

d

ue

to

the

holders

of

defaulted

bo

nds.

The

Arg

entine

government

took

a

number

of

steps

intended

to

cont

inue

servicing

the

bonds

issued

in

the

2005

and

2010

exc

hange

offers,

whic

h

had

limit

ed

succ

ess.

Hold

out

c

reditors

continue

d

to

litigate

a

nd

suc

ceeded

in preventing the Arge

ntine government fr

om regaining mark

et access.

Between February and Apri

l 2016, the Argentine governmen

t entered into agreements in princip

le with

certain

holders

of

defa

ulted

debt

and

put

f

orward

a

proposal

to other

holders

of

defaulted

debt, i

ncludi

ng

those with pending cl

aims in U.S. courts, wh

ich resulted in the se

ttlement of subst

antially all remaini

ng

disputes

and

closure

to

15

years

of

l

itigation.

On

22

April

2016,

Argentina

iss

ued

b

onds

for

U

S$16.5

60

billion,

a

nd

applied US$9.3

billion of

the proceeds

to satisfy

payments

under the

settlem

ent

a

greements

reached

with

holders

of

defau

lted

debt.

Since

then,

s

ubstantially

all

o

f

the

r

emaining

c

laims

under

defaulted bonds have

been settled.

As

of

the

date

of

the

Company’s

Annual

Report,

altho

ugh

lit

igation

in

itiated

by

bondhold

ers

that

have

not

accepted

Argentina’s

s

ettlement

offer

continues

in

several

jurisd

ictions,

the

size

of

the

clai

ms

involved has decrease

d significantly.

In

add

ition,

s

ince

20

01

f

oreign

sh

areholders

of

some

Argentine

c

ompanies

initiated

c

laims

for

substantial

amounts

b

efore

the

Internat

ional

Cen

tre

fo

r

Settlem

ent

of

Investment

Disputes

(“ICSID”)

against

Argentina,

p

ursuant

to

the

arbitration

rules

of

t

he U

nited

Natio

ns

C

ommiss

ion

on

Internatio

nal

Trade

Law.

Clai

mants

allege

t

hat

certain

measures

of

t

he

Argentine

government

issued

during

the

economic

crisis

of

2001

and

2002

w

ere

inconsist

ent

with

the

norms

or

standard

s

set

forth

in

severa

l

bilateral

investment

treaties

by

which

Argentina

w

as

bound

at

the

time.

To

date,

several

of

th

ese

disputes have been settled, and a significant number of cases are in process or have been temporarily

suspended by the agree

ment of the parti

es.

Between

2016

and early

2018, Argentina

regained

acc

ess to

the

market

and i

ncurr

ed

in

additional debt.

However,

as

a

r

esult

of

var

ious

external

and

d

omestic

factors,

during

the

first

hal

f

of

2018,

acc

ess

to

the market

became increasi

ngly onerous.

On 8 May

2018, the Macri

administratio

n

announced that the

Argentine

government

would

initiate

negotiations

with

the

IMF

with

a

view

to

entering

into

a

stand

-by

credit facility

that wou

ld give Arge

ntina access

to finan

cing by th

e IMF. O

n 7

June 2018,

the

Argentine

government

and

t

he

IMF

staff

r

eache

d

an

unders

tanding

on

the

t

erms

of

t

he

SBA

for

d

isbursements

totalling

approximately

U

S$50

billion,

which

was

approved

by

the

IMF’s

Exec

utive

Board

on

20

June

2018.

The

SBA

w

as

intended

to

provide

support

to

the

M

acri

administration’s

economic

pro

gram

,

helping build

confide

nce, reduce

uncerta

inties and

strengthen

Argentina

’s econom

ic prospects

. O

n 22

June

2018

the

Argentine

government

made

a

first

drawing

of

approximately

US$15

billion

under

the

SBA.

Argentina

has

r

eceived

disburs

ements

und

er

the

S

BA

f

or

US$44

b

illion.

Notwit

hstanding

the

foregoing,

the

Arge

ntine

government

has

publ

icly

announced

t

hat

they

will

refr

ain

from

reques

ting

additional disbursements under

the agreement, and instead vowed to renegotiate its terms and

conditions

in

good

f

aith.

O

n

1

3

July

2

021,

the

Argentine

government

and

re

presentatives

of

the

IMF

met

i

n

Venice to

continue discussions

on

a

new program

that will

address the

term

s of

the

debt incurred

under

the

existing

SB

A.

Such

discussio

ns

reflect

ed

pr

ogress

on

matters

that

are

key

for

Arg

entina’s

economic program,

such as economic

recovery based on

employment generation, value-a

dded growth

and

lasting macroeconomic

stability.

On 22

Septem

ber

2

021, Argentina

r

epaid

the fi

rst principal

instalment under the

SBA of US$1.9

billion to

the IMF.

Following

the

execution

of

the

S

BA,

in

A

ugust

2018,

Argentina

faced

an

unexpected

bout

of

v

olatility

affecting emerging

markets ge

nerally. In Se

ptember 2

018, the Macr

i administration

discussed with t

he

IMF

staff

furt

her

measures

of

support

in

t

h

e

face

of

renewed

fi

nancial

volatility

and

a

ch

allenging

economic environment. On 26 October 2018, in light of the adjustments to fiscal and monetary policies

announced

by

the

Argentine

government

and

the

BCRA,

the

IMF’s

Execut

ive

Board

a

llowed

the

Argentine

governm

ent to

draw the

equiva

lent

of US$5.7

billio

n,

bringing total

d

isbursements since

J

une

2018

to

approximat

ely

U

S$20.6

billion,

ap

proved

a

n

augmentation

of

the

SBA

i

ncreasing

total

as

sets

to approx

imately

US$57.1

billion

for

the

dur

ation of

th

e

prog

ram

through

2021

an

d the

front

load

ing o

f

the

disbursements.

Under

the

revised

SBA,

IMF

res

ources

for

Argentina

in

2018

-

19

increased

by

US$18.9

billion.

I

MF

disbur

sements

for

the

r

emainder

of

2

018

more

t

han

doubl

ed

c

ompared

t

o

the

original IMF-supported

program, to a total of US$13.4 billion (in addition to the

U

S$15 billion disbursed

in

June

2018).

Disburs

ements in 20

19 were also nearly

doubled, to US$22.8 billion,

with US$5.9 billion

planned for 2020-

2021.

On

28

August

2019,

th

e

Macri

adm

inistration

iss

ued

a

decree

deferrin

g

the

schedu

led

payment

date

for

85%

of

the

amounts

due

on

short

-term

notes

matu

ring

in

the

fourth

quarter

of

2019,

governed

by

Argentine

law

and

he

ld

by

institutiona

l

i

nvestors.

Of

the

def

erred

amounts,

30%

would

be

repai

d

90

days after

th

e original

p

ayment date

and the

remainin

g 70%

wo

uld be

r

epaid 180

days after

the original

61

payment

date,

except

for

p

ayments

under

Lecaps

d

ue

2020

held

domestica

lly, w

hich w

ould

be

repaid

entirely

90

days

after

th

e

original

payme

nt

date.

Amo

unts

due

on

short-term

not

es

held

by

indiv

idual

investors would be pa

id as originally sched

uled.

Moreover,

in

December

2019,

the

Argen

tine

govern

ment

furth

er

ex

tended

by

decree

payments

of

a

series of

short-

term Argentine-law governed

treasury notes

denominated in

U.S. dollars held

by

institutional

invest

ors

through

August

2020.

Additionally,

on

11

February

2020,

t

he

Argentine

government

decreed

the

e

xtension

of

maturity

to

30

September

2020

of

a

dolla

r

-linked

treasury

note

governed

by

Argentine

law,

which

had

b

een

origin

ally

subscribed

to

a

large

extent

with

U.

S.

dollar

remittances, t

o avoid

a pay

ment wit

h Argentin

e pesos

that w

ould have

required

significant

sterilisation

efforts by the monetary

authority.

On

12

February 2020,

the

Argentine Congress

enacted Law

No.

27,544

for the

Sustainable Restoration

of Foreign-Law Governed Public Debt, which granted the Ministry of E

co

nomy the power to

restructure

the

Argentine

g

overnment’s

external

publ

ic

debt.

On

9

March

2020,

the

Executive

Branch

iss

ued

decree

No. 250/20 author

izing the Ministr

y of Economy to rest

ructure US$68,84

2 million in de

bt.

Following Law No. 27,544, on

10 March 2020, Decree No. 250/20 i

ssued by the Argentine government

established

the

maximum

nomina

l

amount

of

liab

ility

management

tra

nsactions

and/or

exchanges

and/or

restruc

turings

of

t

he

Repu

blic

of

Argentina’s

outs

tanding

publ

ic

securities

issued

under

for

eign

law

as

of

12

F

ebruary

20

at

the

nominal

value

of

US$68,842,528,82

6,

or

its

equivalent

in

other

currencies. How

ever, d

ue to

the COVID

-

19 pand

emic,

the timel

ine initially

publish

ed by th

e Ministry

of

Economy for

the

restructuri

ng of th

e pub

lic externa

l de

bt that

provided,

among

other

steps, t

he la

unch

of an exchange offer o

f such public securities

issued under for

eign law, was post

poned.

On

21

April

2020,

Argentina

invited

holders

of

approx

imately

US$

66.5

billion

aggregate

princi

pal

amount

of

its

foreign

currenc

y

external

bonds

to

exchange

such

bon

ds

for

new

bonds.

The

invitation

contemplated

the

use of

co

llective

action

clauses

included

in

t

he

terms

and con

ditions

of

such

bonds,

whereby

the

decisi

on

by

certain

majorities

would

bind

ho

lders

that

did

not

tend

er

into

the

exc

hange

offer.

On

31

August

20

the

Argentine

governmen

t

announced

th

at

it

had

obtained

b

ondholder

consents required

to exchan

ge and

or

modify

99.01% of

the aggregate principal amount

outstan

ding of

all

series

of

eligible

bonds

invited

to

participate

in

t

he

exchange

offer.

The

restr

ucturing

settled

on

4

September

20

20.

As

a

result

of

the

invitation,

the

av

erage

interest

rate

paid

by

Argentin

a’s

foreig

n

currency external

bonds was l

owered to

3.07%, with

a maximum

rate of

5.0%, compared to

an average

interest

rat

e

of

7.0%

and

maximum

rate

of

8.28%

prior

to

the

invitation.

In

a

ddition,

the

aggregate

amount

outstanding

of

Argentina

’s

foreign

currency

e

xternal

bonds

was

r

educed

by

1.9%

and

the

average maturity of

such bonds was

extended.

On

5

April

2020,

the

Argentine

governm

ent

enacted

Decree

No.

34

6/20

(i)

deferring

the

p

ayments

of

principal

and

interest

on

certain

of

its

foreign

cu

rren

cy

bonds

governed

by

Ar

gentine

law

until

31

December

2020,

or

until s

uch

earlier

date

as

the

Ministry

of

Economy

may

deter

mine, c

onsidering

the

progress

made

in

the

proces

s

designed

to res

tore

the

sustainability

of

Argent

ina’s

public

debt,

and

(ii)

aut

horizing

t

he

M

inistry

of

Ec

onomy

t

o

conduct

liability

manageme

nt

tr

ansactions

or

exchange

offers,

or

to

implement

restr

ucturing

measures

affecting

fore

ign

curr

ency

bonds

govern

ed

by

Argentine

law

which payments had b

een deferred pursua

nt to such Dec

ree.

On 18

August 2020, Argentina offered holders of its

foreign currency bonds governed by Argentine law

to

excha

nge

s

uch

bonds

for

new

bonds,

on terms

that

were

equitab

le

to

th

e

t

erms

o

f

the

invitation made

to

holders

of f

oreign

law-governed

bonds.

On

1

8

Sep

te

mber

2020,

Argentina

announced

that

holders

representing 99.4% of the aggregate principal amount outstanding of all series of el

igible bonds invited

to

partici

pate

in

the l

ocal

ex

change

of

fer

had

participate

d.

As

a

resul

t

of

t

he

exchange

offer,

the average

interest

rate

pa

id

by

Argen

tina’s

for

eign

c

urrency

bonds

governed

by

Argentine

law

was

lowered

t

o

2.4%,

compared

to

an

average

interest

rate

of

7.6%

p

rior

to

th

e

exchange.

In

ad

dition,

the

exc

hange

offer extended the avera

ge maturity of such

bonds.

62

As o

f the date

of the Comp

any’s Annual Re

port, the Ar

gentine governme

nt has initiated

and continues

to

carry

on

negotiatio

ns

wi

th

the

IMF

in

order

to

rene

gotiate

the

principal

maturit

ies

of

the

US$

44.1

billion

disbursed

betwee

n

2

018

a

nd

2019

under

the

SBA,

or

iginally

planned

f

or

the

years

2021,

2022

and 202

3.

We

cannot

assure

whet

her th

e Arg

entine

governme

nt w

ill

be s

uccessf

ul in

the

n

egotiations

with

that

agency,

which

c

ould

aff

ect

its

ability

to

implement

reforms

a

nd

p

ublic

policies

and

boost

economic

growth, nor

the

impact of

the result

tha

t

renegotiation will

have in

Ar

gentina's ability

to access

international

capital

market

s

(and

indirectly

in

our

ab

ility

to

ac

cess

those

market

s),

in

the

Argentine

economy

or

in

our

economic

and

financia

l

situation

or

in

ou

r

capacity

to

extend

the

maturity

dates

of

our debt or

other

conditions

that could

affect o

ur result

s and op

erations or

busine

sses.

Lack of ac

cess

to

in

ternational

or

d

omestic

financ

ial

markets

could

affect

the

proj

ected

c

apital

expend

itures

for

our

subsid

iaries’

o

perations

in

Arge

ntina,

which,

in

turn,

may

h

ave

an

adverse

eff

ect

on

our

f

inancial

condition or the resu

lts of our operations

.

Without

renewed

access

to

the f

inancial

mark

et

the

Argentine

governmen

t

may

not

have

the

financial

resources to

implem

ent reforms and bo

ost

growth,

whi

ch could

have a significant adverse

effect on the

country’s

eco

nomy

a

nd,

co

nsequently,

on

our

activities.

Likewise,

Argent

ina’s

in

ability

t

o

obt

ain

credit

in

internati

onal

mark

ets could

have a

direct impact

on our

ability t

o

access

tho

se markets to

fin

ance our

operations and

our growth, incl

udi

ng

the financing of

c

apital investments, which

would negatively aff

ect

our

financ

ial condition,

results of operations

and cash flows.

In addition, we

cannot predict the

outcome

of

any

future

res

tructuring

of

Argentine

sov

ereign

debt.

Gr

upo

Clarín

do

es

not

have

material

investments

in

Argentine

s

overeign

bonds

as

of

31

December

2021.

A

ny

new

ev

ent

of

d

efault

by

t

he

Argentine government c

ould negatively affect the Argentine econo

my and, c

onsequent

ly, our business

and results of operati

ons.

The Argentine banking s

ystem ma

y be subject to in

stability, which may

affect our op

erations.

In

recent

years,

the

Argentine

financial

system

gr

ew

si

gnificantly

with

a m

arked

in

crease

in

loans

and

private

deposits,

showing

a

recovery

of

credit

activity.

Such

rec

overy

has

been

severely

impacted

by

the

CO

VID-

19

pandemic.

In

spite

of

the

fact

that

the

financ

ial

sy

stem’s

deposits

continue

to

grow

in

nominal ter

ms,

they

are

mo

stly

short

-term

depos

its an

d the

sources

of

medium

a

nd long

-term

fu

nding

for

financial

institutions

are

currently

limited.

In

2021,

n

ominal

pr

ivate

dep

osits

in

Pesos

increased

59.2%

year-over-y

ear

(fuelled

by

the

growth

of

sav

ings

and

current

accounts

wit

h

a

62.9%

increase)

and

nominal

time

deposits

increased

55.9%

year

-over-y

ear.

During

the

same

per

iod,

loans

in

fore

ign

currency

(composed m

ainly

of c

orporate

loans) ev

idenced a

dec

rease

of 25.

2% at

the

end

of 20

21. In

2021, private depos

its in U.S. dollars decl

ined by 1.1%

.

Financial

inst

itutions

are

particularly

subject

to

significant

regulation

from

multiple

regulatory

author

ities,

all

of

which

may,

a

mong

other

things,

es

tablish

limits

on

c

ommissions

and

impo

se

sanctions

on

th

e

financial inst

itutions.

The lack

of

a stable

regulatory

fr

am

ework,

or c

hanges

to such

regulatory

framework

by

the

government,

cou

ld

imp

ose

s

ignificant

limitati

ons

on

the

acti

vities

of

the

financi

al

institutions and could in

duce uncertainty

with respect t

o the financial system

stability.

The

pers

istence

of

the

c

urr

ent

eco

nomic

c

risis

or

th

e

instability

of

one

or

more

of

the

larger

banks,

public

or

private,

could

h

ave

a

materia

l

adv

erse

effect

o

n

th

e

prospects

for

economic

growth

a

nd

political

stability

in

Argentina,

resulting

in

a

loss

of

consumer

confidence,

lower

disposable

income

and

fewer

financing

alternatives

for

c

onsumers.

Thes

e c

onditions

would

have

a

material

adv

erse

effect

o

n us

by

resulting

in

lower demand

for ou

r

subsidiar

ies’

prod

ucts

and

serv

ices

an

d

the

poss

ibility

of

a higher

level

of

uncollec

tible

ac

counts

or

increase

the

credit

risk

of

the

cou

nterparties

r

egarding

our

subs

idiaries’

investments in local fin

ancial institutions.

Exchange

co

ntrols

and

restrictions

on

transfers

abr

oad

an

d

ca

pital

i

nflows

limit

the

ava

ilability

of

international credit.

We

are

subject to

Arge

ntine

and

international anti

-corruption, anti-bribery and

anti

-money

laundering

laws.

Ou

r

failure

to

comply

w

ith

these

laws

could

result

in

penalties,

w

hich

could

63

harm

our reputation and

have

an adverse

effect on our

bu

siness,

fin

ancial

condit

ion

and results

of operations.

The United States Foreign Corrupt Practices Act of

1977, the Organisation for Economic Co

-Operati

on

and

Devel

opment

An

ti-Bri

bery

Conve

ntion,

the

Argentine

Anti-Mo

ney

L

aundering

Law

(Ley

de

Pr

evención

del

Lavado

de

Activos),

the

Argentin

e

Corp

orate

Criminal

Liability

Law

(Ley

d

e

Responsabilidad

Penal

Empresaria)

and oth

er

appl

icable

anti

-corr

uption

l

aws

prohib

it

companies

and

their intermediaries from

offering or making improper payments (or gi

ving anything of value) to

government

offic

ials

and/or

persons

i

n

the

priva

te

sector

for

the

purp

ose

of

inf

luencing

them

or

obtaini

ng

or retaining

b

usiness and

require

companies to

k

eep accurate

books and

r

ecords and

maintain

appropriate

internal

c

ontrols.

In

particular,

the

Argentine

Corporate

Criminal

Liability

Law

provid

es

for

the crim

inal

liability

of co

rporate

entities

for cr

iminal o

ffences

against

public

administration

and

transnational

brib

ery

committed

by,

among

others,

its

attorneys

-

in

-

fact,

directors

,

managers

,

employees

or

representatives. A

comp

any

may

be held

liable and

s

ubject

to

fines an

d/or suspension

of

its activities

if

such

offences

were

committed,

direc

tly

or

indirectly

,

i

n

its

name,

behalf

or

interest,

the

c

ompany

obtained

or

may have

ob

tain

ed

a

benef

it

therefr

om,

an

d

the

offenc

e

res

ulted

fr

om

a

com

pany’s

ineffective control.

It

may

be

possible

that,

in

the

future,

th

ere

may

emerge

in

the

press

allegations

of

instances

of

misbehaviour on

the

part of

former agents,

curren

t or f

ormer em

plo

yees

or others

acting

on our

behalf

or

on

the

part

of

public

offi

cials

or

other

third

parties

doing

or

cons

idering

busin

ess

with

us.

We

will

endeavour

to

monitor

such

press

reports

and

inv

estigate

matters

that

we

believe

warrant

an

investigation i

n

keeping with

the requirements

of compliance

progra

ms,

and,

if

necess

ary,

make

disclosure

and

n

otify

the

releva

nt

authorities.

H

owever,

any

advers

e

publicity

that

such

allegat

ions

attract

may

have

a

negative

imp

act

o

n

our

reputation

and

lead

to

increased

regulator

y

scr

utiny

of

our

business practices.

If

we

or

individ

uals

or

entities

that

are

or

w

ere

relate

d

to

us

are

found

to

be

liable

f

or

v

iolations

of

applicable

anti-

corruption

laws

(either

du

e

to

our

own

ac

ts

or

our

inadvert

ence,

or

due

to

t

he

acts

or

inadvertence

of

others)

,

we

or

other

individua

ls

or

entities could

face

civil an

d criminal

pena

lties

or

other

sanctions,

which

in

turn

could

have

a

mat

erial

adverse

im

pact

on

our

re

putation,

busines

s,

financial

condition and resu

lts of operations.

Risks Relating t

o the Company and

its Operations

Our subsidiaries or their count

erparties may become subje

ct to burdensome regulations,

ordinances

and

laws affecting

certain

of

th

eir

p

roducts

or

services,

which could

adversely

affect

their operations

We

s

ell

program

ming

conte

nt

to

broadcast and

subsc

ription

television providers,

which

in Argentina

are

subject

to

regulations

governing

I

nformation

and

Commun

ications

Technology

(“ICT”)

serv

ices.

Until

August

2

020,

the

D

igital

Argentina

Law

(

“LAD”)

established

that

license

es

of

ICT

services

may

fre

ely

set their prices, wh

ich shall be f

air and reasonab

le, to offs

et the costs of exp

loitation and t

o tend to the

efficient supply and reason

able margin of

operations.

However,

on 22

August 2020,

the

Argentine Executive

Branch issued Decree

N

o. 69

0/20 amending

t

he

LAD. Decree

No.

690/20

dec

lared ICT

serv

ices (wh

ich include

cable

and

satellite

television

prov

iders)

as

well as

acces

s

to telecommunications

net

works

for

and

b

etween

licensees

as

“Essential

and

Strategic Compet

ition Publ

ic Services”,

and empo

wered ENACO

M to ensure

acces

sibility. Decree No.

690/20

f

urther

estab

lished

that

(i)

the

prices

of

the

Essential

and

Strateg

ic

Competition

Public

IC

T

Services,

(ii)

the

prices

of

those

s

ervices

provided

in

accordance

wit

h

the

Univer

sa

l

Serv

ice,

and

(iii)

the prices

of th

ose serv

ices

determined

by

ENACOM f

or pu

blic interest

reasons,

shall

be reg

ulated by

ENACOM.

Moreover,

Decree

No.

690/20

established

that

ENACOM

is

the

age

ncy

responsible

for

t

he

enactment

of

any

regu

lation

t

he

ICT

’s

Basic

Universal

Serv

ices

(“PBUs,”

for

its

Span

ish

64

acronym),

and

a

lso

sus

pended

any

price increases

or

changes

set

or

announced

by

the

ICT’s

licensees

from

31

July

20

to

31

December

2020.

Decree

No.

690/20

has

been

r

atified

by

the

Argentine

Congress under

L

aw No.

26,12

2

and has

be

en

regula

ted

throu

gh

ENACOM

Res

olutions

Nos

.

1,466/20

and 1,467/20.

Resolution

No.

1,466/20,

a

mong

other

things,

a

llows

ICT

licensees

pr

oviding,

among

other

serv

ices,

subscription

broadcasting

serv

ices

through

physical

,

r

adio-electric

or

sat

ellite

link,

to

increase

reta

il

prices

for

services

up

to

5

%

during

January

2021.

In

order

to

establish

the

per

centages

approved,

licensees

must

consider

the

prices

effective

as

of

31

July

2020

as

the

price

of

reference.

Such

Resolution

also

provides that

ICT

Serv

ices

L

icensees may

request a

higher

increase,

on

an

exceptiona

l

basis in accordance wi

th the provisi

ons of Section 48 of th

e LAD.

Said

Resolution

also

prov

ides

that

ICT

licensees

that

hold

reg

istrations

for

Internet

Access

Val

ue

Added

Service, subscription broadcasting services by

physical and/or radio

-electr

ic link an

d audiovisual

communication

subscription

serv

ices

by

satellite

link,

shall n

otify

th

e

enforce

ment

au

thority

a

bout

any

and

a

ll

c

hanges

in retail

prices

they

intend to

make to

th

eir

plans,

prices and

commerc

ial

ter

ms

in

effect,

SIXTY (60) calendar

days in advance of

their impleme

ntation.

Resolution

No.

1467/202

0

regulates

the

Mandatory

Univers

al

B

asic

Service

set

forth

by

Dec

ree

N

o.

690/2020

for

t

he

different

servic

es

prov

ided

by

ICT

service

licensees,

estab

lishing

the

pric

e

and

characteristics of

each plan. Said Resolution

also sets out

t

he persons that

are eligible to

rece

ive those

services. Subscription television service licensees are under

the obligation to appl

y discounts to a plan

and

progra

mming

gri

d

tha

t

already exist,

w

hich

prevents

the

m

fro

m

creatin

g

a

specific

a

nd

less

expensive grid to co

mply with the Manda

tory Univers

al Basic Service.

ENACOM Resolution No. 1,491/2020 issued on December 24, 2020, approved the new General Rules

Governing

Physical

Radio-

Electric

and/or

Satel

lite

Link

Subscription

Broadcasting

Services

.

Even

though

the

n

ew

General

Ru

les

mai

ntain

the

onerosity

of

all

the

broa

dcast

te

levision

serv

ices

and

signa

ls

that

fa

ll

within

the

scop

e

of

the

“m

ust

carry” regi

me (signals

and

services

subject to

mandatory

retransmission) by

the pr

oviders of s

ubscription

television serv

ices, they

introduce

the concept

of “fair,

equitable and

re

asonable price” and

implement a

dispute resolution procedure i

n c

ase of

d

isagreement

between signal

holders

and

distributors

(by

physical, radio

-electric or satellite link)

to be

brought before

the

ENACOM,

w

hereby

the

p

arties

are

d

eemed

to

h

ave

voluntarily

accepted

t

o

b

e

s

ubject

to

t

his

procedure.

In a

ddition,

the

Ge

neral

R

ules

provide

t

hat

in

the

even

t th

at s

ignal

hold

ers

and

ph

ysical, r

adio

-electric

and/or satellite

link subscription television

l

icensees do no

t settle

their dispute,

distributors

shall

inc

lude

the

s

ignal

in

the

progra

mming

grid

at

the

price

s

et

by

ENACO

M’s

Board

based

on

the

information

gathered

during

the

procee

ding.

The

price

and

the

s

ettlement

procedure

is

applicable

to

any

s

ignal,

including those which

are not subject to ma

ndatory retransmissi

on.

In

add

ition,

t

he

General

Rules

also

prov

ide

that

t

he

c

ommerc

ialization

of

one

s

ignal

may

not

b

e

conditional

on

the

acquisition

of

other

s

ignals

and,

in

the

case

o

f

sales

of

signal

packages,

the

pr

ice

must include a breakd

own of each of the si

gnals included in the

package.

Our

legal

advisors

believe

t

hat

the

ENACOM

is

not

em

powered

to

set

the

price

of

a

signal

an

d

that

it

would

be

arb

itrary

and

unc

onstitutional

if

th

e

agency

imposed

a

price

o

n

the

ow

ner

of

conte

nts

that

does not voluntarily agree

to the settleme

nt proceeding.

However,

if

EN

ACOM’s

pos

ition

prevai

ls,

the

opera

tions

and

econom

ic

and

financ

ial

condition

of

our

subsidiary A

RTEAR, which

owns

several cable

televis

ion

signals an

d is

therefore a

prov

ider

of

contents

to

subscr

iption

television

ser

vices

via

physical,

radio

-el

ectric

or satellite

l

ink, ma

y be

adversely affected.

ARTEAR,

with

the

assistan

ce

of

its

legal

advisors,

is

analys

ing

the

actions

that

may

be

necessary

in

order to protect its rights

.

We

operate

in

a

com

petitive

environment

that

is

experiencing

ch

anges

in

the

way

content

is

consumed, which m

ay result in a redu

ction in our mark

et share in the futur

e.

65

The

Company devotes

signi

ficant

r

esources to

analyzin

g

emerging trends

and

has vast

ex

perience

and

a

solid

track

record

in

reading

consumer

d

emands

and

successful

ly

developing

new

pro

d

ucts

and

services, adapting its

business mode

l in time.

The

media

in

dustry

and

cer

tain

mat

uring

markets

to w

hich

our

services

are

catered, are

dynamic

and

constantly

undergo

sign

ificant

developments

at

a

pace

that

may

di

ffer

from

our

curr

ent

expec

tatio

ns

affecting

our

growth.

Incre

ased

co

mpetition

through

new

tec

hnological

developments

may

adversely

affect

our business if

our analysis of

industry

trends

is not accurate

or if

we are

not able

to adapt

r

eadily

our operations.

In

part

icular,

an

increas

ing

number

of

globa

l

p

layers

offer

th

eir

broadcast

ing

co

ntent

through

digital

“Over

The

To

p”

(

OTT)

platforms

in

the

mark

ets

wh

ere

we

o

perate.

O

TT

platforms

comp

ete

w

ith

our

subsidiaries for

a

udience share.

A decrease

in audience share

and

consu

mption of

tr

adi

tiona

l

linear TV

may negatively affect o

ur advertising rev

enues in the b

roadcasting segme

nt.

Future

t

echnologica

l

deve

lopments may

result in

decreas

ed

cus

tomer

demand

for

certain of

o

ur

products

or

services,

in

particular

print

media,

or

even

render

them

obsolete.

In

a

ddition,

as

new

technologies

develop,

equipmen

t may

ne

ed to

be

replaced

or

upgrade

d, at

subst

antial c

ost, to

re

main

competitive.

These

enhancemen

ts

and the

impl

ementation

of

new

technologies

will

continu

e requ

iring

increased

cap

ital

expend

itu

res.

The

macroeconomic

situation

in

Arg

entina

may

advers

ely

affect

our

ability

to

successfully

inves

t

in,

and

im

plement,

n

ew

t

echnologies,

coverage

and

services

in

a

timely

fashion.

Accordingly,

we

canno

t

as

sure

you

that

we

will

have

the

ability

to

m

ake

n

eeded

c

apital

expenditures

an

d

operating

expenses.

If

w

e

are

unable

to

make

these

cap

ital

expend

itures,

or

if

our

competitors

are

able

to

i

nvest

in

their

businesses

to

a

greater

degree

an

d/or

fast

er

than

we

are,

our

competitive position w

ill be advers

ely impact

ed.

Moreover,

t

he

products

and

serv

ices

that

we

offer

may

fail

to

generate

r

evenues

or

attract

and

retain

customers.

If

our

competi

tors

present

s

imilar

or

bette

r

products

and

services

,

our

revenues

may

be

materially

af

fected.

Competitiveness

is

and

w

ill

contin

ue

to

be

affected

by

our

c

ompetitors

’

bus

iness

strategies

and alliances.

We

may face

a

dditional

press

ure

on the

prices that

we

charge for

our

products

and

services

or

experienc

e

a

loss

of

market

sh

are.

In

addition,

the

general

business

and

econom

ic

climate

in

Argentina

may

a

ffect

us

and

our

competitor

s

differently;

thus

our

ab

ility

to

compete

in

the

market could be ad

verse

ly affected.

Even though the Company grew and developed in recent

years

in

a

highly

com

petitive

market

,

because

o

f

the

ra

nge

o

f

b

usiness

an

d

economic

u

ncertainties

w

e

face,

it

is

difficult

for

us

to

predict

with prec

ision

and

acc

uracy

our future

market

share

i

n

relevant

geo

graphic

areas

and

custom

er

segments,

the

possible

drop

in

ou

r c

ustomer’s

consu

mption

that

coul

d res

ult

in

a

reduction

of

our

revenue

mark

et

s

hare,

the

speed

with

wh

ich

such

change

in

our

m

arket

share

or

prevailing

prices

for

s

ervices

may

occur

or

the

effects

of

competition.

Th

ose

effec

ts

c

ould

be

material

and adverse to our over

all financial cond

ition, results o

f operations and cash flows

.

Digital

Advertis

ing

is

increasingly

conc

entrated

in

global

p

layers,

and

as

our

traditional

medi

a

evolves

into

digit

al

media,

competin

g

with

larg

e

digital

companies

ma

y

negatively

impa

ct

our

Advertising Revenues

.

Due to the increasing relevance of our digital media,

r

evenues from digital advertising in the digital and

printed

publications

segment

have

been

steadily

increasing

their

s

hare

of

our

tota

l

advertising

rev

enues,

while

traditional

advertising

r

evenues

have

decl

ined

as

a

result

of

the

s

hift

in

co

nsumption

of

pr

inted

media by our readers.

Unit

values

for

digital

adver

tising

are

significantly

low

er

than

the

unit

values

for

traditional

advertising.

While

in

the

tr

aditional

a

dvertising

market

we

com

pete

w

ith

ot

her

simi

larl

y-s

ized

or

s

maller

loca

l

companies, in

the case of

digital advertising our

compe

titors are

global companies that are

s

ignificant

ly

larger than us.

66

While

we

acc

ompany

the

digital tr

ansformati

on

in

th

e

industry,

the

difference

in

size

and

resources

of

our

digital

advertisin

g

competitors

could

severely

affect

our

compet

itive

position

and

as,

a

result,

our

financial position, res

ults of operatio

ns and cash flows.

Our revenues are cy

clical and depend up

on the cond

ition of the Argentine e

conomy.

Revenues

generated by

our

subsidiaries

have

proven

c

yclical

a

nd

de

pend

on

general

eco

nomic

conditions.

In

the

past, a

g

eneral

economic

downturn

in Argentina

has

had,

and

would

be

expected

to

have in the

future, a negative effect

on our revenues and a

materia

l adverse effect on the results of

our

operations. Hi

storica

lly,

for example,

increases in

losses of

advertisers have

corr

esponded

with

genera

l

economic

downturns

and

regiona

l

and

local

econ

omic

recessions.

M

ost

of

our

revenues

are

denominated

in

Arge

ntine

pesos,

exp

osing

us

t

o

r

isks

ith

fluctuations

in

the

value

of

the

Argentine peso.

Supply

ch

ain

disruptions affecting

the

imp

ortation of

raw

materials and

other inputs

m

ay

negatively affect our op

erations.

Some of our

subsidiaries

’ revenues a

nd

operat

ions depend

on the

provision of

imported m

aterials that

cannot

be

o

btained

in

the

domestic

m

arket.

In

r

ecent

years,

increasing

logistic

al

proble

ms,

includi

ng

regulatory

and

d

e

facto

r

estrictions

on

imports,

hav

e

increased

t

he

cost

and

affected

timely

proc

urement

of

imported materials.

Increased restrictions

to

the avai

lab

ility

of

imported goods

may

affect

the

revenues of some of

our subsidiaries, as

well as their operati

ons, results, and cash

flows.

Our

operations

and

finan

cial

condition

could

be

aff

ected

by

future

union

nego

tiations,

Arg

entine

labour

regulations

and

g

overnment

al

m

easures

req

uiring

private

comp

anies

to

incr

ease

salaries

or otherwise provid

e workers with add

itional benefits.

In

Ar

gentina,

labour

organisations

hav

e

subst

antial

support

and

c

onsiderable

political

influence.

I

n

recent

years,

the

de

mands

of

labour

orga

nisations

eng

aged

with

our

s

ubsidiaries

h

ave

increased

ma

inly

as

a

result

of

the

increase

in

the

cost

of

living,

which

was

aff

ected

by

i

ncreased

inflation,

higher

tax

pressure

over sal

aries and the conse

quent decline in t

he population’s p

urchasing power.

If

we

are

unab

le

to

reach

agreements

with

the

union

s

on

work

conditions

,

or

in

case

of

a

lack

of

recognition among union associations, we may be adversely affected

by individu

al labour

clai

ms, class

actions,

h

igher

union

cont

ributions

expenses,

union

conflicts,

direct

ac

tion

measures

and

ge

neral

impacts

to

our

operations

that

m

ay

also

affect

the quality

of ou

r

products

an

d

serv

ices

and

o

ur

reputation.

The

Argentine

government

has

enacted

laws

and

regulati

ons

requiring

pr

ivate

sector

compani

es

to

maintain

certain

s

alary

levels

and

provide

their

emp

loyees

with

addi

tional

benefit

s.

On

13

Decemb

er

2019,

the

Argentine g

overnment

declared

a

labour

emergency

for

a 18

0

-day

term.

In

this

context,

the

Argentine government doubled the

amount of the

s

tatutory

severance

paymen

ts payable to

employees

hired

before

13

D

ecember

2019

and

dismissed

betwe

en

13

December

2019

and

13

J

une

202

0.

The

layoff

prohibition

was

exten

ded

pursuant

to

Decree

N

o.

528/20

and

Decree

No.

961/20.

Decree

No.

39/21,

c

urrently

in

effec

t

un

til

27

April

2021,

exte

nded

the

pro

hibition

of

dism

issals

without

j

ust

c

ause

or based on lack or red

uction of work an

d force majeur

e, as well as the prohib

itions to suspens

ions for

economic

reasons,

except

for

suspensi

ons

made

under

the

ter

ms

of

Section

22

3

bis

of

the

Labour

Contract

Law

(agree

ments

between

e

mployers

and

e

mployees

later

approved

by

the

Ministry

of

La

bour,

made

either individually

or collectively wi

th the

pur

pose of

su

spending employment for

lack

or reduction

of work due to no fau

lt from the emp

loyer), which are n

ot affected by the proh

ibition.

Likewise, Decree No. 39

/21

extended the

occupat

ional emergency until 31

Decem

ber 2021 i

n cases of

dismissals

without

jus

t

caus

e,

and

grant

ed

the

rig

ht

of

the

affected

worker

to

receive

a

double

sev

erance

payment,

w

ith

a

ca

p

o

f

P$500,000

in

excess

of

what

would

have

bee

n

the

regul

ar

sing

le

sev

erance

67

payment.

Th

e

occupatio

nal

emerge

ncy

was

further

extended

by D

ecree

No

.

886/21

thr

ough

30

Ju

ne

2022. Decree

8

86/21 also

provides that

double severance payments

will be

progre

ssively reduced

until

they are effectively f

inalized in June 2022.

However,

un

der

the

provisions

of

Section

5

of

Dec

rees

No.

624/20,

761/20

and

891/20,

contracts

entered

into

after

the

entry

into

force

of

Decree

No.

34/1

9,

are

n

ot

affect

ed

by

the

aforeme

ntioned

provisions.

The

Arge

ntine

government

may

adopt

new

meas

ures

that

determine

salary

increases

or

additional

benefits

for

workers,

and

wor

kers

and

their

unions

may

pressure

employers

to

comply

with

suc

h

measures. Any salary increase or

additional benefit could result

in an increase

in costs and a

decrease

in

the

res

ults

of

the

operat

ions

of

Argentine

com

panies,

including

thos

e

of

our

subsidiari

es.

Further,

futur

e

extensions

of

the

pro

hibition

of

layoffs

and

dism

issals

due

t

o

force

majeure

or

lack

of

or

decreased

work

or

the

dup

lication

of

t

he

s

tatutory

severance

payments

to

dism

issed

employees

may

affect

the

efficiency of our subsidi

aries’ employees an

d therefore

the costs

and results of the

ir operations.

The

enforcement

of

t

he

Law

for

the

Promotion

of

Register

ed

Labour

and

Prevention

of

Labour

Fraud may have a m

aterial adverse effect on

us.

The

Law

for

the

Promotion

of

Registered

Labour

and

Prevention

of

La

bou

r

Fraud

(Ley

de

Promoción

del

Trabajo

Reg

istrado

y

Prevención

del

Fraude

Laboral),

among

other

things

,

es

tablishes

a

Public

Record

of E

mployers

subject

to

Labour

Sanctions

(“Re

psal”)

and defi

nes a

series

of

labour

and

social

security infringements

as a res

ult of which an empl

oyer shall be inc

luded in the Re

psal.

The

employers

incl

uded

in

the

Repsal

are

subject

to

s

anctions,

such

as:

the

inability

to

access

publ

ic

programs, benefits, subsidi

es or credit from state-own

ed banks, the inability to enter into contrac

ts and

licenses o

f prop

erty

owned

by

the

Argent

ine

government,

or

the

inab

ility to

p

articipate

in t

he

awarding

of

concessions of

p

ublic

ser

vices

and licenses.

Employ

ers

that commit

the

sa

me

infringeme

nt

for which

they

were

added

to

the

Re

psal

within

a

3-y

ear

period

after

the

fina

l

first

decision

imp

osing

sanctions

cannot

deduct

from

the

In

come

Tax

the

expenses

their

e

mployees

while

such

em

ployer

continues

to

be

incl

uded

in

the

Re

psal.

This

new

r

egulation

a

pplies

to

our

s

ubsidiaries

and

their

contractors

and

s

ubcontrac

tors,

whose

emp

loyees

could

initiate

c

laims

agains

t

our

s

ubsidiaries

for

direct or indirect respons

ibility.

As

of the

date

of

the Company’s Annual

Re

port, none

of

our

subsid

iaries

have any

sanctions

registered

in

the

Repsal.

However,

if

sanctions

are

applied

in

the

future,

they

could

have

a

significant

impact

on

such subsidiaries’ fina

ncial position, result

of operation

s and cash flows.

A

cyb

erattack,

could

adversely

aff

ect

our

busine

ss,

balance

sheet,

results

of

operation

s

and

cash flow.

In

general,

information

security

risks

have

increased

i

n

recent

y

ears

as

a

r

esult

of

the

proliferation

of

new

and

more

sophisticat

ed

technol

ogies

and

also

due

t

o

cy

berattack

activiti

es.

As

part

of

the

Company’s

deve

lopment

and

initiatives,

mor

e

quipment

and

systems

h

ave

been

c

onnected

to

the

Internet.

The

Company

also

r

elies

on

d

igital

tech

nology,

incl

uding

inform

ation

s

ystems,

to

pr

ocess

financial

and

operational

information.

Du

e

to

t

he

nature

of

our

business

a

nd

the

greater

acces

sibility

allowed through I

nternet connecti

on, we could f

ace an increased

risk of cyberattac

ks. In the eve

nt of a

cyberattack,

we

could

experience

an

i

nterruption

of

ou

r

commercial

operat

ions,

m

aterial

d

amage

and

loss

of

customer

information,

reput

ational

loss;

a

subst

antial

loss

of

income,

suffe

ring

respons

e

costs

and

other

economic

losses;

and

it

c

ould

subj

ect

us

to

more

regulat

ion

and

l

itigation,

affecting

our

reputation.

As

a

resu

lt,

a

cy

berattack

c

ould

advers

ely

affect

our

business,

results

of

operations

and

financial condition.

Also,

duri

ng

2020

,

the

new

working

methodolo

gy

an

d

the

expone

ntial

growth

of

the

digita

l

collection

channels

res

ulting

fr

om

the

CO

VID-19

iso

lation,

requ

ired

th

e

i

mplementation

of

several

m

easures

in

68

order

to

grant

security

i

n

v

irtual

o

perations,

which

we

re

al

l

implement

ed

succ

essfully.

Although

our

subsidiaries have adopted, and

continues to adopt, al

l required measures to ensure

the proper

functioning of the

ir operating sys

tems, as we

ll as to en

sure their custo

mers’ infor

mation, no assuranc

e

can be

given

that

they

will not

be subject

to

any cyber

attacks

that

could

advers

ely

affect

our

bus

iness

and result of operat

ions.

As

of

the

date

of

the

Company’s

Annual

Report,

our

s

ubsidiaries’

insurance

policies

do

not

cover

damages caused by cy

berattacks and other s

i

milar events.

Operational risks could

adversely aff

ect our reputa

tion and our profitability.

The Comp

any’s subs

idiaries fac

e operat

ional risks

inherent

in the

ir bus

iness, incl

uding those

resulting

from

ina

dequate

internal

process

es;

fraud;

employ

ee

err

ors

or

miscon

duct;

failure

to

com

ply

with

applicable laws and

regu

lations; the loss, security or

improper use

of confidential information; improper

access

to

corporate

sy

stems;

lack

of

sufficient

skilled

r

esources

to

support

the

ev

olutions

of

the

business; failure

to document

transac

tions properly;

sys

tems

failures

(

includi

ng

o

ur

systems,

the

implementation

o

f

corpor

ate

sy

stems

and

cloud

s

ervices);

inadequate

management

of

goods

an

d

materials

in

disuse

that

co

uld

become

hazardous

waste;

excessive

dep

endence

on

certain

providers

with

which

a

large

nu

mber

of

operatio

ns

are

concentr

ated

due

to

the

exclusivity

of

the

technology

or

service they provide,

economic convenience or f

or strategic reasons; a

mong other

s. Moreover, cert

ain

assets

of

t

he

Company

or

it

s

subsidiaries

could

be

damaged

by

acts

of

vanda

lism

or

theft

of

components

or

by

works of

th

ird pa

rties on

p

ublic

thoro

ughfare

that

da

mage

infrastructure that

do

not have

a

seco

nd

safety

path

to

prov

ide

the

serv

ice.

T

hese

events

could

res

ult

in

direct

or

ind

ir

ect

losses,

in

accurate

information

for

d

ecision

making,

adverse

legal

and

regu

latory

proceedings,

technica

l

failures

i

n

the

Company’s

ability

to

provide

its

serv

ices,

damages

to

third

parties,

and

harm

our

reputation

and

operational effectiven

ess, among ot

hers.

Our

subsidiari

es

maintai

n

i

nsurance

policies

to

cover

t

heir

main

assets,

particul

arly

their

pro

perties.

If

economic a

nd financial

conditions

in

Argentina w

ere to

deteriorate

(i.e. dev

aluation, i

nflation,

etc.), the

insurance coverage may not be

repres

entative of the market value

of the properties, which could

result

in losses for the Compa

ny.

Our

s

ubsidiaries’

suppl

iers

of

goods

and

services

are

contractually

obliged

to

comply

with

la

ws

an

d

regulations

(includi

ng

tax,

labour,

socia

l

s

ecurity,

a

nti

-c

orruption,

mon

ey

laundering

sta

ndards,

etc.).

Additionally, such su

ppliers s

hall comply with

a set of c

onduct standards, suc

h as c

odes of ethics, and

must

require

similar

co

mpliance

by

their

e

mployees

and

subcontractors.

D

espite

the

se

legal

s

afeguards

and

monitoring efforts

m

ade by

our subsidiaries in

re

lation to

t

heir

su

ppliers, we

cannot assure you

that

they will comply

with all ap

plicable regul

ations. As a r

esult, we c

ould be advers

ely affected des

pite our

subsidiaries’

contractua

l

ri

ghts

to

claim

for

c

ompens

ations

for

damages

that

s

uppliers

could

cause

the

m.

Even

though

our

s

ubsidiaries

apply

risk

mana

gement

prac

tices

at

the

highest

levels,

we

can

giv

e

no

assurances

that

these

mea

sures

will

be

s

uccessful

in

effective

ly

mitigating

the

operation

al

risk

s

that

they face

.

F

ailure

to

preve

nt s

uch r

isks

could

harm

o

ur

reputation

and

have

a

material

advers

e

effect

on our business, results

of operations

and financial conditio

n.

We

and/o

r

our

management

are

subj

ect

t

o

environmental

and

safety

regulations,

non

-

compliance

of

which

cou

ld

result

in

increased

cos

ts

and/or

penalties

for

the

Company

and/or

its officers.

Some

of

t

he

goods

and

fa

cilities

used

in

our

subsidia

ries’

operatio

n

are

su

bject

to

federal,

s

tate

an

d

municipal

environment

al

a

nd

safety

regulations.

Fai

lure

adequately

to

com

ply

with

such

rules

could

result

in

fines,

p

otential

delays

or

inability

to

obt

ain

authoriza

tion

for

our

s

ubsidiaries’

fac

ilities

and

operations,

which

could

hav

e an

adverse

effec

t on

our

business

an

d res

ult

in pen

alties

for

the

o

fficers

of

our

s

ubsidiaries.

In

ad

dition,

in

accordance

with

global

trends,

n

ew

and

stricter

standards

may

be

69

issued,

or

authorities

may

enforc

e

or

construe

existi

ng

laws

an

d

regulatio

ns

in

a

more

res

trictive

manner, which may forc

e us to incur increase

d c

osts.

Risks Relating to ou

r Shares and G

DSs

The

U.K.

Listing

Autho

rity

(“UKLA”

),

the

Londo

n

Stock

Exchange

(“LSE”)

and/or

the

Bu

enos

Aires

Stock

Exchange

(“BYMA”)

may

suspend

trading

and/or

d

elist

our

GDSs

and

Class

B

common shares, respectively, upon occurrence of certain events relating to our

financial

situation or compliance

with ongoing

regulatory obligations.

The UKLA, the LS

E and/or

the BYMA may s

uspend an

d/or cancel the l

isting of our G

DSs and Clas

s B

common

s

hares,

res

pectively,

in

c

ertain

c

ircumstances,

includi

ng

upon

the

occurre

nce

of

certain

events

relating to our financ

ial situation or complia

nce with ongoing re

gulatory obligatio

ns.

The

UKLA

and

the

LSE

may

in

their

sole

discreti

on

determine

the

suitabil

ity

for

continue

d

listing

and

admission to trading of our GDSs in the light of all pe

rtinent facts. Some of the factors that may subject

a

company to

suspension and

po

tential

delisting procedures,

include, inter

alia, (i)

failure to

comp

ly

with

continuing

ob

ligations

set

out

in

the

U.

K.

Listin

g

Rules

(

such

as

the

requireme

nt

to

m

aintain

a

“fre

e

float”

of

at

l

east

10

per

cent),

and

(i

i)

an

inability

to

accurately

assess

the

financial

position

of

the

company and inform

the market accordingly. The

UKLA and the LSE

may also suspend and ultimately

cancel

a

compa

ny’s

listing

if

they

d

etermine

tha

t

such

action

is

necessary

to

protect

investors

with

a

view to maintaining a

proper functio

ning of the mark

et.

We cannot assure you

that the UKLA, the LSE and/or the BYMA

w

ill not commenc

e any

suspe

nsion or

delisting

pr

ocedures

in

light

of

our

financial

situati

on

or

failure

to

comp

ly

with

ongoing

regulatory

obligations. A delist

ing or suspension of trad

ing of our GDSs

or Class B common

shares by the

UKLA,

the

LSE

and/or

the

BYMA,

respect

ively,

could

adversely

affect

our

results

of

operations

a

nd

f

inancial

conditions and cause t

he market v

alue of our GDSs an

d Class B common

shares to declin

e.

Under

A

rgentine

co

rporate

law,

sha

reholder

rights

may

b

e

f

ewer

or

less

well

defined

than

i

n

other jurisdictions.

Our corporate affairs are

governed by our bylaws

and by Argentine corporate law,

which differ from

the

corporate r

egulatory

frame

work

that

would

apply

if

we

were

incorporat

ed i

n a

juri

sdiction

in

the U

nited

Kingdom

or

in

other

jurisdi

ctions

outside

Arg

entina.

Thus,

your

rights

und

er

Argentine

corporat

e

law

that

protect

shareho

lders’

interests,

espec

ially

in

relat

ion

to

actions

by

our

Board

of

Directors

may

be

fewer

and

less

we

ll

defined

than

un

der

the

laws

of

thos

e

other

jurisdictions.

Although

insider

trading

and price manipulation are illega

l under Argentine law, the Arg

entine securities ma

rkets may not be as

highly

regulated

or

s

uperv

ised

as

the

U.

K.

secur

ities

markets

or

markets

i

n

other

j

urisdictions.

In

addition, rules and poli

cie

s against self-dealing and regarding the preservation of

s

hareholder interests

may

be

less

well

defined

and

enforced

in

Argent

ina

th

an

in

the

U

nited

Kingdom,

or

other

jurisdicti

ons

outside Argentina, putti

ng holders

of our Class B Share

s and GDSs at a pot

e

ntial disadvant

age.

Changes in

A

rgentine

tax

laws ma

y

adversely

aff

ect t

he t

ax tre

atment

of

our

Shares

and/or

the

GDSs.

In

Septe

mber

2013

,

the

Ar

gentine

income

tax

law

was

amended

by

L

aw

No.

26

,893

(the

“Argentine

Income

Tax

Law”).

T

he

Argentine

Income

T

ax

L

aw

pro

vides

that

the

sale,

exchange

or

other

transfer

of

shares

and

ot

her

sec

urities

is

subject

to

a

capital

gain

tax

at

a

rat

e

of

15%

f

or

Argentine

resident

individuals and

fore

ign beneficiaries.

In addition,

Pursu

ant

to Law

No. 26,893,

capi

tal

gains

obtained by

non

-Argentine

residents

from

the

sale,

exc

hange

or

oth

er

d

isposition

of

shar

es

and

other

e

quity

interests,

bonds

a

nd

other

s

ecurities

of

Arg

entine

co

mpanies

were

su

bject

to

c

apital

gains

tax

until

December 30, 2017,

even if those tr

ansactions

were entered

into between

non-re

sidents.

70

Until

the

enactment

of

Law

No.

27,430,

in

f

orce

s

ince

fisc

al

year

2018,

th

ere

wa

s

an

exemption

for

Argentine

res

ident i

ndividua

ls

if certain

require

ments

were

met. However,

there was

no

such exemption

for

non-

Argentine

residents.

For

transactions

made

until

31

December

2

017,

many

asp

ects

of

the

Argentine Income Tax Law as

they apply to the holding and sale of GD

Ss still remain unclear and t

hey

were subject

to further regulation and

interpretation which may

adversely

affect the

tax treatment

of our

Shares

underlying

GDSs

and/or

GDSs.

The

income

tax

treatment

of

i

ncome

derived

from

the

sale

of

GDSs

or

exchanges

of

shares

from

the

GDS

facility

may

not

be

uniform

under

the

revised

Argentine

Income Tax

Law

. The

poss

ibly v

ary

ing tre

atment

of th

e s

ource

of incom

e c

ould i

mpact bot

h Arg

entine

resident holders as

well as non-Arg

entine resident

holders.

Law

No.

27,430

req

uires

th

e

capital

gains

tax

to

be

paid

for

transact

ions

carried

out

betwee

n

Septem

ber

2013

(when

taxat

ion

on

the

sale

of

s

hares

for

non

-residents

was

introduced)

and

the

effective

da

te

of

the

tax

re

form,

provid

ing

that

no

tax,

however,

will

be

due f

or

stoc

k

exchange

transactions

as

long

as

the tax

has not

yet been paid

due to the

lack of

r

egulations for the

with

hol

ding or

collectio

n by

the stock

exchange agents or

intermediaries.

Consequently, holders

of our

Cl

ass

B Shares,

including in

t

he

form of

GDSs

,

are

encouraged to

co

nsult

their tax adv

isors as

to the particu

lar Argentine i

ncome

tax c

onsequences of ow

nin

g

our Shares

or the

GDSs.

Our

shareholde

rs

may

b

e

subject

t

o

liability

u

nder

Argentine

law

for

c

ertain

votes

of

their

securities.

Under

Argentine

law,

a

shareholder

’s

liability

for

losses

of

a

company

is

limited

to

the

value

of

his

or

her

shareholdings

in

th

e

company.

However,

shar

eholders

who h

ave

a

conf

lict

of

interest

w

ith

us

and

who

do

not

absta

in

from

voting

at

the

respective

share

holders’

me

eting

may

be

liable

for

damages

to

us,

but

on

ly

if

th

e

transaction

would

not

have

been

approved without

suc

h

s

hareholders’

v

otes.

Furthermore, shareholders who wilfully or

neglig

ently vote in

favour of a

reso

lution that

is subsequently

declared void by a

court as contrary to the

law or our bylaws may

be held jointly and severally liable

for

damages to us or to ot

her third parti

es, including ot

her sharehold

ers.

The price

of our Class

B Shares and

the GDSs may fluctuate substantially, and

your investment

may decline in valu

e.

The

trading

price

of

our

C

lass

B

S

hares

is

likely

to

be

h

ighly

volatile

a

nd

may

be

subjec

t

to

wide

fluctuations in

res

ponse to various

factors

, many

of which

are beyond our

contro

l. Price

f

luctuations are

explained

mainly

by

the

de

valuation

of

t

he

Argentin

e

peso,

Argentina’s

macr

oeconomic

crisis

and

the

effects of the COVID 19

pandemic and p

ost-

pandemic r

ecovery.

Other factors affecting t

he price of our GD

Ss include:

•

fluctuations in our peri

odic operating results;

•

changes in financial

estimates, recomm

endations or proj

ections by secur

ities analysts

;

•

changes in conditions or tr

ends in ou

r industry

;

•

events affecting equities

markets in the cou

ntries in w

hich we operate

;

•

legal or regulatory

measures affecting our fi

nancial condit

ions;

•

departures of manage

ment and key

personnel; or

•

potential litigation or the

adverse

resolution of pen

ding litigation a

gainst us or our

subsidiaries.

The stock

markets in ge

neral have

experienced

extreme pric

e and v

olume fluctu

ations that h

ave often

been

unrelated or

d

isproportionate to

the operating

perf

ormance of

the

co

mpanies involved.

We

can

not

assure

you

that

tra

ding

pric

es

and

valuations

will

be

sustained.

T

hese

broa

d

mark

et

and

in

dustry

fact

ors

may

materia

lly

advers

ely

affect

the

mark

et

price

of

our

Shares

and

the

G

DSs

,

regardless

of

o

ur

operating performance. Ma

rket fluctuations, a

s well as general pol

itical and economic conditions in the

71

markets

in

which

we

op

erate,

such

as

recession

or

currency

exchange

rate

flu

ctuations,

may

also

adversely affect the m

arket price of

our Shares and

the GDSs.

Future

sa

les

o

f

substa

ntial am

ounts

o

f

our

Class

B

Shares

and

G

DSs, or

the

perce

ption

t

hat

suc

h

future

sales may occur, may d

epress the price

of our Class B

Shares and GDSs.

Following periods of volatility in

the market price of a

company

’s securities, that

co

mpany may often be

subject

to

securities

class

action

litigation.

This

kind

of

litigation

may

result

in

substant

ial

c

osts

and

a

diversion of

manageme

nt’s attention

and resources, which

would have a

m

aterial adverse effect

on our

business, results of op

erations and financ

ial condition.

Restrictions on

transfers of

f

oreign

exchange and

t

he

repatriation of

capital

f

rom

Argentina may

impair

your

ability

to

receive

dividend

s

and

distribution

s

on,

and

t

he

proceeds

of

any

sale

of

,

the Class B Shares unde

rlying the GDS

s.

On 1

September 2

019,

the

Argentine g

overnment

issu

ed

Executive

Decree

No. 6

09/19 (

as

amended)

which,

inter

alia,

reinstated

certain

foreign

c

urrency

exchange

r

estrictions,

most

of

which

had

been

progressively

repealed

as

fr

om

2015.

Decree

No.

609/19

was

further

regulated,

am

en

ded an

d

complemented by

s

everal regulations

issued by

the BCRA

(

included, but

n

ot l

imite

d

to,

C

ommunication

“A”

6844,

as

further

amended,

supplem

ented

and

restated).

Since

then,

the

Ar

gentine

government

implemented

mo

netary

an

d

foreign

exchange

control

mea

sures

th

at

includ

ed

restri

ctions

on

the

transfer

of

funds

abroad,

includi

ng

dividends,

without

prior

approval by

the

BCRA

or

fulfilment

of

certain

requirements.

In li

ne with the restrictions

that were in

place in the

past, the BCRA issued

new regulations

setting

forth

certain limitations on the flow of

foreign currency into and from the Argentine foreign exchange market,

aimed both at generati

ng econom

ic stability and supp

orting the country

’s economic recovery.

On

30

April

2

020,

th

e

BCRA

issued

Commun

ica

t

ion

“A

”

7001

(as

amended by

Co

mmunication

“A” 70

30

and

Commun

ication

“A”

7042

an

d

as

further

am

ended

and

supplemented

from

time

t

o

t

ime)

Communication

“A”

7001

setting

forth

c

ertain

limitat

ions

on

the

tra

nsfer

of

s

ecurities

into

and

from

Argentina.

Pursua

nt

to

Commu

nication

“A”

7001

access

to

t

he

Argentine

for

eign

exchange

mark

et

for

the purch

ase

or

transfer

of

foreign

currency

abroad

(fo

r

any

purpose) s

hall b

e

subject

to

BCRA’s

prior

approval,

if

the

individual

or

entity

seek

ing

access

to

the

Argentine

fo

reign

excha

nge

market

has

sold

securities

which

settled

in

foreig

n

curr

ency

or

transfer

red

a

ny

suc

h

securities

to

foreign

dep

ositaries

during

the

immediately

preceding

90

calendar

day

s.

Further,

Commun

ication

“A”

7001

sets

forth

that

the

individual

or

entity

must

undertake n

ot

to

p

erform

any

such

sale

or

transfer

during

the

succ

eeding

90

days

after

such

access.

In

these

cases,

the

Depositary

for

the

GDSs

ma

y

hold

G

DS

holders’

Argentine Pesos and m

ay cannot convert t

hem into foreign curr

ency.

In

addition,

C

ommunicatio

n

“A”

7106

placed

certain

restrictions

on

foreign

ex

change

transact

ions

carried out by

individuals,

specifical

ly with regards

to p

ayments with

credit cards

in forei

gn currency

or

with

debit

cards

made

abroad.

Un

der

Communicatio

n

“A”

7106,

it

was

also

es

tablished

that

non-

residents

are

not

allowed

to

s

ell

s

ecurities

executed

abroad

in

the

local

stock

ma

rket

in

exchange

for

foreign currency.

We cannot

predict

how the

current r

estrictions on

foreign

transfers of

funds

may chang

e after

the dat

e

he

reof

and w

hether

they

may

impede

our

ability

to

fulfil

our

commitmen

ts

in g

eneral

and,

in

particular,

our

obligati

ons

und

erlying

the

GDSs.

In

addi

tion,

any

future

adoption

by

the

Arg

entine

government

of

restrictions

to

the mo

vem

ent

of

capital

out

of Argentina may

affect

the

abi

lity

of our

foreig

n

shareholders

and

holders

of

GDSs

to

obtain

the

full

v

alue

of

th

eir

Class

B

Shares

and

GDSs

,

and

may

advers

ely

affect the market val

ue of the GDSs.

Trading

of

the

Company’s

Clas

s

B

Shares

in

the

Argent

ine

securiti

es

ma

rkets

is

limited

and

could experience furth

er illiquidity and pr

ice volatilit

y.

72

Argentine

securit

ies

markets

are

substantially

s

maller,

less

liquid

a

nd

more

volati

le

than

maj

or

securities

markets in the United Kingdom. In

additio

n, Argentine securiti

es markets may be materially affected by

developments

in

other

emergin

g

markets,

particularly

other

countr

ies

in

La

tin

A

merica.

Our

Class

B

Shares underly

ing the

GDSs

are less

actively trad

ed th

an securit

ies in m

ore d

eveloped countr

ies and,

consequently,

a

GDS

holder

may

have

a

limited

a

bility

to

se

ll

the

Class

B

Shares

underlyi

ng

GDSs

upon withdrawal from t

he GDSs facility

in the amount a

nd at the price and ti

me that it may des

ire. This

limited trading

market may

also increase

the price

volatility of

the Class B Sha

res underlying the

GDSs.

Holders

of

GD

Ss

may

b

e

advers

ely

affected

by

currenc

y

devaluatio

ns

an

d

foreign

ex

change

fluctuations.

If

the

peso

excha

nge

rat

e

f

alls

rel

ative

t

o

the

U.S.

do

llar,

the

value

of

the

GDSs

and

any

distributions

made

ther

eon

from

t

he

d

epositary

could

b

e

advers

ely

affected.

Cash

distribut

ions

made

in

respect

o

f

the

GDSs

may

be

received by

the

d

epositary

(r

epresented

by

the

custodian

bank

i

n

Arg

entina)

in

pesos,

which

will

be

c

onverted

into

U.S. d

ollars

and

d

istributed

by

the d

epositary

to

the

holders

of

G

DSs

if

in

the

judgment of the

depositary such am

ounts may

be converted

on a

r

easonable basis

into U.S.

d

ollars

and transferred

to GDS holders

on a reasonable ba

sis,

subject

to such di

stribut

ion being i

mperm

issible

or

impracticable

with

r

espect

to

certain

GDS

holder

s.

In

addition,

the

deposit

ary

will

incur

foreign

currency

conversion

cos

ts

(to

be

borne

by

the

holders

of

the

GDSs)

in

c

onnecti

on

with

the

foreign

currency

conversion

and

subsequent

distribution

of

d

ividends

or

other

payments

with

respect

to

the

GDSs.

The

relativ

e

volatility

and

illiquidity

of

th

e

Argentine

securities

markets

may

substant

ially

limit

your

abil

ity

to

sell

the

shares

underlying

the

GDS

s

on

the

BYMA

at

the

price

and

tim

e

d

esired

by the shareholde

r.

Investing

i

n

sec

urities

that

trade

in

emerging

markets

,

such

as

Argentina,

often

involves

greater

r

isk

than

i

nvesting

in

s

ecurities

of

issuers

in

the

United

Kingdom,

and

such

investments

are

genera

lly

considered

to

be

more

s

pec

ulative

in

n

atu

re.

Th

e

Arg

entine

secur

ities

m

arket

is

substantially

sma

ller,

less

liquid,

more

c

oncentrated

a

nd

c

an

be

more

volatile

than

major

securit

ies

m

arkets

in

the

U

nited

Kingdom,

a

nd

is

not

as

highly

regulated

or

superv

ised

as

some

of

t

hese

ot

her

m

arkets.

There

is

also

significantly greater

concen

tration in

the Argentine

securiti

es market

t

han in

major securities

markets

i

n

the

U

nited

Kingdom.

The

ten

largest

companies

in

terms

of

market

capitalisation

r

epresented

approximately

62%

of

t

he

aggregate

mark

et

capital

is

ation

of

the

BYMA

as

of

31

December

20

21.

Accordingly,

although

shar

eholders

are

entitled

to

wit

hdraw

th

e

shares

under

lying

the

GDSs

from

the

depositary

at

a

ny

time,

the

ability

to

s

ell

such

shares

on

the

B

YMA

at

a

pric

e

and

tim

e

shareholders

might elect may be

substantially limited.

We

are

traded

on

more

than

one

ma

rket

and

this

may

result

in

price

variations;

in

add

ition,

investors may not

be able to easily mo

ve shares f

or trading betwe

en such markets.

The shares

underlying

GD

Ss

trade

in

the

Buenos

Air

es

Stock

Exchange

(B

YMA)

and

the

GDSs

tra

de

in the London Stock Exchange, w

ith substantial differenc

es in trading volumes. In addition, th

e shares

and

G

DSs

trade

in

different

c

urrencies

and

transact

ions

take

place

a

t

different

ti

mes

(resulting

fro

m

different

trading

pl

atforms,

different

t

ime

zones,

differe

nt

trading

days

and

different

pub

lic

holidays

in

the United Kingdom and A

r

gentina). The trading prices of

the shares underlying GDSs and

the GDSDs

on

these

two

markets

diff

er

main

ly

due

to

substa

ntially

d

ifferent

trading

volumes,

exchange

rate

fluctuations and other f

actors.

The year-end market price of the shares underlying ou

r GDSs traded in BYMA increased from P$ 33.1

as of

31

D

ecember 2019

to P$ 37.65 as

of 31 December 2020 an

d to P$

122 as

of 31 Decem

ber 2021,

while

the

price

of

our

GDS

(each

w

ith

two

underly

ing s

hares)

in

the

London

S

tock

Exchange

decl

ined

from US$ 1.89 as of 31 December 2019 to US$ 1.5 as of 31 Decem

ber 2020 and to US$ 0.98 as of 31

December 2021.

73

Any decrease

in th

e price

of the

s

hares

underlying G

DSs

on the

BYMA

could cau

se a decr

ease i

n the

trading price

of t

he

GDSs

on th

e LSE.

Investors

could

seek

to sell

or

buy t

he shar

es und

erlying GD

Ss

to

take

advantage

of

any

price

d

ifferences

between

the

markets

through

a

practice

referred

t

o

as

“arbitrage.”

Any

arbitrag

e

ac

tivity

could

create

unexp

ected

volatility

in

both

our

share

prices

on

one

exchange, and the GDSs

available for tra

ding on the other exc

hange. In add

ition, holders of GDSs wi

ll

not be immediately able to surrender their GD

Ss and withdraw the underlying shares

for trading on the

other

market

without

effect

ing

necessary

proc

edures

wi

th

t

he

depositary.

This

c

ould

result

in

time

delay

s

and additional cost for ho

lders of GDSs.

If

we

do

not file

or maint

ain

a

registration

state

men

t

and

no

exemption

from

the

Securities

Act

of

1933

(“Securities

Act”

)

registration

is

available,

U.S.

holde

rs

of

GDSs

may

be

un

able

to

exercise pre-emp

tive right

s granted to our holde

rs of shares underlying

GDSs.

Under

the

GCL,

i

f

w

e

issue

new

s

hares

as

part

of

a

c

apital

increase,

our

sh

areholders

may

have

the

right

t

o

subscribe

to

a

pro

portional

number

of

shares

of

the

same

class

to

maintain

their

existing

ownership

perc

entage.

R

ights

to

subscribe

for

shares

in

th

ese

circums

tances

are

known

as

pre

-emptive

rights.

In

addition,

shareh

olders

are

entitled

t

o

the

r

ight

to

subscribe

for

the

unsubscribed

shares

remaining at the end of

a pre-

emptive rights offeri

ng on a pro rata b

asis, known as

accretion rights.

Upon

t

he

oc

currence

of

a

ny

future

inc

rease

in

o

ur class

B

shares, U.S.

p

ersons (as

defined i

n

Regulation

S

under

the

Securiti

es

Act) ho

lding

our

s

hares

underlying

G

DSs

or

our

GDSs

may

be

un

able

to

exerc

ise

pre-emptive

and

accret

ion

rights

grante

d

to

our

holders

of

s

hares

underlying

GD

Ss

in

connection

with

any

future

issuance

of

our

s

hares

underly

ing

GDSs

unl

ess

a

r

egistration

s

tatement

under

the

Securities

Act

is

effective

wit

h

respect

to

both

the

pre

-e

mptive

r

ights

and

the

n

ew

shares

underlying GDSs, or an exemption from the registration requirements o

f the

Securities Act is available.

We

are

not

obligate

d

to

file

or

maintain

a

registration

statement

rel

ating

to

any

pre

-emptive

rights

offerings

with respect

to our

shares

underlyin

g

GDSs, and

w

e

cannot assure

t

hat

w

e

will

file or

maintain

any

s

uch

re

gistratio

n

s

tatement

or

t

hat

an

exe

mption

from

registration

will

b

e

av

ailable.

Unless

those

shares

underlying

GDSs

or

GDSs

are

registered

or

an

exempt

ion

fr

om

registr

ation

applies,

a

U.S.

holder of our shares und

erlying GDSs or our G

DSs may

receive only the

net

proceeds from those

pre-

emptive r

ights an

d accret

ion rights

if t

hose

rights can

be ass

igned by

the G

DS

depositary

. If

the ri

ghts

cannot

be

sold,

t

hey

will

b

e

allowed

to

l

apse.

Furthermore,

the

equity

interest

of

holders

of

shares

or

GDSs located in the

U.S. may be d

iluted proportiona

tely upon future cap

ital increas

es.

We

are

o

rganised

under

th

e

laws

o

f

Argentina

and

holders

of

the

GDSs

may

find

it

difficult

to

enforce civil liability cl

aims against u

s, our directors, office

rs and certain e

xperts.

We

are organised

under th

e laws of Argent

ina. A sign

ificant portion of

our and o

ur subsid

iaries’ assets

are

located

in

Argentina.

Furthermore,

almost

all

of

our

directors,

officers

and

advisors

reside

in

Argentina.

Inv

estors

m

ay

not

be

able

to

effect

service

of proc

ess

in

England

upon

such

p

ersons

or

to

enforce

judgments

pred

icated

upon

t

he

c

ivil

liability

p

rovisions

of

English

l

aw

against

them

or

us

in

English

courts.

L

ikewise,

it

may

also

be

difficul

t

for

an

investor

to

enforce

in

English

courts

judgments

obtained

a

gainst

us

or

these

persons

in

co

urts

located

in

jur

isdictions

o

utside

En

gland,

i

ncluding

judgments

predicat

ed

upon

the

c

ivil

liability

provisions

of

E

nglish

law.

It

may

also

be

difficult

for

an

investor t

o

bring

an

or

iginal

action

in an

Argent

ine

court

predicated

u

pon

the

civil

liability

prov

isions

of

English law against us or t

hese pers

ons.

Prior

to

any

enforcement

in

Argentina,

a

judgment

issued

by

a

n

E

nglish

co

urt

will

b

e

subject

to

the

requirements

of

Art

icle

517 through

519

of

the

Argentin

e Fed

era

l

Civil

and

Commerc

ial

Procedure

Code

if

enforcement

is

s

ought

before

fed

eral

courts

or

c

ourts

with

juris

diction

in

commerc

ial

matters

of

the

City

of

Buenos

Aires.

Those

requirements

are:

(1)

the

judgment,

which

must

be

valid

and

final

in

the

jurisdiction where

re

ndered, was

issued

by a

comp

etent

court in

acc

ordance with

th

e A

rgenti

ne

principles

regarding

intern

ational

jurisdiction

and

resulted

from

a

personal

action

,

or

an

in

rem

action

74

with

respect

to

personal

property

which

w

as

transferr

ed

to

Argen

tine

territor

y

during

or

after

the

prosecution

of

the

fore

ign

action;

(2)

the

def

endant

against

whom

enf

orcement

of

th

e

j

udgment

is

sought

was

personally

serv

ed

with

the

s

ummons

and,

in

accordance

w

ith

due

proc

ess

of

law,

was

given

a

n

opportunity

to

defen

d

against

foreign

ac

tion;

(3)

the

judgment

must

be

v

alid

in

t

he

jurisdict

ion

where

rendered,

a

nd

its

a

uthenticity

must

be

established

in

accordance

with

the

requir

ements

of

Argentine

law;

(4)

the

judgment

does

not

violate

the

principles

of

public

policy

of

Ar

gentine

law;

and

(5)

the

judgment is not

contrary

to a

prior or s

imultaneous

judgment of an

Argentine

court. Any docum

ent in

a

language

ot

her

th

an

Spanish,

incl

uding,

w

ithout

limitation,

the

foreign

judgment

and

ot

her

d

ocuments

requires

filing

with

the

relevant

court

of

a

duly

legalised

translat

ion

by

a

s

worn

public

translator into the Spa

nish language.

14.

BUSINESS

PROJECTIONS AND PLANN

ING

Grupo Clarín seeks to maintain and conso

lidate its presenc

e in the local and regional

m

arket, focusing

on the creation of qua

lity contents in all m

ultimedia and mul

tiplatform formats.

All

t

he

Group’s

business

un

its

will

strive

to

seize

op

portunities,

seekin

g

t

o

re

inforce,

improv

e

and

expand

the range of pro

ducts and s

ervices offered;

increas

e mark

et share; reach ne

w audiences

and promote

permanent innovatio

ns in all its

activities.

Grupo

Clarín

will

continue

to

optimize

even

more

the

productivity

and

efficiency

levels

in

all

its

areas

and

subsidiaries

. It will seek

to develop and apply

best

practices in eac

h of its process

es.

At

the

corporate

level, i

t

will

continue

to

focus

on

th

e

ma

in

proc

esses

to

c

onsolidate sustainable,

healthy

and

efficient growth from

different perspectives:

quality products and

s

ervices, human

capital, business

st

rategy, innovation, financi

al structure, manageme

nt control, and c

orporate social

responsibility.

Grupo

Cl

arín

w

ill

c

ontinue

to

analyze

alternative

new

v

entures

re

lated

to

its

mission

an

d

s

trategic

objectives both in Argentina and abroad, as long as they

add value to its stakeholders

and are feasible

and viable under the

prevailing economic env

ironment.

Grupo C

larín

rema

ins c

ommitted

to

journalism

a

nd

the

generation

of c

ontent,

with

a

gro

wing

focus

o

n

digital

media,

which

has

be

en

o

ne

of

the

largest

str

ategic

stakes

of

th

e

C

ompany

fo

r

nearly

two

decades.

To

this

end,

it

wi

ll

re

ly

on

the

va

lue

and

prestige

of

its

trademark

s,

which

have

the

largest

rates

o

f

credibility

and

acceptance

in

Argentina.

Th

e

Com

pany

will

use

its

bro

ad

exper

ience

in

the

cr

eation

o

f

contents, rec

ognized world

wide

-especial

ly in

the S

panish-s

peaking wor

ld-,

to bo

ost the suc

cess of

its

new platforms and f

ormats.

Grupo Clarín reaffirms its sustained com

mitment to regulatory

compliance, its readers,

audiences, and

the

country.

In

its

d

aily

wor

k,

Grupo

C

larín

seeks

to

assume

wi

th

strength

and

responsi

bility

the

rol

e

that

the

media

are

c

alled

t

o

play

thro

ugh

pro

fessional

and

independe

nt

journali

sm

and

throu

gh

the

defense

and

pro

motion

of

principles

and

v

alues,

such

as

freedom

of

speech,

i

nc

lusion

and

divers

ity,

the

e

ffectiveness

of

r

epubli

can

democracy

and

the

pr

omotion

of

the

c

omprehens

ive

development

of

Argentina and its inha

bitants.

15.

PROPOSAL OF

THE BOARD OF DIRE

CTORS

Grupo

Clarín

is

a

holding

company.

Its

results

derive

mainly

from

th

e

operations

of

its

subsi

diaries.

Therefore,

its

li

quidity

positi

on

depends,

among

other

thin

gs,

on

the

distribution

of

dividends

of Gr

upo

Clarín's

subsid

iaries

-

which

hav

e

to

me

et

their

investment

and

interest

payments

needs

-,

the

contributions

r

equired

by

other

subsidiaries

and

the

expected

future

cash

flows

from

operating

and

financing

ac

tivities.

In

t

his

sense,

the

me

dia

are

face

d

every

day

with

the

challe

nge

posed

by

digital

transformation, with the development of a new bu

s

iness model that does

not com

pro

mise their

75

journalistic

independence

and

the

q

uality

of

their

contents

in

a

mature

market,

and

w

ith

th

e

stro

ng

impact that Argentin

e economy has on its

revenues.

In

th

e

ye

ar

ended

Dec

ember

31,

2021,

th

e

C

ompany

recorded

a

n

et

profit

o

f

$

1,039,043,355,

mainly

derived fro

m the

earnings

generat

ed by

the

segments

Broadcas

ting a

nd Pro

gramming

and

Publishing

and

Pri

nt

and

Di

gital

Publications.

Taking

int

o

cons

ideration

that

the

Company

's

Leg

al

Res

erve

was

entirely allocated

to absorb the

accumulated deficit from previous years,

the Board of

Directors

proposes

to

allocate

the total

of

re

tained

earnings as

of

December 31

, 2021

to

set

up

t

he

Legal

Reserv

e

in accordance with the provisions of CNV

re

gulations (pursuant to Article 5, Chapter III, Section II,

Title

IV).

The

Board of

D

irectors

of

G

rupo

Clarín

would

like

to

t

hank

its

customers,

suppliers, employees,

bank

ing

and

f

inancial

institutions

and

other

stakeholders,

who

are

the

key

players

in

a

chieving

the

results

obtained this fiscal year by

the Company's

man

agement.

The Board of Directors

Buenos Aires,

April

22

, 2022

16.

EXHIBIT I - REPOR

T ON THE CODE

OF CORPORATE

GOVERNANCE

OF

GRUPO CLARÍN

S.A.

ROLE OF THE BOARD O

F DIRECTOR

S

Principles

I.

The com

pany

shall

be

led

by

a

prof

essional

and

qualif

ied

Board

of

Direct

ors

in ch

arge

of

laying

the

f

oundations

for

th

e

c

ompany's

sustainable

success

.

The

Board

of

Direc

tors

is

the

gu

ardian

of the company and t

he rights of all its share

holders.

II.

The Board of D

irectors shal

l be responsi

ble for determi

ning and prom

oting the

corporate culture

and values.

The

Board

of D

irectors’

performance

shall

guara

ntee the

observ

ance

of the

highest

standards of ethics an

d integrity, based o

n the best int

erest of the compa

ny.

III.

The

Board of

Directors

shall

be in

charge of

ensuring a

strategy

insp

ired

by the

company’s vision

and

mission,

aligned

with

its

values

and

culture.

The

Board

of

Directors

shall

engage

constructively

with

manage

ment

to

ensure

the

correct

developm

ent,

execution,

monitoring

and

revision of the company's

strategy.

IV.

The

Board

of

Direc

tors

s

hall

control

and

supervise

on

an

ongo

ing

basis

the

direction

of

the

company, e

nsuring t

hat m

anagement

takes

actions

ai

med at

the

implementat

ion

of the

strategy

and the business plan a

pproved by the

Board of Direct

ors.

V.

The Board

of D

irectors

must

have t

he necess

ary mech

anisms and

policies

in orde

r to

efficiently

and effectively fulfill th

e role of the Board an

d each of its members

.

Recommended P

ractices

1.

The

Board

of

D

irectors

generates

an

ethical

work

culture

and

est

ablishes

the

visi

on,

missi

on,

and values of the com

pany.

The

Company

ap

plies

the

rec

ommended

prac

tice.

The

Board

of

Directors

est

ablishes

the

values

and

principles

th

at

set

th

e

general

fr

amework

within

wh

ich

the

C

ompany’s

ac

tivities

must

be developed. They are implemented by Depar

tme

nts or Divisions through a consistent

message

in

the

conduction

of

its

daily

activit

ies,

and

are

reflected

in

its

corpo

rate

policies,

among

w

hich

the

most

relev

ant

is the

Code

of E

thics

an

d

Conduct.

T

hose

principles

an

d

va

lues

follow

the

highest

ethical

standards,

as

demonstrated

by

the

Company

along

its

track

record,

among

w

hich

the

followin

g

stand

out:

its

co

mmitment

to

provide

h

onest

and

i

ndependent

communication,

exerc

ised

with

profession

al

r

esponsibility,

s

eeking

to

s

trengthen

th

e

ins

titutions

that

s

ustain

t

he

democratic

sys

tem,

promoting

debate

and

comm

unication

betwe

en

different

sectors

of

soci

ety.

The

Code

of

Ethics

and

Conduct

descr

ibes

objective

s

cenarios

wher

e

a

76

conflict

of

interest

may

exist

and

provides

a

non

-

exhaustive

list

of

examples

that

standar

dize

conflicts

including

re

lations

with

the

personnel,

po

litical

and

gov

ernmental

relat

ionships,

and

corporate asset prot

ection.

2.

The

Board

of

Directors

se

ts

out

the

genera

l

strateg

y

for

the

Company

and

approv

es

the

strategic

pla

n

developed by

Manag

emen

t.

In

doing

s

o,

the

Board

of

D

irectors

takes

into

consideration environmental, social, and corporate governance factors.

The Board of

Directors

supervises

its

implementation

through

the

use

of

key

performance

indicators

a

nd

tak

ing

into

consideration th

e best interes

t of the Company a

nd the rights of a

ll its sharehold

ers.

The

C

ompany

applies

the

recommend

ed

practice.

T

he

C

ompany's

Board

of

Directors

an

d

Management

design

the

general

strategy,

consi

dering

as

the

g

lobal

framework

the

opportunities

and thr

eats

of the

context

in w

hich

it

operates (extern

al risk

f

actors),

the

Company's

internal

situation

(interna

l

risk

factors)

in

the

light

of

th

e

esta

blished

mission

and

values, and an

alyze, disc

uss and appr

ove on a

n annua

l basis th

e strategic

plan, composed

of

it

short,

me

dium

and

long

term

goals,

and

mo

nitor

its

implementation

using

metric

s

that

allow

for

an ad

equa

te

oversight of

s

aid

s

trategic plan.

In addition,

the Board

hol

ds

quarter

ly

meetings

at

which

t

he

Directors

asse

ss

the

Company’s

operat

ing

and

fin

ancial

p

osition,

wh

ich

inclu

des

a comparison with th

e previous quarter.

3.

The Board of Directors supervises management and ensures that it develops, imp

lements and

maintains an adequ

ate internal control sy

stem with clear r

eporting lines.

The

C

ompany

applies

t

he

rec

ommended

practice.

The

Board

of

D

irectors,

which

is

mostly

composed

of

n

on-executive

directors,

overs

ees

the

Co

mpany's

operat

ions

not

on

ly

with

resp

ect

to

the

ac

hievement of

the established

o

bjectives an

d goals,

b

ut

also

with

respec

t

to

the integrity

and

commitment

with

the

values

of

th

e

organizat

ion,

the

c

onsistency

of

its

ac

tions

with

its

mission

and values

and the

capacity

to convey

those values

to all

its employees.

Thr

ough

a set

of

mechanisms

and

proc

edures,

the

Board

of

Directors

monito

rs

that

the

activities

c

arried

out

by

Managem

ent

comply with

the policies

i

n pl

ace, that

the objectives

be accomplished,

that

the

changes in the enviro

nment be contem

plated in the dec

isions adopted, and th

at the measures

required

to

correct

devi

ations

be

i

mpleme

nted.

Among

the

m

ain

mechanisms,

t

he

Company

has de

tailed systems and

p

rocedures that

set quantitative and

qualitative rules

for the

approval

of

transactions,

regular

management

control

meet

ings,

and

internal

audits.

Th

e

Division

of

Corporate

Control

follows

high

standards

of

co

ntrol

to

assure

the

g

eneral

control

system

and

compliance by

the Co

mpany

. Through

previously

established

metrics, t

he upper

management

regularly

reports on

its performance,

allowing the

Bo

ard

of

Directors

to

assess the

performa

nce

of

those

responsi

ble

for

the Company’s

operations.

The

Comp

any’s

Board of

Directors,

through

its Audit Commit

tee, monitor

s that the Co

mpany has in

place an a

dequate inter

nal control an

d

accounting

and

administrat

ion

system.

Sa

id

Committee

also

m

eets

qu

art

erly

with

the

extern

al

auditors as part of the

monitoring of the

proper perform

ance of these contro

l systems.

4.

The

Board

o

f

Directors

designs

c

orporate

g

overnance

structures

and

prac

tices,

appoints

the

person

responsible

for

their

implementation,

mon

ito

rs

their

effec

tiveness,

and

sugg

ests

changes as deeme

d necessary

.

The

Company

does

no

t

apply

the

recomm

ended

prac

tice

within

the

terms

mentioned

above

because

the

Board

of

Directors

has

not

formally

designated

an

o

fficer

responsible

for

the

implementation of the corp

orate governance structure

s and initiatives. However, t

he Company

has the

D

ivisions of

Cor

porate Control and

Corporate

Affairs,

which lead the

implementat

ion of

the

Compa

ny’s

c

orporate

g

overnance

practices,

and

analyze

the

need

to

intro

duce

cha

nges

upon

amendments

in

regulations

,

upon

or

c

hanges

in

the

Company's

businesse

s,

processes

or

structure.

In

this

sense,

the

Compa

ny

also

has

a

Departmen

t

of

Inves

tor

Relations,

a

Department

of

I

nternal

Audit,

the

Audit

Comm

ittee,

and

th

e

Supervisory

Committee.

Those

practices

have

bee

n

de

emed

ad

equate

and

approved

by

the

Co

mpany's

Board

of

Directors.

77

For that

re

ason,

the Company

ap

plies the principles

that underlie

this practice. The

Company’s

website has a Corporate Governance tab, which describes the role of the Board of Directors in

its implementation.

5.

The

mem

bers

of

the Board

of

Directors

have

s

ufficient

time

to

perform their

duties i

n

a

professional

and

efficient

manner.

The

Board

of

Directors

and

its

c

ommittees

have

clear

an

d

formalized

rules

of

operati

on

and

org

anization,

wh

ich

are

disclosed

throu

gh

the

Company's

website.

The

Company applies the recommended

practice. The

Company's

Board

of

Directors is

composed

of

members

that

have

imp

eccable

personal

and

professiona

l

quali

f

ications

that

enable

the

m

to

p

erform

t

heir

dut

ies

in

the

B

oard.

In

addition,

t

hey

devot

e

suff

icient

time

to

adequately

perform

their

duties

and,

therefore,

they

attend

without

fail

the

meetings

to

which

they are

called

and

r

eceive

relevant

informa

tion

suf

ficiently in

a

dvance

so

that

th

ey

can

mak

e

informed

decisions

at

the

Board.

As

a

r

esult

of

the

a

bove,

given

the

f

act

t

hat

the

r

ules

t

hat

govern their actions, as well

as their roles, functions and

responsibilities arise from the

Company's

Bylaws

,

which

are

pub

lished

in

the

F

inancial

Informat

ion

Highway

and

on

the

Company’s

website,

the

C

ompany

has

not

deemed

it

necessary

to

state

in

a

n

add

itional

document the

rules that

set

out the

duties, ro

les and

functions o

f the

members

of the B

oard of

Directors. The Audit Commi

ttee, composed of member

s of the Board of Di

r

ectors, has a Rules

of Procedure, which was f

iled with the CNV.

CHAIR OF THE BOARD O

F DIRECTOR

S AND COM

PANY SECRETAR

Y

Principles

VI.

The

Chair

of

the

Boar

d

is

in

charge

of

ensurin

g

the

effective

fulfillme

nt

of

the

functions

of

t

he

Board

of

D

irectors

and

has

a

leading

ro

le

among

the

members.

The

Chair

sh

all

generate

a

positive

work

dynamic

and

promot

e the

co

nstructive

engagement

of

the

mem

bers

of

the B

oard,

and

shall

also

ensure

t

hat

they

have

the

ele

ments

and

information

necessary

for

decision

-

making.

The

above

a

lso

a

pplies

to

the

Cha

irs

of

each

committee

of

t

he

B

oard

of

Directors,

regarding their corr

esponding functions.

VII.

The

Chair

must

lea

d

process

es

and

establish

struc

tures

to

ensure

the

com

mitment,

objec

tivity

and

competence

of

the

members

of

the

B

oard,

as

we

ll

as

the

best

operat

ion

of

t

he

body

as

a

whole and its evolut

ion according to the c

ompany's ne

eds.

VIII.

The Chair must ensure that the Board of Directors as a

whole is fully committed and responsible

for the succession of

the CEO.

Recommended P

ractices

6.

The

Ch

air

of

the

Board

of

Directors

is

responsible

for

the

proper

orga

nization

of

the

Board

of

Directors’ meetings, prepares

the agenda ensuring the cooperation of the other members, and

ensures

that

t

hey

r

eceive the

necessary materials

wel

l

in

advance

for

their

efficient

a

nd

informed

particip

ation.

The

Chairs

of

the

committees

bear

the

sa

me

responsi

bilities

for

their

meetings.

The

C

ompany

app

lies

the

recomm

ended

practice.

The

C

hair

of

the

Co

mpany’s

Board

o

f

Directors leads and

organiz

es the

Board of Directors’ me

etings

and

receives the support of

the

Division

of

Corpora

te

Affairs,

which

, a

mong

its

dut

ies,

is

responsib

le

for

assisting

the Cha

ir o

f

the

Board

regarding

the

coordinat

ion

of

meetings,

te

chnical

s

u

pport,

delivery

of

information

sufficiently

in

advance

for

the

work

carr

ied

out

by

th

e

D

irectors

a

nd

is

also

res

ponsible

for

minute-taking

at

those

meetings,

among

oth

er

activities.

The

members

of

the

Board

of

Directors

are called s

ufficiently in

advance

s

o that they

can atte

nd the me

etings an

d receive

in due tim

e

the relevant i

nformation req

uired to deci

de on the

items

of the agenda

of the

meeting to w

hich

they are called.

78

7.

The

Ch

air

of

the

Board

of

Directors

ensures

t

he

pr

oper

internal

o

peration

of

the

Board

of

Directors by implem

enting formal proc

esses for condu

cting annual performanc

e reviews.

The

Co

mpany

does

not

apply

th

e

r

ecommended

practice

through

the

implem

entation

of

a

formal

annual

performance review

pr

ocess. However,

it complies

w

ith

the

principles that

underlie

t

he

r

ecommended

practice

b

ecause

the

Chair

of

the

Compa

ny’s

Board

of

Direct

ors

ensures

the

correc

t

and

a

dequate

internal

functioning

of

the

Bo

ard

t

hrough

the

verification

of

the compliance

with all t

he

obligations applica

ble to its

members

and thos

e that ari

se from

the

Bylaws,

the

la

ws

and

th

e

Code

of

Ethics

and

Cond

uct.

The

s

har

eholders

gathered

at

the

Shareholders’ Meeting are t

he ones who, upon being furnished w

ith the relevant and sufficient

information, perform a

n annua

l review of the perf

ormance of the Bo

ard of Directors

at the time

of

considering

the

performance

of

its

memb

ers.

Among

t

he

informat

ion

m

ade

av

ailable

to

the

Shareholders is the An

nual Report, wh

ich gives accou

nt of the performance

of Management.

8.

The Chair generates a positive and constructive workpl

ace for all the members of the Board of

Directors

and

ensures

that

they

r

eceive

on

going

tra

ining

to

keep

up

to

date

an

d

t

o

be

able

to

properly fulfill their dut

ies.

The

Company applies

th

e

recommended practice.

Th

e Company's

Bo

ard

of Di

rect

ors

performs

its

duties

in

an orderl

y and

harmon

ious

environment among

its memb

ers,

ensuring constructive

and

efficient

teamwork

for

t

he

b

enefit

of

the

Company

and

its

share

holders.

Ev

en

though

t

he

Company

has

not

impleme

nted

an a

nnual

formal

training

progr

am, t

he m

embers

of

the

Board

of

Directors, in

addition to

their

professional

and

personal qualifications and

experience,

regularly

receive

updates,

through

the

coordi

nation

carr

ied

o

ut

by

the

Division

of

Corpora

te

Affairs, information, training,

concern

ing the

industry, business or

regula

tions, for

the adequate

fulfillment

of

their

f

unctions

and

r

esponsibilities,

training

given

by

h

ighly

qualified

officers

w

ith

experience

in

th

e

Compan

y's

businesses

,

renowned

market

prof

essionals,

industry

referents

or specialized consu

ltancy firms.

9.

The

Co

mpany

Secretary

p

rovides

assistance

to

the

Chair

of

the

B

oard

of

Direc

tors

in

the

effective

adm

inistration

of

the

Board

and

coo

perates

in

the

communication

with

th

e

shareholders, the Boar

d of Directors and m

anagement.

The Company applies the recommended practice.

Even though the Company does not

have a

Company Secretary, it has a

Division of Corporate Affairs that

assists the Chair of

the Board of

Directors

in

admin

istrative

and

orga

nization

tasks

r

equired

for

the

a

dequate

func

tioning

of

the

Board, such as

those related to the

preparatio

n and

dist

rib

ution of information, meeting

minutes-taking, training, provision

of information and

induction for

new members, assistance in

the

comm

unication

among the

members of

the

Board

of

Directors and

of

t

he

latter

wi

th

Management, organization

of

shar

eholders’

Meetings,

among

others

.

Taki

ng

into

consideration

the legal nature required in some of the functions of the Board of Directors, it also receives the

advice of

externa

l legal

advisors

, who,

even t

hough

they adv

ise th

e Board

on

an

annual bas

is

regarding

the

holding

of

Shareho

lders’

Meetings

and

also

support

th

e

Chair,

s

ince

2020,

they

have

advised

the B

oard on

t

he

holding

of

remote S

hareh

olders’ Meetings

and

Board

of

Directors’ Meetings

in

confor

mity

with the

man

datory and

preve

ntive

socia

l

isolation ordered

by

the

Nat

ional

Exec

utive

Branch

through

Decr

ee

No.

297/20

20,

purs

uant

to

R

esolution

No.

830/20 issued by the N

ational Secur

ities Commission.

In

addition,

the

Company

has

a

Department

of

Investor

Relations wh

ich

is

respo

nsible

for

the

relationship and com

munication w

ith the sharehold

ers of the Company

.

10.

The Chair of the Board of Directors ensures the involvement of all its members in the

development and ap

proval of a succession

plan for the

company's CEO.

79

The

Comp

any

does

not

apply

t

he

recomm

ended

practic

e i

n

t

he

terms

set

out

in

it.

The

Company’s

Div

ision

of

Corporate

Human

Resources

is

in

charge

o

f

the

identification

and

retention

of

talents

for

manager

ial

positions,

as

well

as

the

plann

ing

of

th

eir

success

ors.

It

receives the assistance

of human resourc

es pro

fessionals hired to suc

h end.

COMPOSITION, NOM

INATION AND

SUCCESSION

OF THE BOARD OF

DIRECTORS

Principles

IX.

The Board must have adequate lev

els of independence and divers

ity in order to make decisions

in the company’s best interest, avoiding

groupthink

and decision-making

by individuals or

dominant groups w

ithin the Board.

X.

The

Board must

ensure

that

the

c

ompany

has

forma

l

pr

ocedures

for the

proposal and

nomination

of candidates to fill posit

ions in the Board

within a fram

ework of a succes

sion

pla

n.

Recommended P

ractices

11.

The Board

of Directors

has

at

least

two

indepe

ndent

members

in

confor

mity

with

the

effective

criteria established by t

he Argentine Securit

ies Commiss

ion.

The

Company applies the recommended

practice. The

Company's

Board

of Direct

ors is

composed

of

mem

bers

wh

o

are

also

managers

of

t

he

Company,

non

-

independent

directors

without

execut

ive

responsi

bilities

and

independent

directors

.

The

B

oard

of

Dir

ectors

has

two

permanent

directors

and

two

alterna

te

directors

wh

o

are

inde

penden

t

in

co

nformity

with

t

he

criteria

es

tablished

by

the

Argentine

Securities

Commission.

Their

n

ames

and

capacity

are

published on the Co

mpany’s website an

d in that of the

Argentine Securit

ies Commission.

12.

The Company ha

s a Nomination Committee that has

at leas

t three

(3) members and is chaired

by

an

independent

director.

If

the

Chair

of

the

Board

of

Directors

is

also

the

chair

of

the

Nomination

Committee,

he/she

shall

refrain

fr

om

part

icipating

in

th

e

ap

pointment

of

his/her

o

wn

successor.

The

Company

does

not

apply

the

reco

mmended

prac

tice

because

it

does

not

h

ave

a

nomination

comm

ittee.

The

Company’s

Bylaws

set

out

the way

in

which

each

class

of

s

hares

shall

appo

int

the

member

s

of

the

Bo

ard

of

Director

s,

i.e.,

the

sh

areholders

appoint

their

directors. The Byl

aws are publ

ished on the webs

ite of the Nationa

l Securities Com

mission.

13.

The Board of Directors, through the Nomination Committee, develops a success

ion plan for its

members

that

guides

th

e

candidate

pre

-select

ion

proces

s

to

fill

v

acancies

and

takes

int

o

consideration

the

non

-bindi

ng

recom

mendations

of

its

members,

the

C

EO

and

the

Shareholders.

The

Company

does

not

apply

the

recommend

ed

pr

actice.

The

Company

does

not

have

a

nomination committee.

See the explanat

ion related to the recom

mended pract

ice in p

o

int 12.

14.

The Board of Directors im

plements an onboard

ing program for

its newly appointed

members.

The

Company

applies

th

e

recommended

prac

tice.

T

he

Comp

any

provides

ass

istance

to

the

new

mem

bers

o

f

the

Boar

d

of

Directors

through

an

induction

proces

s

th

at

cov

ers

all

the

necessary

aspects

to

gain

an

in-de

pth

k

nowledge

of

the

C

ompany,

through

the

c

ontact

w

ith

management and

access to

documentation related

to the

Company to

le

arn about

i

ts structure,

businesses,

oper

ations,

personnel,

processes

,

policies

,

leg

a

l

advisors

and

ap

plicable

regulatory

fra

mework.

In

addition,

the

new

members

,

as

well

as

thos

e

elected

receive training under the

terms indicat

ed in practice 8 above.

REMUNERATION

80

Principles

XI.

The Board

of

Directors

must

generate

incentives

thr

ough re

muneration,

in

order to

align

management

-

led

by

the

C

EO-

and

the

Board

with

the

long

-term

interests

of

the

company,

so

that all the directors

equally comply w

ith their obligatio

ns with respect to a

ll its shareholders.

Recommended P

ractices

15.

The

Compa

ny has

a Remuneration Committee that

is composed of

at least

three (3) members.

All the members are i

ndependent or n

on-execut

ive.

The Company does

not apply the recom

mended pract

ice. The Board does n

ot have in place

a

remuneration

c

ommittee.

Ev

en

though

the

Co

mpany

hires

independent

professional

h

uman

resources

advisors

th

at

advise

th

e

Company

re

garding

th

e

r

emuneration

of

the

Board

of

Directors,

th

e

Board

does

not

have

a

r

emuneration

com

mittee.

In

addition,

the

Audit

Committee

provides

a

n

opinion

—

in

c

onformity

with

the

app

licable

regulations

and

a

t

the

request

of

th

e

Board

of

Directors

before

t

he

Annual

Shareholders’

M

eeting

—

on

the

reasonab

leness

of

the

fees paid

to the

members

of

the Board

of

Directors

taking i

nto consid

eration the

ir

professional

background

a

nd

rep

utation,

tasks

performed

,

responsi

bilities

and

the

amount

of

time

devoted

to

the

performance

of

their

duties.

On

t

he

o

ther

ha

nd,

the

Division

of

Corporate

Human

Resources

is

in

charge

of

s

upervising

the

remuner

ation

of

the

first

lin

e

managers

w

hich

includes

the

com

petitiveness

of

the

remun

eration

practices

a

nd

p

olicies.

Said

Department,

with

the

advice

of

inde

pendent

human

r

esources

professionals oversees

that

the

re

muneration of

managers

is

in

line

w

ith

the

short,

mediu

m a

nd

long

ter

m returns

according

t

o th

e

Company

’s

management object

ives.

16.

The

Board

of

Directors,

through

th

e

Rem

uneration

Committee,

es

tablishes

a

remuneration

policy for the CEO and

the members of t

he Board.

The

Company

does

not

apply

the

recommen

ded

practic

e

in

the terms

set

out

in

it.

As

ment

ioned

in

the

explanation

rela

ted

to

recommended

pr

actice

15,

the

Board

of

Directors

does

not

have

in

place

a

re

muneration

c

ommittee.

The

policy

t

hat

provides

f

or

the

r

emuneration

of

management

is

established

by

the

Division

of

Corp

orate

Human

Resourc

es.

That

policy

sets

out

a

fixed

an

d

varia

ble

re

muneration

scheme.

T

he

f

ixed

compensation

is

the

level

of responsib

ility attached

to

each posit

ion, the

competit

iveness w

ith respect

to th

e mark

et and

the

performance of the

executive. The

a

nnual variable

remuneration is

related to

the objectives

set by the

Com

pany for the fiscal year and the degree of

compl

iance, which are in line with

th

e

Company’s

business

plan

and

strategy.

On

t

he

oth

er

hand

,

the

executives

have

the

option

of

adhering to

a long-term savings plan, which i

s used by

the Company as

a strong

retent

ion tool.

The

remunera

tion

of

the

Board

of

Direct

ors

is

approved

by

the

shareholders

at

the

Annual

General Shareh

olders’ M

eeting. In

addition, t

he Boar

d

of Directors

pr

oposes the sharehold

ers

to

authorize

the

payment

of

advances

of

fees

up

to

a

certain

amount

subject

to

the

following

Shareholders’

Meeting

at

which

s

hareholders

shall ap

prove their

rem

uneratio

n,

advances

distributed

by

the

Board

of

Directors

among

its

memb

ers

in

accordance

with

the

delegation

made

by

the

A

nnual

Shareholders’

Mee

ting.

Before

proposing

an

amount

of

fees

to

be

paid

and

subm

itting it

on an

ann

ual ba

sis to the

c

onsiderati

on

of the shareholders

for their approval,

the Board

of Directors receives

an opinion

from the Audit Committee on the

reasonab

leness of

those fees.

CONTROL ENVIRONM

ENT

Principles

XII.

The

Board of

Direc

tors

shall ensure

the

ex

istence

of a

c

ontrol

environmen

t,

compos

ed of

internal

controls

develope

d

by management,

internal audit,

ris

k ma

nage

ment,

regu

latory

comp

liance an

d

external

audit,

all

of

w

hich

shall

establish

the

lines

of

defe

nse

necessary

to

ensure

the

integri

ty

of the company's op

erations and its fi

nancial reports.

81

XIII.

The Board of Directors must ensure the existence of a compreh

ensive

risk management system

that allows

management

and

the Board

of

Directors

to

efficiently direct

the co

mpany

towards

its

strategic goals.

XIV.

The

B

oard of

Directors

must

ensure t

he existence

of a

person

or depart

ment (dep

ending on

the

size and complex

ity of t

he business, the

nature of its o

perations and th

e risks it fa

ces) in charg

e

of

the

internal

audit

of

the

company.

Suc

h

audit

shall

be

independent

and

objective,

with

clear

reporting lines, in

order to properly evaluate an

d audit the company’s i

nterna

l

c

ontrols, corporate

governance processes

, and risk man

agement.

XV.

The

Audit

Committee

of

the

Bo

ard

shal

l

be

c

ompose

d

of

qualified

and

experien

ced

members

,

and shall perform

its duties transparently a

nd independently.

XVI.

The

Board

of

Directors

must

estab

lish

adeq

uat

e

pro

cedures

to

ensure

the

in

dependent

and

effective work performed

by the Externa

l Auditors.

Recommended P

ractices

17.

The

Board

of

D

irectors

determines

the

com

pany’s

risk

app

etite

and

also

superv

ises

an

d

guarantees the existence of

a comprehensive risk management system to identify, assess and

decide on

the co

urse of

act

ion and

monitor

the

risks

faced by

the

Company

, includin

g, among

others, t

he

environme

ntal a

nd

social

risks

and

those in

herent

to

the

bus

iness i

n t

he

short

and

long term.

The

Company does not

apply the

recommende

d practice

in the

terms

set

o

ut in

it. Even though

the Division of

Corporate Control consolidates information about the risks posed by

the

Company's

operations

in

th

e

regular

r

eports,

which

are

analyzed

by

the

Co

mpany's

Board

of

Di

rectors

an

d,

in

particular,

by

the

A

udit

C

ommittee,

the

Comp

any

d

oes

n

ot

have

in

p

lace

a

formal

c

omprehensive

r

isk

management

process;

neither

does

t

he

Board

of

Dire

ctors

have

a

risk

management

c

ommittee.

H

owever,

the

C

ompany’s

m

anagement

conte

mplates

oper

ational,

env

ironment,

i

nformation,

f

inancial

and

non

-financi

al

risks

in

the

de

velopment

of

its

strategic

and

bus

iness

plan,

which

is

disc

ussed

with

th

e

Co

mpany’s

Bo

ard

of

Directors.

Those ri

sks

are

contem

plated in

the management of

th

e

Company's

acti

vities

,

which has

areas

and process

es

to i

dentify

and

manage

certain

risks

, such

as

environment,

equity

,

information,

financial, environm

ental and techn

ological risk

s. In addition,

the Company

has an Au

dit

Committee

compose

d

of

q

ualified

and

exper

ienced

members,

as

indicated

in

the

Pri

nciples,

which fulfills the duties co

nferred by the Ca

pital Market Law.

18.

The

Board

of Di

rectors

m

onitors

and

rev

iews

the

effectiveness of

t

he

ind

ependent

internal

aud

it

and

guarantees

th

e

resourc

es

for

the

implementat

ion

of

an

annu

al

audit

plan

bas

ed

on

risks

and a direct reportin

g line to the Audit

Committee.

The

Compa

ny

applies

the

recomm

ended

practice.

The

Company

has

an

internal

aud

it

department

that

is

independ

ent

fr

om

the

areas

of

the

Company

it

audit

s an

d

reports

to

th

e

Audit

Committee, which guarantees the

ob

jectivity of its

work

. Taking into

consideration the extent

of

the

Com

pany's

operations

and

the

g

uidelines

of

its

inte

rnal

rules,

th

e

Audit

Commit

tee

monitors

the

function of

said department through

the analysis of

t

he

reports issued, the

sufficiency of

the

resources available for the fulfillment of its duties and the consistency of its annual plan, which

is developed based on t

he audit risks ident

ified.

19.

The

internal

auditor

or

me

mbers

of

the

int

ernal

aud

it

department

are

independent

and

highly

qualified.

The

Compa

ny

applies

the

recomm

ended

practice.

The

Company

has

an

internal

aud

it

department

with

qualified

personnel

for

the

adequate

fulfillment

of

their

duties.

The

members

of

that

department

have

a

vast

professional

exp

erience

in

interna

l

au

dit,

financial

reportin

g,

fraud invest

igations an

d internal

contro

l. Said

staff

keeps

up to

date

on

an ong

oing bas

is. The

structure,

policies

and

guidelines

set

by

the

C

ompany's

Management

e

mpowers

the

depar

tment to

perform its d

uties without any kin

d of scope limitati

ons.

82

20.

The Boa

rd of Di

rect

ors has

an A

udit

Committee that works

in accordance with

r

ules of

procedure. Th

e co

mmittee

is

mostly

composed

of a

nd

chaired by

in

dependent

directors

and

it

does n

ot

include

the

CEO.

Most of

its

mem

bers

have

professional

exper

ience

in

financ

ial an

d

accounting areas.

The Company applies the recommended practice. The Board of Directors has an Audit

Committee

composed

of

a

majority

of

indepen

dent

directors.

Its

members

a

re

elected

by

the

Board

of

Directors

am

ong

its

members

a

nd

the

Chair

is

elected

by

the

me

mbers

of

the

Committee,

wh

o

acts

in

conformity

with

t

he

l

aws,

th

e

Bylaws

and

internal

r

ules.

Those

rules

were duly approved by the Board

and presented to the Comm

ittee

, and are regula

rly reviewed

by

its

members

.

The

members

of

the

Aud

it

Committ

ee

have

a

v

ast

exper

ience

in

fina

ncial,

accounting

and

internal

control

matters.

The

Chair

of

the

A

udit

Committee

is

an

independent

director.

The

Au

dit

Comm

ittee

issues

o

n

an

annu

al

b

asis

at

the

ti

me

of

pres

entation

of

the

annual f

inancial

statements

the rep

ort

that

discloses

the

treat

ment

given

to t

hose

matters

that

are within its competenc

e.

21.

The Board

of Directors, based on

the opinion of the

Au

dit Committee, approves a

policy f

or the

selection

an

d

mo

nitoring

of

external

auditors

that

prov

ides

for

the

indicators

to

be

considered

in

the recommendation to

th

e

Shareho

lders’

Meeting about the

continuity or

replacement of

t

he

external auditor.

The

Compa

ny

app

lies

the

recommended

prac

tice.

The

Audit

Com

mittee,

which

provides

an

opinion bef

ore

the

Annual

Shareholders’

Meeting

on

the

engag

ement

of th

e exte

rnal au

ditors,

has in

place

a policy

that

sets

out

the

guidelines

to

be

followe

d i

n the

as

sessment

of

the

work

performed

by

the ext

erna

l auditor,

in

order

to

iss

ue its

opinio

n on

the

prop

osal o

f the

Board

of

Directors

for

the

appointment

of

the

external

auditor,

to

ensure

and

assess

its

independence

and to perform a compr

ehensive asses

sment of its wor

k.

83

ETHICS, INTEGRITY

AND COMPLIAN

CE

Principles

XVII.

The

Board

of

Direc

tors

shall

design

and

est

ablish

appro

priate

structures

and

pract

ices

to

pro

mote

a

culture

of

ethics,

integrity

and

c

ompliance

with

standards

in

order

to

detect

and

address serious corpor

ate or persona

l breaches.

XVIII.

The

Board

s

hall

ensure

the establishment

of

formal

me

chanisms

to

prevent,

or

failing

this,

to

dea

l

with

confl

icts of

interest that ma

y arise in

the administration and

direction of

the company. It

s

hall

also have in

place formal procedures seek

ing to ensure that related party transactions are made

in the best interest of th

e company and the e

quitable treatment o

f all its shareholders.

Recommended P

ractices

22.

The

Board

of

Directors

ap

proves

a

C

ode

of

Ethics

and

C

onduct

that

reflects

the

ethical

and

integrity

values

and

princ

iples,

as

well

as

the

culture

o

f

the

company

. The

Code

of

Ethics

and

Conduct

is

communicate

d and

app

licable t

o a

ll t

he d

irectors,

managers

an

d em

ployees

of

the

company.

The

Compa

ny

ap

plies

th

e

recommended

practice.

The

Company

has

a

C

ode

of

Et

hics

and

Conduct

to

address

good

corporate

governa

nce

and

corporate

social

responsibility

practices,

approved

by

its

Board

of

Directors,

which

refl

ects

the

values

and

conducts

prom

oted

by

t

he

Company. All the

directors

, managers and employees of

the Compan

y are aware of said

Code

and

its

co

mpliance

is

mandatory

for

all

of

them.

The

Code

provi

des

f

or

s

anctions

in

cas

e

of

non

-compliance.

23.

The

B

oard of

Directors sets

out

and periodically

reviews an

Eth

ics

and Integrity

Pro

gram

based

on

risks,

size

a

nd

economic

capacity.

The

plan

is

clearly

a

nd

unequivocally

supported

by

management,

which

des

ignates

an

internal

officer

responsible

for

deve

loping,

coordinating,

supervising

and

reviewing

on

an

ongoing

basis

the

efficacy

of

the

program.

The

program

provides

for:

(i)

periodic

tr

aining

for

directors

,

administrators

and

emp

loyees

about

ethics,

integrity

and

compl

iance

issues;

(

ii)

internal

channel

s

to

report

irregu

larities,

open

to

third

parties

and

adequately

dis

seminated;

(iii)

a

policy

for

the

protect

ion

of

whistleb

lowers

from

retaliation;

and

an

internal

investigat

ion

system

that

res

pects

the

rights

of

those

under

investigation and imposes effective sanctions on violations of the Code of Ethics and Conduct;

(iv)

integrity

policies

in

bidding

procedures;

(v)

mechanis

ms

for

period

ic

analys

is

of

risks,

monitoring

and

eva

luation

of

t

he

Program;

and

(vi)

proc

edures

to

v

erify

the

integrity

and

background of

relev

ant

third parties

or business partners

(including due

dilige

nce du

ring

corporate

transformat

ion

a

nd

acquisitions

proc

esses

t

o

evaluate

p

otential

irregu

larities,

ille

gal

actions or

vulnera

bilities),

including

suppliers,

distributors,

service

providers,

agents

and

intermediaries.

The

Compa

ny

app

lies

the

rec

ommended

prac

tice.

The

Company

has

developed

an

in

tegrity

program base

d on

its risks

, size an

d econom

ic capacit

y. Such

program

includes:

(i) a Co

de

of

Ethics

and

Conduct

that

r

eflects

the

values

and

principles

prom

oted

by

the

Company,

as

mentioned

in

the

ex

planation

o

recomm

ended

practice

No.

22,

a

nd

wh

ich contemplates

the integrity policies in all those situations in

w

hich an employee of the Company interacts with

public off

icials;

(ii)

a r

eporting

channe

l that

has

its own

protocol

and

is

aim

ed at

st

rengthening

the

Comp

any’s

et

hical

infras

tructure,

wh

ich

a

l

ows

fo

r

anonymous

report

ing

and

guara

ntees

the confidential

ity of comm

unications as wel

l as the

protection against

retaliation

as a result of

an

investi

gation

process

bec

ause

the

Com

pany

encourages

all

of

its

employees

to

express

freely

without

fear

o

f

reta

liation;

(iii)

training

for

directors,

managers

and

employees

about

ethics

and

integrity

;

(iv)

t

he

evaluati

on

by

th

e

Divisi

on

of

Corporate

Control,

as

the

internal

body

responsible

for

the

ethics

and

int

egrity

pr

ogram,

of

integrity

risks

and

t

he

mon

itori

ng

of

t

he

evolution

of

t

he

progra

m;

(v

)

the

adherenc

e

by

t

he

suppliers

to

the

Company's

transpare

ncy

principles and practices.

84

24.

The

Board

of D

irectors

ens

ures

the

existence

of

formal

mechan

isms

to

prevent

and

d

eal

with

conflicts

of

i

nterest.

In

the

case

of

re

lated

party

transactions,

the

Board

of

Directors

approves

a policy that provi

des for the rol

e of each corp

orate b

ody and sets

out how to

identify, address

and disclose those transac

tions that are d

etrimental to

the company or to cert

ain investors

.

The

Compa

ny

ap

plies

th

e

r

ecommended

pr

actice.

T

he

Company's

Code

of

Ethics an

d

Conduct

has a section that contains the provisions applicable to conflicts of interest. On the

other hand,

the Company

has a

specific

policy on re

lated party

transactions,

wh

ich complies

with effectiv

e

rules.

ENGAGEMENT OF SHAR

EHOLDERS A

ND STAKEHOL

DERS

Principles

XIX.

A

ll s

hareholders

must receive equitab

le treatment

from the company.

The company

shall

guarantee

equitable

access

to

non

-confidenti

al

and

r

elevant

information

for

deci

sion

making

at

the company's share

holders’ meetings.

XX.

The

c

ompany

sha

ll

promote

th

e

active

engagement

of

a

ll

sharehol

ders

with

ad

equate

information, especial

ly in connection with th

e composition of the

Board.

XXI.

The

com

pany must have a

transparent Dividend D

istribution Policy, in line with

its strategy.

XXII.

The company m

ust take int

o account the interes

ts of its stak

eholders.

Recommended P

ractices

25.

The Company's

website

has

financial

and

non

-f

inancial

information

availa

ble, prov

iding

timely

and equitable

access

to

al

l

the investors. The

webs

ite has

a special

section to answer

inquiries

from investors.

The

Com

pany

applies

t

he

recommended

practice.

Th

e

Comp

any

has

a

websit

e

in

which

it

publishes

financ

ial

and

non-financ

ial

inform

ation,

thu

s

allowing

investors

to

have

material

information in

due

time a

nd form.

The

Compa

ny also

has

an investor

relati

ons area

led

by the

Market

R

elations

Officer

to answer

inquiries. Said

Officer i

s appointed

by the

Board

of

Directors

in conformity with CNV rule

s. Said department

organiz

es conference calls on a quarter

ly basis

ensuring investors worldwide

the possibility of

connec

ting for

free. At

these calls, the

Comp

any

provides

information

about

its

results

,

i

ts

goals

and

a

nswers

questions

and/or

inquiries

made

by inves

tors.

Thes

e conf

erence

calls

are

announc

ed

in

the

daily

bullet

ing

of

the

Buenos

Aires

Stock

Exchange,

in

the

r

eporting

serv

ice

of

t

he

London S

tock

Exc

hange,

an

d

on

the

Company’s

website.

The

Company

m

aintains

communicat

ion

ch

annels

with

the

minority

s

hareholders

through

the

disc

losure

of

r

elevant

information

in

the

stock

exchanges

where

its

s

hares

and

GDSs

are

listed

and

t

hrough

information

disclose

d

in

t

he

Comp

any's

webs

ite.

In

addition,

the

Company's

s

hareholders

and

investors

can

c

ommunicate

wit

h

the

dep

artment

via

email

or

by

telephone, as detaile

d on the website

.

Among

the

non-

financial

informat

ion

disclosed

by

the

Compa

ny

on

its

webs

ite,

the

s

ustainability

reports i

t issues

are

available under

the

ta

b “Sustainability”.

It

should

be no

ted that

t

he

Company is

t

he only

media company

that publishes

a sustainability report.

This tab

also shows

the

money

in

kind

don

ated

in

p

ublic

we

lfare

mess

ages

to

promot

e

social,

c

ivil

and

environmental

c

auses.

T

he

Company

is

a

leader

in t

erms

of

Sustainab

ility:

It

creates

month

ly

supplements

to

promote

sus

tainable

dev

elopment.

It

also

carries

o

ut

a

literacy

program

for

children

and

ad

olescents

aimed

at

pr

omoting

content

creation

skills

and

a

cri

tical

look

at

journalistic content.

For

this

fisc

al

year

2021,

the

C

ompany

presents

its

first

inte

grated

annual

re

port,

i.e.,

the

integration of

its annua

l report

with its

annual sus

tainability report

in acc

ordance

with the

most

advanced internationa

l common practices.

85

26.

The

Board

of

Directors

must

ensure

that

there

is

a

process

in

place

for

the

identification

and

classification of its stakeh

olders and a com

munication

channel for them.

The

C

ompany

applies

the

recommend

ed

practice.

T

he

C

ompany's

Department

of

Inv

estor

Relations

works

together

with

th

e

Depart

ment

of

Sustainability

to

identify

poten

tial

an

d

actua

l

stakeholders

of

the

company.

The

Com

pany

has

d

ifferent

communica

tion

chann

els

that

allow

it

to

have

contac

t

w

ith

k

ey

internal

and

external

audie

nces,

l

isten

to

the

ir

p

oints

of

v

iew

a

nd

disclose

those

of

the

Company;

and

hence

build a

l

ong

-term value

-generating

rel

ationship

for

all the

parties invo

lved. The

Company’s

main st

akeholders

are journa

lism; the c

ommunity a

nd

civil

s

ociety

organizations;

business

chambers

and

ass

ociations;

audie

nces,

customers

and

readers;

associates;

unive

rsiti

es;

companies;

sup

pliers

and

empl

oyees.

Since

2015,

th

e

Company

has

issued

a

sustainability

report

on

an

annual

basis

and

has

been

the

first

media

company

to

do

s

o

in

confo

rmity

with

internat

ional

guidel

ines

including

the

Global

R

eporting

Initiative

s

tandards,

the

UN

Global

Co

mpact

and

the

c

ontribution

to

the

20

30

UN

agenda,

whose

priority

is

to

generate

value

for

the

country,

providing

journ

alistic

content,

a

bond

with

the

audience,

and

economic

in

dependence.

T

his

report

defines

the

follow

ing

st

akeholders:

shareholders, investors,

analysts, companies,

b

usiness chambers,

emp

loyees,

journalists,

audiences, cust

omers, su

ppliers, lead

ers in

the fiel

d of cu

lture, sc

ience and

technology

entrepreneurs,

universities,

media

, news

agencies,

pre

ss as

sociations,

leader

s in

the world

of

communications.

As

explai

ned in

the

prac

tice 2

5, th

e Comp

any

presents

for

the

year

2021

an

integrated report th

at contains the susta

inability report i

n the same document

.

27.

The Board of

Directors

provides

the shareho

lders,

in

advance

of the S

hareholders

’ Meeting,

a

“provisional

informat

ion

pack

age”

that

allows

shareh

olders

-throu

gh

a

formal

c

ommunication

channel

-

to

make

non-

binding

c

omments

an

d

s

hare

opin

ions

that

dissent

from

the

recommendations made by the

Board of

Director

s. When the

Board sends the

final information

package, it shall

expressly state its answers to

the comments received, as deemed ne

cess

ary.

The

Co

mpany

applies

the

rec

ommended

practice.

Th

e

Company

m

akes

available

at

its

main

office

to

its

s

harehol

ders

inf

ormat

ion

pack

ages

before

each

Shareholders’

Me

eting.

Notwithstanding

th

e

forego

ing,

the

pack

ages

are

not

provisional.

In

addition,

the

Company

uploads

to

CNV’s

Financi

al

Information

Highw

ay

all

the

information

re

quests

made

the

Company's

shareh

olders

befor

e

Shareholders

’

Meetings

are

held,

r

egarding

th

e

items

of

the

agendas

to

be

cons

idered

at

those

mee

tings,

together

with

th

e

answers

prov

ided

by

the

Company

to

each

o

f

the

requests,

so

t

hat

all

the

inv

estors

have

the

sam

e

information

t

hus

ensuring

equita

ble

access

to

the

information

provided.

S

uch

informat

ion

is

also

prov

ided

in

English for the foreig

n investors

through the reporting

service of the Lo

ndon Stock

Exchange.

28.

The

Compa

ny's bylaws

provide that

the shareholders can

receive the i

nforma

tion packages

for

Shareholders’

Meetings

t

hrough

virtual

media

and

participate

at

the

meetings

through

electronic

co

mmunication

med

ia

that

a

llow

the

s

imultaneous

transmissio

n

of

sound,

imag

es

and words, ensurin

g the principle of eq

uitable treatme

nt of the participants

.

The

Company

do

es

not

apply

t

he

recommend

ed

practice.

The

C

ompany's

By

laws

do

n

ot

provide

for

the hold

ing

of

remote

Shareholders’

Meeti

ngs.

Notwithsta

nding

the

fo

regoing,

and

in

v

iew

of

the

health

situatio

n

generated

by

the

CO

VID-

19

pandemic

a

nd

the

iso

lation

an

d

social

distancing

meas

ures

imple

mented

by

t

he

National

Executive

Branch,

the

Com

pany

has

he

ld

since fiscal year 202

0 all its Shareho

lders’ Meetings re

motely as author

ized by Res

olution No.

830

issued

by

the

Argentine

Securities

Comm

ission.

In

addi

tion,

the

Comp

any

took

notice

of

the

interpretative

criter

ion

No.

80

of

th

e

CNV,

whereby,

in

view

of

th

e

extension

by

th

e

Executive

Branch o

f the

term

of

the

health

emergenc

y

until D

ecember

31,

2022,

sa

id

agency

decided

to

maintain the

effectiveness of

Resolut

ion No.

83

0/2020 and

to de

lega

te

on the

B

oard of

Directors

the

power

to

evaluate

t

he

circ

umstances

and

opt

to

hold

Shareholders’

Meetings

in

person

or

r

emotely

guaranteeing

the

due

compliance

with

the

corresponding

legal a

nd

hea

lth

requirements. The Co

mpany

provides through virtual media, such as the Financ

ial Information

86

Highway and

its own website,

the information to be

cons

idered at

the Shareholders’ Meeting in

order to

ensure equitable access to

information by

all

the

shareholders. In

addition, the

Company

sends,

thr

ough

the

Dep

ositary,

to

the

shareholders

that

do

not

r

eside

in

Arg

entina

the

items

of

the

agend

a

s

o

that

they

can

grant

a

po

wer

of

attorney

to

the

Depos

itary,

who

attends

the

Sharehold

ers’

Meetings

in

its

name

and

representation,

v

oting

a

s

i

nstructed

by

them.

29.

The

Divid

end

D

istribution

Policy

is

aligned

with

the

str

ategy

and

c

learly

s

ets

out

the

c

riteria,

frequency and cond

itions under which

dividends will b

e distributed.

The

Company

does

not

apply

the

r

ecommended

practice.

The

Company’s

Board

of

Directors

believes that given the nature of a holding company and depending basically on the liquidity of

its

revenues

that

derive

fr

om

the

compan

ies

in

which

it

holds

equity

interests,

it

is

not

convenien

t

to

establish a

dividend distribution

policy

.

Notwithsta

nding the

fore

going, the

Board

of

Directors

provides

gro

unds

for

its

proposal

for

the

distribution

of

dividen

ds

and

the

reasons

for

which

it

deems reasonable u

nder a prude

nt administration of

the Company.

17.

EXHIBIT II

–

GRI

CONTENT INDEX

AND

COM

MUNICATION ON PR

OGRESS

2021

International Guidelines

Grupo

Clarín

uses

a

set

of

international

sus

tainabili

ty

guidelines

w

ith

the

aim

of

standardizi

ng

its

performance,

reporting

on

its

performance

in

a

transparent

and

rigorous

manner,

and

showi

ng

its

contribution to sustainab

le development.

➢

Since

2004,

it

has

remained

committed

to

the

United

Nations

Global

Compact

and

has

reported

on

the

progres

s

made

concernin

g

th

e

fulfillmen

t

of 10

g

uiding

princ

iples:

human

rights,

labor

rights,

the environment, and

anti-c

orruption.

➢

The

Comp

any

rep

orts

on

its

contributio

n

to

the

2030

Agenda

for

the

Sustain

able

Deve

lopment

Goals (SDG).

➢

It applies the Global Re

porting Initiative (GRI)

Standards

under the option Core

.

➢

It

uses

“The

Int

ernational

<

IR>

Framework

”

develop

e

d

by

the

Internat

ional

Integr

ated

Reportin

g

Council (IIRC).

➢

The

Company

a

dopts

th

e

principles

and

gu

idelines

established

by

the

I

SO

26000:20

10

International Social R

esponsibility Standard

in the man

agement of its bus

iness.

Materiality Assessm

ent

Since 2015,

Grupo Clarín has

performed a

mater

iality assessment

in order to

identify the

most relevant

and

significant issues

regarding

the

b

usiness

strategy

and

stakeholders

’

needs.

The

most

recent

rev

iew

of

this process was

conduct

ed

in 2018. Below is

the Materiality Matrix

that shows

th

e level

of relevance

of the priority susta

inability issues for the com

pany.

87

GRI Content Index

This Report was prepar

ed in acc

ordance with GRI

Standards: Core o

ption.

Below is

the GRI

Cont

ent I

ndex that

meets the

requirements

of t

hose

Standards.

In addition,

the t

able

includes contents required for the "c

omprehensive” option. In addit

ion, it shows the fulfillment of the 10

principles

of

the

U

nited

Nations

Globa

l

Comp

act

a

nd

the

c

ompany's

contr

ibution

to

t

he

Susta

inable

Development Goals a

nd the goals iden

tified as releva

nt.

References:

➢

RP:

Informa

tion

reported

in

Exhibit

I

of

the

2021

Integrated

Annual

Report

w

hich

includes

the

Report

on the

Code of

Corporate Governance of

Grupo Clarín S.A

., including the responses to

th

e

Recommended Practices (

RP). The numbers indicate the Best Practice where inf

ormation related

to the corresponding GRI C

ontent can be foun

d.

➢

Italic

:

Indicators

that

address

the

Advanced

COP

criteria

of

the

10

princ

iples

establishe

d

by

the

United Nations Globa

l Compact.

➢

All the notes included in

the table are disclos

ed at the end of the tab

le.

88

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

GENERAL DISCLOSUR

ES

GRI 102

:

General

Disclosu

res

2016

102

-1 Name of

the

Organizat

ion

2

-

102

-2 Activiti

es,

brands, p

roducts

and services

4.2; Note 1

-

102

-3 Location

of

the Headq

uarters

Note 2

-

102

-4 Location

of

the Operat

ions

4.1

-

102

-5 f Ownershi

p

and legal

form

2

-

102

-6 Markets

served

4.1; 4.2

-

102

-7 Size of t

he

Organizat

ion

4.2; 4.2; 5; 10.1

-

102

-8 Informa

tion

on emplo

yees and

other work

ers

10.1; Note 3

X

8.5

102

-9 Supply ch

ain

9.2

-

102

-10 Sign

ificant

changes t

o the

organi

zation and

its supply ch

ain

3.3.; 4.2.2. (ARTEAR)

-

102

-11

Precautio

nary

principle o

r

approach

7.1; 7.2; 12.2

-

102

-12 External

initiativ

es

7.2; 7.3; 8.1; 16

-

102

-13

Membership

of

associati

ons

7.4; 8.1; 11.6

-

102

-14 Stat

ement

from senio

r

decision-mak

er

1

-

102

-15 Key

impacts, risk

s, and

opport

unities

3; 6.2; 7.1; 7.2; 7.3; 8; 1

2.1; 13

-

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

102

-16 Values,

principl

es,

standa

rds, and

norms of b

ehavior

6; 8.1; RP22

-

102

-17

Mechanisms

for

advice an

d

concerns ab

out

ethics

6; 8.1; RP23

-

102

-18

Governance

structure

6; 8.1

-

102

-21 Consul

ting

stakehold

ers on

economic,

environment

al,

and soci

al topics

7.2; 7.4; 8.4; 8.7; 9.1;

9.2; 10.3; Exhibit

II; RP26

16.7

102

-23 Chair o

f the

highest

governan

ce body

Note 4

16.6

102

-26 Role o

f

highest

governan

ce body

in setting

purpose,

values, and

strategy

RP1

-

102

-27 Collecti

ve

knowled

ge of

highest

governan

ce body

Note 5, RP8

-

102

-29 Identi

fying

and man

aging

economic,

environment

al,

and soci

al impacts

7.1; 7.2; Exhibit

II; RP2

16.7

102

-30

Effectiveness o

f

risk mana

gement

processes

RP17

-

89

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

102

-32 Highest

governan

ce body’s

role in

sustainab

ility

reportin

g

The Board ap

proves

The Integrated

Annual Report

-

102

-33

Communicat

ing

critical co

ncerns

10.3, RP26; RP27

-

102

-36 Process f

or

determini

ng

remunerati

on

RP15; RP16

-

102

-40 List o

f

stakehold

er groups

RP26

-

102

-41 Collecti

ve

bargaini

ng

agreements

10.3

X

-

102

-42 Identi

fying

and select

ing

stakehold

ers

RP26

-

102

-43 Approach

to stak

eholder

engagemen

t

7.4; 8.1; 8.4; 8.7;

9; 10.3; Exhibit

II.

-

102

-44 Key topi

cs

and con

cerns

raised

9; 10.3; Exhibit

II.

-

102

-45 Entiti

es

included

in the

consoli

dated

financial

statements

2

-

102

-46 Defini

ng

report cont

ent and

topic bo

undaries

Note 6

-

102

-47 List o

f

material i

ssues

Exhibit II, Not

e 6

-

102

-48

Restate

ment of

informati

on

Note 7

-

102

-49 Changes i

n

reporting

2

-

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

102

-50 Repor

ting

period

Note 8

-

102

-51 Date o

f last

report

Note 9

-

102

-52 Repor

ting

cycle

Note 8

-

102

-53 Contact

point for q

uestions

regarding the

report

Note 10

-

102

-54 Claims of

reporting in

accordanc

e with

the GRI St

andards

Exhibit II

-

102

-55 GRI

Content Inde

x

Exhibit II

102

-56 External

Assurance

The External Ass

urance Report

is availab

le

at www.grupoclar

in.com

-

MATERIAL ISSUE

S

Economic Perfor

mance

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

5; 6; 7.2

-

103

-3 Review of

managemen

t

approa

ch

5; 7.2

-

GRI 201:

Economic

Performance

2016

201

-1 Direct

economic v

alue

generated an

d

distribute

d

5; 11.1; 11.2

9.1; 9.4

201

-4 Financial

Assistance

receive

d from the

government

6; 7.3; Note 11

X

-

90

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

Indirect Econo

mic Impacts

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

7.1; Exhibit II; Not

e 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

7.1; 7.2; 9.2; 11.1; 11.

2; 11.5

-

103

-3 Review of

managemen

t

approa

ch

5; 7.2; 11.1; 11.2; 11.

5

-

GRI 203:

Indirect

economic

impacts 2016

203

-

1

Infrastructur

e

investment

s and

service

s supported

11.2

X

9.1; 9.4

203

-2 Signific

ant

indirect e

conomic

impacts

7.1; 9.2; 11

1.4; 8.5

Anti-

corruption

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

6; 7.1; 7.2; 7.3; 8.1; 9.

2; 16.1

-

103

-3 Review of

managemen

t

approa

ch

6; 7.1; 7.2; 7.3; 8.1; 9.

2; 16.1

-

GRI 205: Anti-

corruption

205

-3 Confi

rmed

incident

s of

corruptio

n and

actions

taken

Note 12

16.5

Materials

103

-1 Explan

ation

of the materi

al

7.1; 12.3; Exhibit

II; Note 6

-

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

GRI 103:

Management

Approach 2016

topic a

nd its

boundary

103

-2 The

managemen

t

approa

ch and its

component

s

7.1; 7.2; 12.2; 12.3

-

103

-3 Review of

managemen

t

approa

ch

7.1; 7.2; 12.3

-

GRI 301:

Material

s 2016

301

-1 Material

s

used by weig

ht or

volume

12.3

X

8.4; 12.2

301

-2 Recycled

input mat

erials

Note 13

8.4; 12.2; 12.5

Energy

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

7.1; 12.4; Exhibit

II; Note 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

7.1; 7.2; 12.2; 12.4

-

103

-3 Review of

managemen

t

approa

ch

7.2; 12.4

-

GRI 302:

Energy 2016

302

-1 Energy

consumpti

on

within

the

organi

zation

12.4

X

7.3; 8.4; 12.2;

13.1

Water and Effluent

s

GRI 103:

Management

Approach 2016

103

-

1

Explan

ation

of the materi

al

topic a

nd its

boundary

7.1; 12.6; Exhibit

II; Note 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

7.1; 7.2; 12.2; 12.6

-

91

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

103

-3 Review of

managemen

t

approa

ch

7.2; 12.6

-

GRI 303: Water

and Effluent

s

2018

303

-

2

Management of

water disc

harge-

related impact

s

12.6; Note 14

303

-4 Water

discharge

Note 14

X

12.4

Emissions

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

7.1; 12.4; Exhibit

II; Note 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

7.1; 7.2; 12.2; 12.4

-

103

-3 Review of

managemen

t

approa

ch

7.2; 12.4

-

GRI 305:

Emissions 2016

305

-1 Direct GHG

emissions (

Scope

1)

12.4

12.4; 13.1;

15.2

305

-2 Energy

indirect G

HG

emissions (

Scope

2)

12.4

X

12.4; 13.1;

15.2

305

-3 Other

indirect G

HG

emissions (

Scope

3)

12.4

12.4; 13.1;

15.2

305

-5 Reduction

of

GHG emission

s

12.4

13.1; 15.2

305

-6 Emission

s of

ozone-depleti

ng

substan

ces (ODS)

Note 15

12.4

Waste

103

-1 Explan

ation

of the materi

al

7.1; 12.5; Exhibit

II; Note 6

-

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

GRI 103:

Management

Approach 2016

topic a

nd its

boundary

103

-2 The

managemen

t

approa

ch and its

component

s

7.1; 7.2; 12.2; 12.5

-

103

-3 Review of

managemen

t

approa

ch

7.2; 12.5

-

GRI 306:

Waste

202

0

306

-1 Waste

generatio

n and

significan

t waste-

related impact

s

12.5

12.4

306

-

2

Management of

significan

t waste-

related impact

s

12.5

306

-3 Waste

generated

Note 16

X

12.4

306

-4 Waste

diverte

d from

disposal

Note 16

X

12.4

306

-5 Waste

direct

ed to

disposal

Note 16

12.4

Employment

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 10.1;10.2;10.3

; 10.4

-

103

-3 Review of

managemen

t

approa

ch

7.2; 10.3

-

401

-1 New

employee hi

res

Note 17

X

5.1; 8.5; 8.6

92

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

GRI 401:

Employment

2016

and empl

oyee

turnover

401

-2 Benefits

provided t

o full-

time emplo

yees

that are n

ot

provided t

o

temporary o

r part-

time emplo

yees

Note 18

X

8.5

401

-3 Parenta

l

leave

Note 19

X

5.1; 8.5

Training and Educat

ion

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 10.5

-

103

-3 Review of

managemen

t

approa

ch

7.2

-

GRI 404:

Training and

educatio

n

2016

404

-1 Average

hours of

training

per year per

employee

Note 20

X

5.1

404

-2 Programs

for upg

rading

employee ski

lls and

transitio

n

assistan

ce

programs

10..5

8.5

Diversity and Equ

al Opportunities,

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

-

103

-2 The

managemen

t

7.2; 8.6; 10.2

-

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

approa

ch and its

component

s

103

-3 Review of

managemen

t

approa

ch

7.2; 8.6; 10.2

-

GRI 405:

Diversity a

nd

equal

opportun

ities

2016

405

-1 Diversit

y of

governan

ce bodies

and empl

oyees

Note 21

X

5.1; 5.5; 8.5

Customer Privacy

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

-

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.1; 9.1

-

103

-3 Review of

managemen

t

approa

ch

7.2; Note 22

-

GRI 418:

Customer

privacy 2016

418

-

1

Substantiat

ed

complaints

concerni

ng

breaches

of

customer p

rivacy

and

losses of

customer d

ata

Note 22

16.10

SPECIFIC MATERI

AL TOPICS

Accountabili

ty: Publication of Annua

l Sustainability Report

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 7.3

93

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

103

-3 Review of

managemen

t

approa

ch

7.2; 7.3; Exhibit

II.

Accountabi

lity:

Publicati

on of

Annual

Sustainabil

ity

Report

Number of

stakehol

ders who

responde

d to the

materiali

ty inquiry

Exhibit II; Not

e 23

Responsible Cr

eation of Contents

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.1-8.7

103

-3 Review of

managemen

t

approa

ch

7.2; 8.1-8.7

Responsi

ble

Creation

of

Contents

Principle

s, values,

internal

codes and

communicatio

n

channels t

o ensure

the repr

esentation

of human right

s in

the cont

ents.

8.1; 8.7

Initiati

ves to

ensure t

he

represe

ntation of

human rights in

the cont

ents.

8.1;8.3; 8.5; 8.6; 8.7

Actions t

o ensure

privacy p

rotection.

8.1; 8.8

Responsible Disse

mination of Contents

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.1; 8.2; 8.4; 8.7;

8.8

103

-3 Review of

managemen

t

approa

ch

7.2

Responsi

ble

Disseminati

on

of Content

s

Actions t

aken to

improve

performanc

e in

relatio

n to content

disseminati

on

issues (ac

cessibility

and prote

ction of

vulnerabl

e

audiences

and

informed de

cision

making) and

results

obtained.

8.2; 8.8

Editorial Indep

endence

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.1

103

-3 Review of

managemen

t

approa

ch

7.2

Freedom of Expressi

on

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.1

94

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

103

-3 Review of

managemen

t

approa

ch

7.2

Freedom of

Expression

Adherence

to

agencies t

hat

ensure f

reedom of

expressio

n and

disseminati

on of

activitie

s of these

instit

utions

8.1

Promotion of Pu

blic Debate and Civi

c Involvement

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; No

te 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.7

103

-3 Review of

managemen

t

approa

ch

7.2

Promotion o

f

Public Deba

te

and Civic

Involvement

Initiati

ves for the

Promotion o

f

Public Deba

te and

Civic Invol

vement.

8.7

Interaction with th

e Audience

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.4

103

-3 Review of

managemen

t

approa

ch

7.2

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

Interact

ion

with the

Audience

Methods t

o

interact wi

th

audiences

and

results.

8.4

Promotion of respon

sible advertisin

g in the value chain

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.1

103

-3 Review of

managemen

t

approa

ch

7.2

Promotion o

f

responsi

ble

adverti

sing in

the value

chain

Initiati

ves for the

promotion

of

responsi

ble

adverti

sing

8.1

Contribution to

Education and Culture

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 11.3-11.5

103

-3 Review of

managemen

t

approa

ch

7.2

Contribut

ion

to Educati

on

and Culture

Disseminati

on of

local cult

ure

8.4; 11.5

Media Literacy

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

95

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 11.3

103

-3 Review of

managemen

t

approa

ch

7.2

Media Lit

eracy

Measures t

aken to

empower

audiences

through

the deve

lopment

of skills

in

educatio

n about

the media an

d

results

obtained.

11.3.

Raising Awarene

ss on Environmenta

l Protection

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 12.1

103

-

3

Review of

managemen

t

approa

ch

7.2

Raising

Awareness on

Environmental

Protecti

on

Initiati

ves for the

promotion

of

environment

al

protectio

n

12.1

Gender Diversity

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

7.2; 8.6; 10.2

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

103

-3 Review of

managemen

t

approa

ch

7.2; Note 21

People with Di

sabilities

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; Not

e 6

103

-2 The

managemen

t

approa

ch and its

component

s

8.6

103

-3 Review of

managemen

t

approa

ch

7.2; Note 21

Age Diversity

GRI 103:

Management

Approach 2016

103

-1 Explan

ation

of the materi

al

topic a

nd its

boundary

Exhibit II; No

te 6

103

-2 The

managemen

t

approa

ch and its

component

s

Note 21

103

-3 Review of

managemen

t

approa

ch

7.2; Note 21

Ideological Diver

sity

GRI 103:

Management

Approach 2016

103

-

1

Explanati

on

of the mat

erial

topic and

its

boundary

Exhibit II; No

te 6

103

-2 The

management

approach an

d its

components

7.2; 8.1; 8.4; 8.5; 8.6;

8.7

103

-3 Review of

management

approach

7.2

96

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

Ideological

Diversity

Topics of s

ocial

interest t

hat are

addressed

from

the dive

rsity of

7.2; 8.1; 8.4; 8.5; 8.6;

8.7

GRI Standard

Contents

Section / Respons

e

External

Assurance

SDG

viewpoint

s and

opinions

.

NOTA 1

Grupo Clarín does not sell or market prohibited products. However, since the

Company broadcasts content through different audiovisual media, our stakeholders may challenge

them,

which

is

ch

anneled

through

agencies

created

for

this

pu

rpose:

The

Office

of

the

Ombudsman

of

Audiovisual

Communication

Services

and

the

National

Institute

against

Discrimination,

Xenophobia

and

Racism

(INADI).

The

section

“Responsible

Creation

and

Distribution of

C

ontents”

of

the Integra

ted

Annual

Report

details

the

mechanisms

that

the group has in place to monitor the commitments undertaken to stakeholders in this regard.

NOTE 2

Buenos Aires, Argentina

NOTA 3

Number of Employees in 2021

Workforce broken down by type of contract

Women

Men

Total

Permanent employme

nt contract

(1)

1,

287

2,

940

4,227

Fixed-term contrac

t

(2)

103

189

292

Total

1,390

3,129

4,519

Employees by Region

AMBA and the Prov of Bs As.

1,209

2,745

3,954

Mendoza

55

97

152

Córdoba

98

251

349

Santiago del Estero

1

3

4

Tucumán

2

3

5

Chubut

-

1

Santa Fe

14

17

31

Río Negro

-

Chaco

-

Corrientes

-

Entre Ríos

-

Formosa

-

97

La Pampa

-

1

Misiones

-

1

Neuquén

-

Salta

-

1

San Juan

9

5

14

San Luis

2

4

6

Total

1,390

3,129

4,519

Number of Employees - by Employment Contract and Region

Employees by Type of Contract and Region

Permanent employment contract

Fixed-term employment contract

Total

AMBA and the Prov of Bs As.

3,699

255

3,954

Mendoza

135

17

152

Córdoba

331

18

349

Santiago del Estero

4

-

4

Tucumán

5

-

5

Chubut

1

-

1

Santa Fe

31

-

31

Río Negro

-

Chaco

-

Corrientes

-

Entre Ríos

-

Formosa

-

La Pampa

1

-

1

Misiones

1

-

1

Neuquén

-

Salta

1

-

1

San Juan

14

-

14

San Luis

4

2

6

Total

4,227

292

4,519

Business units sur

veyed: AGEA; C

úspide; Autospo

rts; Artear Canal

13; Canal 12; P

ol-k

a; CIMECO; C

MI; Gestión Com

partida; La Voz

del Interior; Los A

ndes; Radio

Mitre; TyC Spo

rts; and Grupo Cl

arín.

(1)

An emplo

yment contract wi

th a full or p

art-time employe

e, for an in

definite period

of time.

(2)

An emplo

yment contract t

hat ends after

a pre-establis

hed period of time

, or when a work

or service is com

pleted withi

n a pre

-established

term.

NOTE 4

Jorge Rendo, the Chair of the Board of Directors, also serves as Director of External Relations in the Corporate area.

NOTE 5

Even

though

the

Company

has

n

ot

i

mplemented

an

annual

formal

training

program,

the

me

mbers

o

f

the

Board

of

Directo

rs,

in

a

ddi

tion

to

their

professional

an

d

personal

qualifications a

nd ex

perience, regularly

receive

updates,

through the

coordination

carried

out

by

the Division

of

Corporate Affa

irs,

information, training,

concerning

the

industry,

98

business or regulations, f

or the adequate fulfillment of

their functions and re

sponsibilities, training given by

highly quali

fied

officers with experience in th

e Company's businesses,

renowned market professionals, industry referents or specialized consultancy firms.

NOTE 6

Coverage of Material Issues and Impact on Stakeholders

Category

Material Issues

Stakeholders

Strategy,

Economy and

Transparency

Investors

and

analysts;

advertisers;

journalist

ic e

ntities;

unions;

government;

media

observatorie

s;

community;

civil

society

organizations; bu

siness chambers

; international or supran

ational agencies or enti

ties.

Ethics and Integrit

y

Employees;

inv

estor

s a

nd

analysts;

advertisers;

journalistic

entities;

unions;

government;

media

observa

tories;

community;

civil society organ

izations; internat

ional or supranational ag

encies or entitie

s.

Accountability:

Publication of Annual Su

stainability

Report

Investors

and

analysts;

advertisers;

journalist

ic e

ntities;

unions;

government;

media

observatorie

s;

community;

civil

society

organizations; bu

siness chambers

; international or supran

ational agencies or enti

ties.

Responsible

Creation and

Dissemination

of Contents

Responsible Cr

eation of Contents

Audiences/customer

s

/public;

journalistic

entities;

government;

media

observatorie

s;

c

ommu

nity;

civil

society

organizations; inter

national or supr

anational agencies or

entities.

Responsible Dissemina

tion of Contents

Audiences/customer

s

/public;

journalistic

entities;

government;

media

observatorie

s;

c

ommu

nity;

civil

society

organizations; inter

national or supr

anational agencies or

entities.

Labor indepe

ndence

Audiences/customer

s

/public;

journalistic

entities;

government;

media

observatorie

s;

c

ommu

nity;

civil

society

organizations; peer

companies/co

mpetitors; international or

supranational agenc

ies or entities.

Freedom of Expr

ession

Audiences/customer

s

/public;

journalistic entities; government; universities; media

observatories; commun

ity;

civil s

ociety

organizations; pol

itical organization

s; international or supr

anational agencies or

entities.

Promotion of Jour

nalistic Excellence

Investors and ana

lysts; employees, communi

ty; journalistic ent

ities.

Promotion of Publi

c Debate and Ci

vic Involvement

Audiences/customer

s

/public;

journalistic

entities;

government;

media

observatorie

s;

c

ommu

nity;

civil

society

organizations; inter

national or supr

anational agencies or entities.

Interaction with

the Audience

Audiences/customer

s

/public;

journalistic

entities;

government;

media

observatorie

s;

c

ommu

nity;

civil

society

organizations; inter

national or supr

anational agencies or

entities.

Value Chain

Customer Privac

y

Audiences/customer

s

/public; gove

rnment

Promotion of re

sponsible adverti

sing in the value chain

Audiences/customer

s

/public; supp

liers; government; media ob

servatories; ci

vil society organiza

tions.

Social

Performance

Generation of Emp

loyment

Employees; union

s; government; c

ommunity.

Dissemination of

public service ad

s campaigns

Audiences / cus

tomers / public; go

vernment, civil so

ciety organizations;

community.

Training and Pro

fessional Develop

ment for Employees

Investors and ana

lysts; employees

; unions.

Contribution to Edu

cation and Cultu

re

Audiences/customer

s

/public; government; civil

society organizations; media

observatorie

s;

international or

supranational

agencies or enti

ties; community.

Media Literacy

Au

dience

s/customers/public; gove

rnment; civil socie

ty organizations; media o

bservatories;

community.

Environmental

Performance

Responsible mana

gement of mate

rials

Investors and ana

lysts; governme

nt; community; civil so

ciety organization

s.

Energy Efficienc

y

Investors and ana

lysts; governme

nt; community; civil so

ciety organization

s.

Raising awarene

ss about environmen

tal protection

Government; emp

loyees; commun

ity; civil society orga

nizations.

Gender Diversi

ty

Audiences/customer

s

/public;

government;

employees;

media

observatories;

international

or

s

upranat

ional

agencies

or

entities; communi

ty; civil society or

ganizations.

99

Commitment

to Diversity

People with Disab

ilities

Audiences/customer

s

/public;

government;

employees;

media

observatories;

international

or

supranational

agencies

or

entities; communi

ty; civil society or

ganizations.

Age Diversity

Audiences/customer

s

/public;

government;

employees;

media

observatories;

international

or

s

upranat

ional

agencies

or

entities; communi

ty; civil society or

ganizations.

Ideological Diver

sity

Audiences/customer

s

/public;

government;

employees;

media

observatories;

international

or

s

upranat

ional

agencies

or

entities; communi

ty; civil society or

ganizations.

NOTE 7

In the e

vent of a re

statement of the

information, it i

s expressly state

d in a

footnote to

the table or indicator presented.

NOTA 8

The Integrated Annual Report covers t

he period from January 1, 2021 to December

31, 2021. It is published on an annual basis.

NOTE 9

2020

NOTE 10

We receive inquiries and suggestions at

rse@grupoclarin.com

NOTE 11

FINANCIAL A

SSISTANCE RECE

IVED

FROM THE GOV

ERNMENT (in A

rgentine Pesos)

Tax incentives and

reliefs related to

companies located

in technological

and audiovisual di

stricts

(1)

.

$ 118,964,144

Other Tax Incent

ives/Reliefs

(2)

$ 477,008,268

(1)

Business units sur

veyed: Gestió

n Compartida an

d TyC Sports.

(2)

Business units sur

veyed: AGEA Tacu

arí, Canal 12 an

d Pol-Ka.

NOTE 12

No cases of corruption were recorded in 2021.

NOTE 13

Recycled Material

Total (tons)

2021

2020

Use

of

pape

r

from

sustainable

sources (FSC certified)

0.70

4.75

Business units

surveyed in 2020:

AGEA Tacuarí and T

yC Sports

Business units

surveyed in 2021:

Canal 12 Córdoba

. TyC Sports and AG

EA Tacuarí did not re

cycle FSC sheets.

NOTE 14

Discharges into Fresh Water

Total (in megaliters)

Annual volume discharged in areas without water stress

(1)

35.00

Annual volume discharged in water stress

areas

(2)

3.65

(1)

35 megaliters were discharge

d in third-party water. Business units

surveyed: AGEA Zepita,

La Voz del Interior and Los Andes.

For AGEA

Zepita,

the

amou

nt was

esti

mated b

ased

on wat

er delive

red

by the

supplier

minus

water

evapor

ated i

n th

e cooling

tower and that a

pplied in the diluti

on of the source

solution used

in the producti

on process.

(2)

Los

And

es:

2.1

0

megalite

rs

cor

respond

t

o

irrig

ation

(

surface

wa

ter)

and

1.55

megaliters

correspo

nd

to

third

-part

y

wat

er.

Discharge value estim

ated at 100% ac

cording to the

amount of refills ca

rried out in the irrigati

on pool for surface wa

ter and we

considered

the

huma

n

consumption

(m

ain

office),

water

consumpti

on

and

9%

water

ab

sorption

by

paper

(pri

nting

plant)

for

third party water. It is

classified as

a water stress

area acco

rding to Aqueduc

t, World Resou

rces Institute.

NOTA 15

The consumption of ozone-depleting substances in air-conditioning gases was identified in Diario Clarín.

Ozone-Depleting Substances (ODS)

Total (metric tons CFC-11 equivalent)

2021

2020

HCFC22

0.0045

0.0015

The increase was

due to the need

for equipment repairs due

to obsolescence.

100

NOTE 16

Type of Waste

Composition

Disposal / Treatment

Method

Removal Method

Weight (tn)

2020

2021

Hazardous Waste *

Y8 Liquid

Thermal Destruction

Contractor Procedure

0.83

4.05

(1)

Y48/Y8C Solid

0.07

(2)

Y31/Y34 Lead Acid Batteries

2.13

(3)

Y29 Fluorescent Tubes/Lighting

Equipment

0.72

(4)

Y1

Autoclave

Contractor Procedure

0.023

0.04

(5)

Y12 Liquid

On

-land incineration

Contractor Procedure

62.52

28.14

(6)

Y48/Y12

7.76

(7)

Y18/Y16

13.88

(8)

Y12 Solid

-

34.19

(9)

Y16

-

0.80

(10)

Y48

On

-Site Storage

Contractor Procedure

1.29

1.20

(11)

Electronic / cells and batteries

0.14

(12)

Toners and cartridges

0.02

(13)

Recycled

Recycling

-

0.10

2.35

(14)

Total Hazardous Waste

64.77

95.49

Non-Hazardous Waste *

Urban Solid Waste

Sanitary landfill

Contractor Procedure

126.86

715.64

(15)

Recycled

Recycling and reuse

Contractor Procedure

280.88

258.31

(16)

Total Non-Hazardous Waste

407.73

973.95

*Not imported or e

xported

(1) Business Units

: AGEA and Los An

des. For L

os Andes, an estim

ate was made

based on the

oils us

ed for the ope

ration of the m

achinery. Incl

udes estima

tes by specific wei

ght of oils.

(2)

Business Unit: AGEA T

acuarí.

(3)

Business Unit: AGEA.

(4)

Business Unit: AGEA T

acuarí.

(5)

Business Units: AGEA Zepi

ta and Artear Ca

nal 13.

(6)

Business Unit: AGEA Z

epita.

(7)

Business Unit: AGEA Z

epita.

(8)

Business Unit: AGEA Z

epita.

(9)

Business Unit: AGEA Z

epita.

(10)

Business Unit: AGEA Z

epita.

(11)

Business Unit: Los And

es. Estimated val

ue at 100% base

d on the rags us

ed for the op

eration of

the machine

ry. Includes waste

classified int

ernally as rags.

(12)

Business Unit: TyC Spo

rts. Includes

internally categori

zed waste as c

ells and batteries. Es

timated value

considering the

numb

er of cells

and batteries co

nsumed and thei

r unit weight

according

to scale weighin

g.

(13)

Business Unit: TyC Spo

rts. Estimated val

ue based on wei

ght of unused m

aterial.

(14)

Business Unit: Gestión Com

partida. Inclu

des waste that is in

ternally categ

orized as electro

nic.

(15) Busine

ss Units:

AGEA;

Artear

Can

al 13;

Pol

-

ka

; and L

a Voz

del

Interior.

It

includes wa

ste classi

fied int

ernally

as

wet w

aste, cons

truction

and p

roduction

waste,

similar t

o resi

dential an

d or

ganic waste.

In

the c

ase of

Artear

Canal 13: the tot

al wet waste con

templates the n

umber of operatin

g days of c

ollecti

on, and the eq

uivalence 1 kg =

1 liter.

101

(16)

Busin

ess

Unit

s:

A

GEA;

Arte

ar

Ca

nal

13;

Pol-ka;

Canal

12;

Gesti

ón

Com

partida;

La

Voz

del

Interior;

and

TyC

Spor

ts.

Includes

dry

waste,

plastic

c

aps,

pa

per,

ca

rdboard,

and

aluminum

sh

eets.

For A

rtear

Canal

13

a

unit

weight per bag of 3

00 kg was consi

dered; an

d in the case of C

anal 12 Cord

oba the values we

re estimated.

NOTE 17

New Hires and Employee Turnover 2021

Additions

Retirements

Rate of hires

(1)

Employee Turnover Rate

(2)

Total

736

776

16.3%

17.2%

Breakdown by age

Up to 30

363

241

51.9%

34.5%

Between 31 and 50

332

432

12.6%

16.4%

Over 51 years

41

100

3.5%

8.5%

Breakdown by Gender

Female employees

371

326

26.7%

23.5%

Male employees

365

450

11.7%

14.4%

Breakdown by Region

AMBA and the Prov of Bs

As.

679

709

17.2%

17.9%

Mendoza

20

25

13.2%

16.4%

Córdoba

33

37

9.5%

10.6%

Santiago del Estero

1

-

25.0%

-

Tucumán

1

2

20.0%

40.0%

Chubut

-

Santa Fe

1

3.2%

Río Negro

-

1

-

Chaco

-

Corrientes

-

Entre Ríos

-

Formosa

-

La Pampa

-

Misiones

-

Neuquén

-

Salta

-

1

-

100%

San Juan

-

San Luis

1

-

16.7%

-

Business units sur

veyed: AGEA; C

úspide; Autospo

rts; Artear Canal

13; Canal 12; P

ol-k

a; CIMECO; C

MI; Gestión Com

partida; La Voz

del Interior; Los A

ndes; Radio

Mitre; TyC Spo

rts; and Grupo Cl

arín

(1) Calculated as t

he total new

hires divided by the

total payroll as o

f Decembe

r 31, 2021 for

each category.

(2) Calculated as t

he total departur

es divided by th

e total payroll as

of December 31,

2021 for each cat

egory.

102

NOTE 18

Exclusive benefits for full-

ti

me employees:

•

Flexible work / home office

(1) (2) (3) (4)

•

Friday flex

(4)

•

Birthday

(4)

•

Vacation days in addition to those provided by law

(1) (4)

•

Personal days

(4)

•

Reimbursement of dayc

are fees

(1) (4)

•

Benefits for the family of o

ur employees

(health care

)

(1) (3) (4)

•

Benefits for the family of o

ur employees

(Fitnes

s Center)

(1) (3) (4)

•

Extended maternity leave

(1) (3) (4)

•

Extended parental leave

(1) (3) (4)

•

Adoption leave

(1) (4)

•

Wedding Policy

(4)

•

Post-maternity leave flexibility

(1) (4)

•

Breastfeeding room

(4)

•

Card 365

(4)

•

English Classes

(1) (3) (4)

•

Preferential prices in insurance

(1) (3) (4)

•

Discounts on various products and services

(4)

•

Vending machine

(4)

•

Financial assistance

(1) (3) (4)

•

Long

-term savings plan for ex

ecu

tives

(1) (4)

(1)

AGEA

(2)

Canal 12

(3)

Radio Mitre

(4)

Grupo Clarín

103

NOTE 19

Parental Leave 2021

Total Number of Employees

Women

Men

Number of employees that were entitled to parental leave in 2021

1,390

3,129

Number of employees who made effective use of the parental leave in 2021

46

52

Number of employees who returned to work after the end of the parental leave 2021 and whose leave started and

ended in 2021

19

48

Number of employees who made effective use of the parental leave in 2021 and are still on leave as of December 31, 2021

14

2

Number of employees who made effective use of the parental leave in 2021 and w

ho did not return and are no longer on leave

3

2

Number of employees who returned to work after the end of the parental

leave in 2021 and whose leave started in 2020 or before

10

4

Number of employees who had to return to work after the end of the parental leave i

n 2021 and whose leave had started in 2020

or before, but

did not return to work

1

-

Return-

To

-Work Rate (2021)

88%

96%

Number of employees who returned to work during 2020 (after the parental leave that started in 2019 or 2020)

35

20

Number of employees who returned to work during 2020 (after the parental leave that started in 2019 or

2020) and continued working for 12

months

32

15

Retention Rate (2021)

91%

75%

Business units sur

veyed: AGEA; C

úspide; Autospo

rts; Artear Canal

13; Canal 12; P

ol-k

a; CIMECO; C

MI; Gestión Com

partida; La Voz

del Interior; Los A

ndes; Radio

Mitre; TyC S

ports; an

d Grupo Clarín

NOTE 20

All the data below includes part time and full time employees.

Employee Training in 2021

Average Hours of Training

Total hours of training

Number of Employees

Training by Employee

9

40,689

4,519

Breakdown by Gender

Training by Women

14.7

20,471

1,390

Training by Men

6.5

20,217

3,129

Breakdown by Job Category

Directors, General Managers and Managers

15.1

1,826

121

Middle Management

14.7

13,139

896

Analysts and Administrative Staff

16.1

23,329

1,452

Technical Staff

1.7

1,757

1,042

Other

2.8

2,870

1,008

Business units sur

veyed: AGEA; C

úspide; Autospo

rts; Artear Canal

13; Canal 12; P

ol-k

a; CIMECO; C

MI; Gestión Co

mpartida; La V

oz del Interior;

Los Andes; Ra

dio Mitre; TyC S

ports; and Gru

po Clarín

104

NOTE 21

Breakdown of Employees as of December 31, 2021

Distribution by category

Distribution by gender

Distribution by age

Professional category

Men

Women

< 30 years

31

- 50 years

> 51 years

%

Directors, General Managers and Managers

85%

15%

0%

35%

65%

Middle Management

73%

27%

3%

64%

34%

Analysts and Administrative Staff

51%

49%

26%

59%

15%

Technical Staff

93%

7%

6%

58%

36%

Other

66%

34%

23%

56%

21%

Total

69%

31%

15%

58%

26%

Business units sur

veyed: AGEA; C

úspide; Autospo

rts; Artear Canal

13; Canal 12; P

ol-k

a; CIMECO; C

MI; Gestión Com

partida; La Voz

del Interior; Los A

ndes; Radio

Mitre; TyC Spo

rts; and Grupo Cl

arín.

We also have 2 people with disabilities working in Gestión Compartida and TyC Sports.

Employees with Journalistic Functions

Number

Unionized Journalists

656

Other jobs in journalistic areas that are not represented by press unions

166

Self-employed workers with journalistic functions in the group's media

222

Business units sur

veyed: AGEA; C

anal 12; CMI; La Voz

del Interior; L

os Andes; and TyC S

ports.

Employees related to the newsroom area broken down by hierarchy in business units

engaged in print activities

Women

Men

Total

Copy writers

119

232

351

Sub-editors

35

77

112

Editors

34

65

99

Head of Area

14

51

65

Center Table

2

9

11

Editors-

in

-chief

-

9

Business units sur

veyed: AGEA; C

MI; La Voz del Inte

rior; and Los And

es.

NOTE 22

In 2021, there were not any substantiated complaints regarding breaches of customer priva

cy and losses of customer data in 20

21.

NOTE 23

No changes were made to the Materiality Assessment in 2021, and we used the matrix developed in 2018.

105

18.

EXHIBIT III

–

NOTE

ON COVID-19

Given the

magnitude

of

the spread of

the virus called

“Cor

onavirus” (COVID

-19) at a global

level,

in Argentina, the N

ational Gov

ernment implement

ed a series

of meas

ures aime

d at reducing t

he

movement

of

the

populatio

n,

order

ing

the

Mandatory

and

Preventive

Social

Isolat

ion

as

from

March 20

, 2020, allowing

the movement of

only those

people involved in

the provision/producti

on

of

essential

or

exempt

ed

se

rvices

and

products.

The

G

overnment

made

ch

anges

to

and

ex

tended

such

isolation

measures

in

different

stage

s

by

geograph

ical

regions

accordin

g

to

the

epidemiological situati

on of each city.

On

November

9,

2020,

th

e

National

Government

ordered

the

Mandatory

and

Preventive

Social

Distancing for

all pers

ons who reside

or tr

ansit in urba

n c

enters and in

district

s

and

departments

of the Argentine provinces that do not hav

e a sustained community transm

ission of the virus and

they positively verify

certa

in epidemiological and sanitary parameters. The locations where these

parameters were not

met continued w

ith the M

andatory and Prev

entive Social Isolat

ion.

By

the

end

of

2020,

Argentina

rolle

d

out

the

national

vaccinatio

n

cam

paign

under

th

e

d

irect

management

of

the

natio

nal

and

provincial

govern

ments

and

of

the

governmen

t

of

the

Autonomous City of

Buenos Aires.

Th

e

vaccin

ation

campaign is

being

completed wi

th

the

application

of

a

booster dose,

which

favors

a

lower

severity

i

n

COVID

-19

infections

in

Argentina

with

th

e

new

strains

that

are

spreading

worldwide. Like

the rest of

t

he

world,

A

rg

entina does

not escape the exponential rise in

infections

that since the end of 20

21 and early 2022 has

been strongly affecti

ng all age gro

ups.

During the effectiveness of the Mandatory

and Preventiv

e Social Distancing, and ev

en under the

new

r

estrictions,

s

everal

s

ervices

and

ac

t

ivities

ar

e

still

dee

med

“essent

ial”

as

they

h

ad

been

defined during the effect

iveness of the M

andatory and

Preventive Social Iso

lation.

Since

th

e

beginning of

t

he

p

andemic,

the

Company

h

as

carried

out

its

activities un

der challenging

circumstances

derived

fro

m

the

h

ealth

situati

on.

E

ven

though

the

print

media,

radio

and

audiovisual

communication

services,

which

are

the

Group's

main

businesses

,

have

bee

n

exempted from the Mandat

ory and Preventive Social I

solation, the Company has experie

nced or

is expected to experi

ence the following im

pacts:

-

A

d

ecline in

the sale

o

f

advertising in

all

the media

of

Grupo Clarín,

m

ainly due

to the

c

uts

in the customers’ advertisin

g budgets. However, Arte

ar has been showing a gradu

al and

continued recovery s

ince September

202

0 to date;

-

A

drop in

circ

ulation, with

a

n i

mpact on subscriptions

as from

the second

quarter of 2020;

-

An increase in the overdue

collection of rec

eivables;

-

Television audience lev

els were affected

by the lack of

production of cert

ain contents for

prime

time,

which

were

suspend

ed

due

to

the

pandemic

.

As

from

May

2

021,

the

co

mpany

resumed the airing of con

tents that ge

nerally lead to a

n increase in audienc

e levels;

-

Several difficulties th

at hindered our op

erations, such

as:

o

Those

the

logistics

regarding

the

commute

of

employees,

p

erformers

and journalists;

o

The reconfiguration of som

e programs due to

social dis

tancing measures;

o

The implementation o

f home office m

ainly for our back

office staff;

o

Strict sanitation, disinfecti

on and preve

nti

on protocols at our

offices;

o

The

incorporat

ion

of

technologies

requir

ed

to

ensure

the

virtu

al

pres

ence

of

talents in the producti

on of contents.

In order to

help compani

es mitigate the

economic impacts

of the pandem

ic, the National

Government

l

aunched

a

series

of

financial

aid

measu

res.

Among

the

co

mpanies

that

qualify

for

such

financial

aid,

certa

in

subsidiaries

of

the

C

ompany

have

benefited

from

t

he

Emergency

Assistance

Pro

gram

for

W

ork

and

Production

fro

m

A

pril

to

September

2020

and,

subsequently,

to

a

lesser

extent,

the

Program

for

Produc

tive

Recovery

II

from

Nove

mber

2020

to

June

2021,

106

whereby

the

Nat

ional

Government

has

as

sumed

the

burden

of

a

portion

of

the

w

age

costs

and

has allowed f

or reduct

ions/deferm

ent of

the payme

nt of cert

ain em

ployers’ s

ocial security

contributions.

I

n

a

ddition,

other

activities

which

have

a

s

maller

weight

in

the

Group

’s

operations

taken

as

a

whole

were

heav

ily

affected

since

t

he

Mandatory

and

Preventive

Social

Is

olation

entered

into

effect, such as

the operatio

ns of Autosports,

Pol

-ka an

d Cúspide. T

hese comp

anies were forc

ed

to reduce or suspend m

ost of their operat

ions and the commerc

ialization of their p

roducts during

most

of

fiscal

year

2020.

In

th

e

case

of

Pol-k

a,

the

economic

impacts

were

very

significant

because,

during

2020,

it

w

as

unable

to

pr

o

duce

conte

nts

for

the

subseq

uent

commercializat

ion.

Consequently, it

h

ad serious di

fficulties in

meeting its

financial, business and

l

abor commitments,

being

in a

very

difficult

posi

tion

to

have

access

to

new

financ

ing

sources.

As

from

the

beg

inning

of 2021, Pol-ka starte

d to resume its ac

tivities.

The

u

ltimate

effects

of

COVID

-19

and

its

impact

on

t

he

g

lobal

and

loc

al

ec

onomy

are

unknown

and

impossible

to

be

re

asonab

ly

predicted.

However

,

even

t

hough

the

Compan

y

has

suffered

and

is

expected

to

suffer

shor

t

term

effects,

it

does

not

expect

that

t

hey

will

affect

the

continuity

of the Group’s bus

inesses.

The

Board

of

D

irectors

is

cl

osely

monitorin

g

the

evoluti

on

of

the

situati

on

and

takin

g

the

necess

ary

measures

available

to

pre

serve

the

safety

and

hea

lth

o

f

the

employees

and

the

Company’s

activities.

Issuance of the Integr

ated Report 20

21 in the Curr

ent Context

As

mentioned

above,

there

is

uncerta

inty

about

t

he

impacts

that

the

COVID

-19

pandemic

could

have on the global ec

onomy and on o

ur business.

The

Inte

grated

Annual

Rep

ort

2021

we

are

presenti

ng

includes

our

key

topics

and

indicators

of

economic,

environmental

,

social

and

corporate

gover

nance

performance

as

of

Decemb

er

31,

2021.

It

should

be

noted

that

the

results

of

the

cr

isis,

which

h

as

had

econo

mic

and

po

litical

consequences

in

Arg

entina,

may

require

a

reassessment

of

our

objectives

in

the

light

of

t

he

changes, internal and ext

ernal, that will arise

in the coming m

onths.

We intend to remain responsive and effective in

our aim of promoting a posi

tive impact for all our

stakeholders

in

th

e

light

of

their

priority

demands.

That

is

why

we

will

continue

to

monitor

the

impact

of

the

pandemic

on

our

2022

p

erformance

indicators,

and

work

with

our

s

takeholders

to

address this crisis.

GRUPO CLARÍN S.A.

-

1

-

GRUPO CLARÍN S.

A.

GLOSSARY OF SELE

CTED TERMS

AGEA

....................................................

Arte Gráfico Editorial Argentino S.A.

AGL

.......................................................

Artes Gráficas del Litoral S.A.

ARTEAR

................................................

Arte Radiotelevisivo Argentino S.A.

BCBA

....................................................

Bolsa de Comercio de Buenos Aires

(Buenos Aires Stock Exchange).

BIMO

.....................................................

Billetera Móvil S.A.

Cablevisión Holding

...............................

Cablevisión Holding S.A.

Canal Rural

................................

...........

Canal Rural Satelital S.A.

CIMECO

................................................

Compañía Inversora en Medios de Comunicación (CIMECO) S.A.

CMI

........................................................

Comercializadora de Medios del Interior S.A.

CNV

.......................................................

Comisión Nacional de Valores

(Argentine Securities Commission)

DLA

.......................................................

Diario Los Andes S.A.

Adjusted EBITDA

..................................

Revenues

less

cost

of

sales

and

selling

an

d

administrative

expenses

(excluding

depreciation

and

amortization).

Additionally,

the

s

egment

"Cable

Television

and

In

ternet

Access"

includes

adjustments

r

elated

to

the

recognition

of

revenues

from install

ation services

and

transactions

including

separate items and the non-consolidation of special purpose entities.

Exponenciar

................................

..........

Exponenciar S.A.

FACPCE

................................................

Federación

Argentina

de

Consejos

Profesionales

de

Ciencias

Económicas

(Argentine Federation of Professional Councils in Economic Sciences)

FPP

.......................................................

Frecuencia Producciones Publicitarias S.A.

GCGC

...................................................

GC Gestión Compartida S.A.

GCSA Investments

...............................

GCSA Investments, S.A.U.

GC Minor

...............................................

GC Minor S.A.U.

GDS

......................................................

Global Depositary Shares

Grupo Clarín, or the Company

..............

Grupo Clarín S.A.

IASB

......................................................

International Accounting Standards Board

IESA

......................................................

Inversora de Eventos S.A.

IGJ

.........................................................

Inspección General d

e Justicia

(Argentine Superintende

ncy of Legal En

tities)

Impripost

...............................................

Impripost Tecnologías S.A.

INDEC

...................................................

National Institute of Statistics and Census

VAT

.......................................................

Value Added Tax

LSE

.......................................................

London Stock Exchange

LVI

.........................................................

La Voz del Interior S.A.

IAS

........................................................

International Accounting Standards

IFRS

......................................................

International Financial Reporting Standards

Papel Prensa

.........................................

Papel Prensa S.A.I.C.F. y de M.

Patagonik

..............................................

Patagonik Film Group S.A.

Pol-

Ka

...................................................

Pol-Ka Producciones S.A.

Radio Mitre

............................................

Radio Mitre S.A.

Gain (Loss) on Net Monetary Position

...

Results

from

changes

in

the

purchasing

power

of

th

e

curre

ncy

(“RECPAM”,

for its Spanish acronym)

Ríos de Tinta

.........................................

Ríos de Tinta S.A de C.V.

Telecom

................................................

Telecom Argentina S.A.

Telecor

..................................................

Telecor S.A.C.I.

TRISA

....................................................

Tele Red Imagen S.A.

TSC

.......................................................

Televisión Satelital Codificada S.A.

UNIR

.....................................................

Unir S.A.

URBANO

...............................................

Urbano Express Argentina S.A.

GRUPO CLARÍN S.A.

-

2

-

GRUPO CLARÍN S.

A.

CONSOLIDATED

FINANCIAL STATEMENTS

AS OF

DECEMBER 31,

2021 PRESE

NTED O

N A

COMPARATIVE BASIS

In Argentine Pesos (

$)

–

Notes 2.

1 and 2.12.

Registered office: P

iedras 1743, Buenos A

ires, Argentina

Main corporate busin

ess: Investing and financ

ing

Date of incorporation: J

uly 16, 1999

Date of registration wi

th the Public Reg

istry of Commer

ce:

- Of the by-laws: August

30, 1999

- Of the latest amend

ment: April 27, 2

017

Registration number wit

h the IGJ: 1,669,

734

Expiration of Articles of

Incorporat

ion: August 29, 2098

Information on Parent

Company:

Name: GC Dominio

S.A.

Registered office: P

iedras 1743, Buenos A

ires, Argentina

Information on the subsi

diaries in Not

e 2.4.

CAPITAL STRUCTU

RE (See Note

13

)

Type

Number of

votes per

share

Subscribed,

registered and

paid-in capital

Class “A”

Comm

on shares, with nominal va

lue of $ 1

5

28,226,683

Class “B” Common shares,

with nominal valu

e of $ 1

1

69,203,544

Class “C” Common s

hares, with nomi

nal value of $ 1

1

9,345,777

Total as of December 3

1, 2021

106,776,004

Total as of Decembe

r 31, 2020

106,776,004

GRUPO CLARÍN S.A.

-

8

-

GRUPO CLARÍN S.

A.

NOTES TO THE CON

SOLIDATED FIN

ANCIAL STAT

EMENTS

FOR THE YEAR EN

DED DECEMB

ER 31, 2021,

PRESENTED ON A CO

MPARATIV

E BASIS

(Amounts stated in

Argentine Pesos

–

Note 2.1.

1)

NOTE 1

–

GENERAL INFORMATION

Grupo

Clarí

n

is

a

holdi

ng

co

mpany

th

at

operates

in the

Media

industry

.

Its

operating

income

and

cash

flows

derive

from the operations

of its subsidiaries in wh

ich it participates dir

ectly or indirectly.

Its

operations

include

n

ewspaper

and

other

printing,

publishing

and

advert

ising

activities,

broadcas

t

elevision,

radio

operations

and

telev

ision

content

production,

on

-line

and

new

me

dia

services,

a

nd

other

media

rela

ted

activities.

A

subst

antial

port

ion

of

its

r

evenues

is

generated

in

Ar

gentina.

Throu

gh

its

subsidiaries,

it

is

e

ngaged

primarily in the fol

lowing business s

egments as of Dec

ember 31, 2021:

−

Print

and

Digita

l

Publications,

c

onsisting

of

national

and

regio

nal

n

ewspapers,

a

s

ports

daily,

magazine

publishing,

e

diting

and

distribution,

a

nd

c

ommercial

pr

inting.

D

iario

Clarín,

the

flagship

nat

ional

newspaper,

is

the

ne

wspaper

with

t

he

second

largest

circula

tion

in

th

e

S

panish

-s

peaking

world.

Th

e

s

ports

daily

Ol

é

is

the

o

nly

newspaper

of

its

kind

in

the

Argentine

mark

et.

T

he

children’s

ma

gazine

Gen

ios

is

the

childre

n’s

magazine with the h

ighest circul

ation in Arge

ntina.

−

Broadcasting

and

Prog

ramming,

consisting

of

Can

al

13,

one

of

the

two

broadcast

television

stations

wi

th

the

highest

audience

share

in

Arge

ntina,

AM

(Amplitude

Modulation)

/FM

(Frequency

Modulation)

radio

broadcast

stati

ons

(Radio

Mitre

an

d

La

100),

and

t

he

prod

uction

of

television,

f

i

l

m

and

ra

dio

program

ming

content, including cab

le television signals a

nd organiz

ation and broadcast

ing of sporting eve

nts.

−

Other,

consisting mainly

of the operations

of its subsidiary

GCGC, its shared serv

ice center.

NOTE

2

-

BASIS

FO

R

TH

E

PRE

PARATION

A

ND

P

RESENTATION

OF

T

HE

CONSOLIDAT

ED

FINAN

CIAL

STATEMENTS.

2.1 Basis for the prepar

ation

Through

General

Resolutions

No.

562/09

and

No.

576/10,

the

Argentine

Securitie

s

Commission

(“CNV”,

for

its

Spanish

acronym)

prov

ided

for

t

he

application

of

Technical

Reso

lutions

(“TR”)

No

. 26

a

nd

No.

29

issue

d

by

the

Argentine

Federat

ion

of

Pr

ofessional

C

ouncils

of

Econ

omic

Sc

iences

(“FACP

CE”,

f

or

its

Sp

anish

acronym),

which

adopt the International Financial Report

ing Standards (“I

FRS”) issued by the International Account

ing Standards

Board (“IASB”)

for entities subject

to the public

offering regime governed

by Law No.

26,831, whether on account

of t

heir

equity

or

their

notes,

or

which h

ave

requested

authorizat

ion to

be

subjec

t

to

s

uch

regime.

T

he F

ACPCE

issues Adoption Com

munications in order t

o imple

ment IASB resolutions

in Argentina.

These consolidated financi

al statements of Grupo Clarín for the year ended Dec

ember 31, 2021, present

ed on a

comparative

basis,

have

been

prepared

i

n

acc

ordance

w

ith

IFR

S.

Certain

additional

matters

were

inc

luded

as

required

by

the

Arge

ntine

General

Ass

ociations

L

aw

and

/or

CN

V

regu

lations,

incl

uding

the

supp

lementary

information provided

un

der the

last

paragr

aph of

Sectio

n

1, Chapter

III, Titl

e

IV

of General

Res

olution

N

o.

622/13.

That information is

inclu

ded in

the Notes to these

cons

olidated financial statements, as provided

under IFRS and

CNV rules.

In

preparing

th

ese

consolidated

f

inancial

stat

ements

for

the

year

end

ing

December

31,

2021

,

and

for

t

he

purpo

ses

of pres

entation

to

the

London

Stock

Exc

hange

(LSE),

the

Company

has

fo

llowed

accounting

pol

icies t

hat ar

e

in

accordance with IFRS.

These cons

olidated f

inancial s

tatements

have

been

prepare

d based

on

restated

historica

l cost,

as

ment

ioned i

n

Note

2.1.1,

except

f

or

the

valuation

of

fi

nancial

instruments

(see

Note

2.21).

In

gen

eral,

th

e

histor

ical

cost

is

ba

sed

on the fair value of the c

onsideration granted

in exchange for the

assets.

GRUPO CLARÍN S.A.

-

9

-

Certain

figures

reported

in

the

financi

al

statement

s

presented

on

a

comparative

b

asis

were

rec

lassified

in

or

der

to maintain the consist

ency in the disclosure

of the figu

res corresponding to th

is year.

The

attached

consolidated

informatio

n,

approve

d by

th

e Board

of Directors at

the meeting held on April 22,

2022,

is

presente

d

in

Argentine Pesos

($),

the

Arg

entine

legal

ten

der,

a

nd

arises

from

ac

counting

records

kept by

Grupo

Clarín S.A. and its subsi

diaries.

2.1.1 Application of

IAS 29 (Financial

Reporting in

Hyperinflationary

Economies)

IAS

29

-Fina

ncial

Report

ing

in Hyperinflationary

Economies requires

that

the financial

s

tatements of

a

n

entity

that

reports

in

the

currency

of

a

highly inflat

ionary

economy

shall

be

stat

ed

in

terms

of

the

measurin

g

unit

curr

ent

at

the

clos

ing date

of the

reporting year / period,

r

egardle

ss of

whe

ther they

are based on

a historical cost

approac

h

or

a

current cost

approach. To

this end,

in general

term

s,

the

inflation rate

mus

t

be

computed in

the non-

monetary

items

as

from

the

acquisi

tion da

te

or

the

revaluat

ion

date,

as

app

licable. T

hese

requireme

nts

also

comprise

th

e

comparative informat

ion of the financia

l statements.

To

determine

the

ex

istence

of

a

high

ly

inflationary

economy

under

the

terms

of

IAS

29

,

the

st

andard

details

a

series

of

fact

ors

to

c

onsider,

including

a

cumul

ative

i

nflation

rate

over

three

years

that

is

close

to

or

exc

eeds

100%. This

is why

, in ac

cordance w

ith IAS

29, Ar

gentine eco

nomy sho

uld be

considered

as a

highly i

nflationary

economy as from Ju

ly 1, 2018.

In addition, Law No. 27,468, published in the Official Gazette on

December 4, 2018, amended Section 10 of Law

No. 23,928,

as amended, providing that

the repeal of all

the laws

and regulations that

establish

or

authorize price

indexation, currency restatement, cost variance and

any

other form of restatement of debts, taxes, prices or fees

related to property, works or services, does

not apply to financial statements, which remain subject to Section 62

in

fi

ne

of

th

e

Ge

neral

Associations

Law

(as

restated

in

1984),

as

amended.

In

additio

n,

it

repeal

ed

Decree

No.

1,269/2002

dated

July

16,

2002,

as

a

mended,

a

nd

delegated

on

the

Execut

ive

Branch,

through

its

oversight

agencies, the power to set the date as from wh

ich those regulations will come into

effect with respect to financial

st

atements.

On

Decemb

er

28,

2

018,

through

G

eneral

Resolution

No

.

777/2018,

the

CNV

provided

that

t

he

entities

subject

to

the

Co

mmission's

ov

ersight

m

ust

apply

the

method

to

res

tate

annual,

inter

im

and

specia

l

fi

nancial

statements in

constant currency, as

est

ablished by IAS

29,

for fiscal years

ended on or

af

ter December 31,

2018.

Therefore, these financ

ial statements have b

een restated in consta

nt currency as

of December 31,

2021.

According

to

IAS

2

9,

the

f

inancial

s

tatements

of

an

entity

that

reports

i

n

the

curr

ency

of

a

highly

i

nflationary

economy shall be state

d in terms of the

measuring unit

current at the c

losing date of the financ

ial statements.

The inflation adjustment was

calculated taking into consideration the

indexes established by the FACPCE bas

ed

on the price index

es published by IND

EC. The fol

lowing table sho

ws the evolut

ion of those indexes

over the last

three

fiscal

ye

ars,

acc

ording

to

official

statistics

(

INDEC)

in

accordance

w

ith

the

g

uidelines

described

under

Resolution No. 539/1

8:

As o

f

December 31,

2019

As of

December 31,

2020

As of

December 31,

2021

General Pr

ice Index (December

2016=100)

284.44

385.88

582.46

Variation of Price

s

Annual

53.8%

36.1%

50.9%

Accumulated

over 3 years

183.2%

209.2%

216.1%

The main procedures

applied for t

he above-

mentioned inflat

ion adjustment were t

he following:

-

The mo

netary

assets

and

liabilities

recorde

d

at t

he c

urrency

unit

of

the

financial

st

atement ar

e

not res

tated

because

they

are

already

stated

in

terms

of

the

meas

uring

uni

t

current

at

the

clo

sing

date

of

the

financia

l

statements.

-

The

non-monetary assets

and

liabilities recorded

at

cost

at

the date

of the

financ

ial

statement,

and the

equi

ty

items, are restated by

applying the corres

ponding adj

ustment coefficients.

-

All

the

eleme

nts

o

f

t

he

Sta

tement

of

co

mprehensive

income

are

adjus

ted

by

applying

the

corr

esponding

adjustment coefficients.

-

The

effect

of i

nflation on

the

Company's

net

monetary

pos

ition

is i

nclude

d

in

the

Statement

of

c

omprehensive

income under the

item “Gain (Loss) on N

et Monetary P

osition”.

GRUPO CLARÍN S.A.

-

10

-

The comparative figures have been restated

for inflation following the same procedure explained above and

after that, they wer

e restated as of the dat

e of these financial stat

ements.

The

following

is

a

descript

ion

of

the

initial

application

of

t

he

inflat

ion

adjustme

nt

in

the

most

relevant

equity

accounts:

-

The

capital stock

was restated since

t

he

date of

subsc

ription

or since

the date

of the

last inflation

adjustmen

t

for accountin

g purposes,

whichever

occ

urred later.

The differe

nce betwee

n the

nominal

value of

the c

apital

stoc

k and its value res

tated for inflation is

disclosed un

der “Inflation Adjustm

ent on Capital Stoc

k.”

-

The

paid-in

capital

w

as

restated

si

nce

the

date

of

s

ubscription

or

since

the

da

te

of

the

last

inflati

on

adjustment

for accounting purpos

es, whichever

occurs

later.

-

Other comprehens

ive income was rest

ated since eac

h date of the acc

ounting entry.

-

The ot

her r

eserves

were

restated

since

Jan

uary

1, 2

017,

which

was

the

first day

of

the

comp

arative

period

at the time of the initia

l application of th

e adjustment fo

r i

nflation.

2.2 Standards and Inte

rpretations is

sued but not a

dopted to date

As of

the

date

of

thes

e fi

nancial s

tatements,

no

new

standar

ds

have be

en iss

ued

that

apply

to

the

Company

for

the fiscal year that be

gan on January

1

st

, 2022 and/or in subseq

uent y

ears.

2.3. Standards and Inte

rpretations i

ssued and ado

pted to date

As of

the

date

of

thes

e fi

nancial s

tatements,

no

new

standar

ds

have be

en iss

ued

that

apply

to

the

Company

for

this year.

2.4 Basis for Consolid

ation

These consolidated financ

ial statements incorpora

te the financial statemen

ts of

the Company

and of the

subsidiaries

and

joint

ventures

(“Interests

in

Joint

Operations”,

Note

2.7)

controlled

by

the

Company.

Control

is

presumed to

exist when

the

Company has

a right to va

riable returns

from its

interest

in a subsi

diary and

has t

he

ability

to

af

fect

those

returns

through

its

power

over

the

subsidiary.

This

power

is

presumed

to

exist

when

evidenced

by

the

votes,

be

it

t

hat

the

C

ompany

has

the

m

ajority

o

f

vot

ing

rights

or

potenti

al

rig

hts

curr

ently

exercised.

The

subsidiaries

are

consolidated

from

the

date

on

which

the

C

ompany

assumes

control

over

them

and are excluded from co

nsolidation

on the date contr

ol ceases.

For

conso

lidation

purposes,

the

i

ntercompany

tr

ansa

ctions

and

th

e

ba

lances

between

t

he

Company

and

the

consolidated subsid

iaries have been e

liminated.

Unrea

lized income has also b

een eliminated.

Below

is

a

detai

l

of

th

e

most

s

ignificant

c

onsolidated

subsidiaries,

together

w

ith

the

interest

percentage

s

held

directly or indirectly in eac

h subsidiary’s cap

ital stock and votes,

as of each date

indicated below:

.

Direct or Indirect Interest in

the Capital Stock and Votes

(%)

Companies

December

31, 2021

December

31, 2020

AGEA

100.0%

CIMECO

100.0%

ARTEAR

(1)

99.3%

IESA

100.0%

Radio Mitre

100.0%

GCGC

100.0%

(1)

Interest in vote

s amounts to 99.7

%.

The

subsidiaries’

f

inancial

statements

used

for

consolidation

purposes

bear

the

same

closing

date

as

th

ese

consolidated

financ

ial s

tatements,

c

omprise

the

s

ame

periods

a

nd

have

been

pre

pared

under

exac

tly

the

sa

me

GRUPO CLARÍN S.A.

-

11

-

accounting policies

as

those used

by the

Comp

any, which

ar

e

described in

the notes

to

the consolidated

financ

ial

statements or, as the case

may be, adj

usted as app

licable.

2.4.1 Changes in the Com

pany’s Interest

s in Existing Subsidia

ries

The changes in

the Company’s interests

in

subs

idiaries that do not g

enerate a loss of control are

recorde

d under

equity.

The

book

value

of

t

he

Company’s

interests

and

no

n-controlling

interests

is

adj

usted

to

reflec

t

the

changes

in

the

relat

ive

interest in the

s

ubsidiary.

Any

differenc

e

between the amount

for which non-controlling interests were

adjusted and

the

fair va

lue of

the cons

ideration p

aid or

received

is d

irectly reco

gnized

in equity

and

attributed

to

the shareholders of the

parent c

ompany.

In case of loss of control, any residual interest in the

issuing company is measure

d at its fair value at the date on

which contro

l was

lost,

allocating

the c

hange

in the

re

corded va

lue with

an

impact

on n

et inco

me. The

fair

value

is the initia

l amount rec

ogn

ized for

such investm

ents for

the purpose

of the s

ubsequent v

aluation for

the

interest

retained

as

associate,

joint

operation

or

financial

ins

trument.

Additionally,

any

amount

recogn

ized

under Oth

er

Comprehensiv

e

Income

regarding

such

in

vestm

ents

is

recognize

d as

if

Grupo C

larín

had

disposed

of

the

and

liabilities.

Consequent

ly,

the

amounts

recognized

under

Other

Comprehensive Inco

me may be reclassif

ied to the stat

ement of income.

2.5 Business Combinat

ions

The

Company

applies

the

acquisition

meth

od

of

accounting

for

business

combinations

.

The

consideration

for

each

acquisition

is

m

easured

at

fair

value

(o

n

the

date

of

e

xchange)

o

f

the

assets

acquired,

the

liabilities

incurred

or

assumed

a

nd

the

equity

instruments

issued

by

the

C

ompany

in

exchange

for

t

he

c

ontrol

of

the

acquired

company.

The

costs

re

lated

to

the acquisition are expe

nsed as inc

urred.

The consideration for the acquisition, i

f any, includes any asset or liability arising from a

conting

ent consideration

arrangement,

me

asured

at

fair

val

ue

at

the

acquisit

ion

date.

Subsequent

change

s

to

such

fair

value,

identifi

ed

during the measurem

ent period, are adj

usted against the acq

uisition cost.

The

measurement period

is

the

effective period

that begins

on the

acq

uisition

date an

d ends

on

the date

on

w

hich

the

Co

mpany obtains

all the

informati

on

about

the facts

and circumstances

existing on

the acquisition

d

ate,

w

hich

may

not

ex

tend

bey

ond

on

e

year

after

the

acquisition

date. A

ll

other

changes

in

the

fair

va

lue

of

the

contingent

consideration classified as

assets or liabilities, outside

the measurement

period, are recognized

in the statement

of income.

The changes in the fair val

ue of the contingent co

nsideration clas

sified as equity

are not recognized.

In

the

c

ases

of

business

combinations

conducted

i

n

stages,

the

Company’s

e

quity

interest

i

n

the

ac

quiree

is

remeasured

at

fa

ir

va

lue

on

its

acquisition

da

te

(

i.e.,

the

date

on

which

the

Company

obtained

control)

and

the

resulting

gain

or

loss,

if

any

,

is

recogniz

ed

in

the

s

tatement

of

income

or

in

other

c

omprehensive

incom

e,

as

appropriate according to

th

e

source

of

the variation. In the

periods preceding the

reporti

ng periods,

the Company

may

have

recognized

un

der

oth

er

com

prehensive

income

the

changes

in

the

val

ue

of

the

interes

t

in

the

c

apital

stock

of

the

acquired

co

mpany.

In

that

case,

the

amoun

t

rec

ognized

under

other

comprehensive

income

is

recognized

on

the

sa

me

basis

that

w

ould

have

been

required

if

the

Com

pany

had

directly

disposed

of

t

he

previously-held eq

uity interest.

The

iden

tifiable

assets,

liabilities

and

contin

gent

l

iabilities

of

t

he

acquired

co

mpany

that

meet

the

conditions

for

recognition u

nder IFRS

3

(2008)

are reco

gnized at

fair

value at

the

acquisition

date,

except

for c

ertain p

articular

cases provided by s

uch standard.

Any excess

of t

he acquisiti

on cost (

including th

e intere

st previous

ly held,

if any

, and th

e non

-c

ontrolling i

nterest)

over

the

net

fair

value

of

t

he

subsidiary’s

or

ass

ociate’s

ident

ifiable

assets,

liabi

lities

and

contingent

li

a

bilities

measured

at

the

ac

quisition

d

ate

is

reco

gnized

as

goodwill.

Any

excess

of

th

e

net

fair

value

of

the

identifiable

assets, liabilities

and contingent

liabilities over t

he acq

uisition cost is

immediately

recognized

in the sta

tement of

income.

The ac

quisition

cost co

mprises

the cons

ideration tr

ansferred,

the a

mount

of any

n

on

-controlling interest

a

nd t

he

acquisition-date fa

ir value of the ac

quirer's previous

ly-

held equity interest in

the acquiree, if any.

GRUPO CLARÍN S.A.

-

12

-

The Com

pany i

nitially

recognizes

any

non

-contro

lling

interest

as

per

its s

hare i

n t

he am

ounts r

ecognized

for

the

net identifiable assets of t

he acquired co

mpany.

2.6

Investments in Associat

es

An associate

is an

entity ov

er which t

he Compa

ny has

significan

t influence, w

ithout ex

ercising control

, general

ly

accompanied by equ

ity holdings of betwe

en 20% and 50% of

voting rights.

The associates’

net inco

me and th

eir assets

and l

iabilities are

disclosed

in the c

onsolidated

financial sta

tements

using the

equity

method,

exc

ept when th

e

investment

is classified

as he

ld for

sale,

in wh

ich case

it

is accounted

for under

IFRS 5 “Non

-

Current Assets

Hel

d for S

ale and Discontinued Operations”. Under

the

equity

method, the

investment in an associate is to be initially record

ed at cost and the book value will be increased or decreased to

recognize

the investor’s share

in

the comprehensive income

(loss) for

the year

or in other

c

omprehensive income

obtained by

t

he associate, after

the acquisition date.

The distributions rece

ived from

the associate will

r

educe the

book value of the inves

tment.

Any

exc

ess

of

the

acquisiti

on

cost

over

the

C

ompany’s

share

in

th

e

net

fair

v

alue

of

the

associate’s

identifiable

assets, liabilities and contingent liabilities measured at the acquisi

tion date is recognized as goodwill. Goodwill is

included in the book value of the investm

ent and tested for impa

irment as part of the investment.

Any excess of the

Company’s

share

in

the

net

fai

r

value

of

the

ident

ifiable

as

sets,

liabilities

and contingent

liabilities

ov

er

the

acquisition

cost, after its measurem

ent at fair value,

is immediatel

y recognized in the state

ment of income.

Unrealized

gains

or

losses

on

transactions

between

the

Company

(and

its

s

ubsidiaries)

and

ass

ociates

a

re

eliminate

d cons

idering the Company’s

interest in the a

ssociates.

Adjustments

were

made,

w

here

necessary,

to

the

asso

ciates’

financial

stateme

nts

so

that

their

account

ing

po

licies

are consistent with those

used by th

e Company.

Investments in companies in which the

company does not have control or significant influence have been valued

at cost, as establishe

d by IAS 39, restated

as mentioned in No

te 2.1.1.

In

the

cases

where

non-c

ontrolling

share

holders

hol

d

put

opti

ons

whereby

they

may

forc

e

the

Comp

any

to

ac

quire

shares

of

subsidiaries,

and

the

C

ompany

reason

ably

estimates

t

hat

such

put

o

ptions

wi

ll b

e

duly

exerc

ised,

the

Company discloses th

e present value of th

e corresponding fut

ure payments un

der Other Liab

ilities.

2.7

Interests in Joint Operati

ons

A

joint

o

peration

is

a

contrac

tual

arrangem

ent

where

by

the C

ompany

and

other

parties

undert

ake

an

ec

onomic

activity

that

is

subject

to

j

oint

contro

l,

i.e.,

whe

n

the

financial

strategy

and

the

ope

rating

decisions

t

he

company’s activities re

quire the unan

imous c

onsent of the parties

sharing control.

Joint vent

ure

arrangements

that entai

l th

e estab

lishment

of

an

independent

entity

in which

each

company

holds

an interest are

called jointly controlled entities. The Company, in accordance with IFRS 11

"Joint

Arrangements”,

has

applied

th

e

equity

m

ethod

to

measure

its

hold

ing

in

the

jointly

controlled

ent

ity

and

disclos

es

its

holdings

in

such entities under Inves

tments in unconsol

idated affiliates

.

In

the

cases

of

jo

int

busi

ness

arrange

ments

ex

ecuted

thro

ugh

U

niones

T

ransitorias

de

Empresas

("UTE"),

considered

joint

operations

under

IFRS

11,

the

Comp

any

recognizes

in

its

financ

ial

statements

on

a

line

-

by

-line

basis the assets, l

iab

ilities and

net income subject to joint control in proportion to its share

in suc

h arrangements

.

The consolidated financial statements

as of December 31, 2020 includ

e the balances of the UTEs, among them,

FEASA

–

S.A.

La

Nación

Unión

Transitoria

de

Empresas,

AGEA

S.A.

–

S.A.

La

Nación

–

UTE

and

Unir

S.A.

-

Correo

Andreani

S.A.

-

Un

ión

Transitor

ia

de

E

mpresas,

in

which

the

Compa

ny

a

nd/or

its

su

bsidiaries

held

an

interest.

The

consolidated

financial

stateme

nts

as

of

December

31,

2021

do

not

include

balances

from

interests

in

joint

ventures.

GRUPO CLARÍN S.A.

-

13

-

2.8

Goodwill

Goodwill arises

from the acquisition

of subsidiaries and refers

to the

excess of

the cost of

ac

quisition over the ne

t

fair

value

at

the

date

of

ac

quisition

of

the

ident

ifiable

as

sets

acquired

and

liabili

ties

assume

d.

The

Co

mpany

initially recognizes

any

non-

controlling interes

t as per

its

share in the

amounts

recognized for

the ne

t identifia

ble

assets of the acquired

company.

If,

after

the

fair

v

alue

measurement,

the

C

ompany's

s

hare

in

t

he

fair

v

alue

o

f

the

net

id

entifiable

as

sets

of

the

acquiree exceeds the amount of the transferred consideration, the

amount of any non-c

ontrolling interest in such

company

and

the

fair

va

lue

of

the

interes

t pr

eviously

h

eld by

th

e

acquirer

in

th

e a

cquiree

(if

any),

that

ex

cess

is

immediately

recognized

in

the

statement

of

c

omprehens

ive

income

as

income

from

purchase

in

very

profitable

terms.

Goodwill is not

amortized,

but tested f

or impairment

on an

annual basis.

For the purposes

of impa

irment testing,

goodwill

is

allocated

to

e

ach

of

the

Comp

any's

cash

-generat

ing

units

expec

ted

to

render

benefits

from

the

synergies of

the respective business

comb

ination. Those

cash

-generating units

to which goodwill i

s allocated are

tested

for

impairme

nt

on

an

a

nnual

b

asis,

or

more

frequently,

whe

n

there

is

any

ind

ication

of

impairm

ent.

If

the

recoverable

value

of

the

c

ash-

generating

unit,

i.e.

the

higher

of

the

v

alue

in

us

e

or

the

fair

value

net

of

s

elling

expenses,

is lower

than

the

value of

the n

et assets

allo

cated to

that

unit,

including good

will, the

impairme

nt lo

ss

is first allocated

to reduce

the goodwi

ll allocated to

the unit

and then to

the other as

sets of the unit,

on a pro r

ata

basis, bas

ed

on

the

valuati

on of

eac

h ass

et

in

the

unit.

The

imp

airment

loss

recognize

d ag

ainst

the v

aluatio

n of

goodwill is not revers

ed under any circu

mst

ance.

In case of a loss of control in a subsidiary, the amount

attributable to goodwil

l is included in the calculation of the

gain or loss for retireme

nt.

2.9

Revenu

e Recognition

Revenues

are

reco

gnized

when

the

amount

of

revenues

may

be

reliably

estimated,

when

future

econo

mic

benefits are

likely

to

be

obtained

by

the

C

ompany,

and

when

speci

fic c

riteria

are

met

for

each

of Grupo

Clarí

n's

activities, as described be

low.

Revenues for each of

the main business

segments identified by the

Compa

ny are

recognized when the following

conditions are met:

- Print and Digital Pu

blications

Advertising

sales

are

d

etermined

by

the

prices

achieved

p

er

single

column

c

entimeter

an

d

the

number

of

advertising

c

entimeters

s

old

in

the

relevant

period.

Circulation

sa

les

include

the

price

r

eceived

from

t

he

sa

le

of

newspapers,

magazines

an

d oth

er

publications.

Printin

g s

ervices

sales

consist

mainly

of

fees

rece

ived fro

m

the

printing of magazin

es, books, brochures an

d related pr

oducts.

Those

rev

enues

are

calcul

ated

t

akin

g

in

to

cons

ideration

the

esti

mated

amount

o

f

any

discount,

benefit

or

price

reduction that the Comp

any and its subsid

iaries may grant.

Advertising

s

ales

fr

om

ne

wspapers

and

magazines are

recognized

when

advertisin

g

is

published

.

Reve

nues

fr

om

the sale of newspap

er and magaz

ines are recognized

upon passin

g control to the

buyers.

Revenues

from

t

he

sale

of

newspa

per

and

m

agazines

are

recognized

upon

passing

control

to

t

he

buyers.

The

Company

r

ecords

the

estimated

impact

of

returns,

calculated

based

o

n

hist

or

ical

trends,

as

a

deduction

from

revenues.

Reve

nues

from

printing

services

are

recognized

upon

co

mpletion

of

the services,

delivery

of

the

mer acceptanc

e.

Digital

advertis

ing

revenue

s

are

recorded

according

to

the

price

set

for

each

site

and

sect

ion

wh

ere

adverti

sing

is

served,

considering

its

placement

and

format.

Revenues

from

online

advertis

ing

f

or

sponsorship

or

fixed

positions are recognized

over the term set for the a

d, while revenues from

online advertisin

g for served pri

nt ads

are recognized base

d on the number

of times the ad w

as displayed on the w

eb.

GRUPO CLARÍN S.A.

-

14

-

- Broadcasting and Pro

gramming

television

an

d

rad

io

adv

ertising

s

ales

r

evenues

are

re

cognized

when

a

dvertising

is

broadcast.

Revenues

from

programming and d

istribution of television conte

nt are recognized wh

en the programming services are

provided.

Advertising

revenues

are

calculate

d

taking

into

c

onsideration

th

e

estimated

a

mount

of

any

discount,

b

enefit

or

price reduction that th

e Company and its subs

idiar

ies may grant.

2.10 Barter Transa

ctions

The

C

ompany,

through

its

subsidiaries,

s

ells

a

smal

l

portion

of

its

advertising

spaces

in

exchange

for

good

s

or

services received. Revenues are recorded when

the advertisement is made,

value

d at

the fair value

of t

he goods

or serv

ices received,

in the

case

of goods

and o

ther ser

vices advertising

barter

transactions,

or de

livered,

in the

case

of

advertising

-

for

-a

dvertising

barter

tra

nsactions.

Goods

or

services

are

r

ecorded

at

th

e

time

goods

are

received or

services

are

rendered.

The go

ods or

servic

es to be

received

in c

onsideration

for the

advertisem

ents

made

are

recorded

as

Trade

Receivables.

The

a

dvertisements

to

b

e

m

ade

in

exc

hange

for

the

goods

a

nd

services received are

recorded as Trade and Ot

her Pay

ables.

2.1

1 Leases

Leases

are

classified

as

fi

nancial

leases

whe

n

the

terms

of

the

lease

tr

ansfer

to

the

lessee

substantially

a

ll

the

risks and benefits inhere

nt to the property

. All other lea

ses are classif

ied as operating le

ases.

The

assets

held

under

f

inancial

l

eases

are

r

ecognized

at

the

lower

of

the

fair

v

alue

of

the

Co

mpany’s

l

eased

assets at the beginning of

the lease term, or t

he present value of the

minimum lease payme

nts. The liability h

eld

with

the

lessor

is

incl

uded

in

the

stat

ement

of

financi

al posi

tion

as

an

obl

igation u

nder

financial

le

ases

recorded

under lease liabilities.

Lease pay

ments

are a

pportioned

between

the

finance

charge

and

the

reduction

of

the

liabilities

under

the

lea

se

so

as

to

ac

hieve

a

const

ant

interest

rat

e

on

the

outst

anding

balance.

The

finance

charge

is

expensed

over

the

lease term.

The

assets

held under

fin

ancial l

eases are

de

preciated over

the shorter

of the

usef

ul

l

ife

of

the assets

or the

l

ease

term.

Until

December 31,

2018, the

rentals under

opera

ting

leas

es

were charged

to

inco

me

on

a straight-line

basis over

the corr

esponding

lease

term.

As

from

January

1,

2019,

the

Company

has

applie

d

IFRS 16

regard

ing o

perating

lease agreements.

2.12 Foreign Cu

rrency and Functio

nal Currency

The financial statements of each of the

entit

ies consolidated by the Company are prepared in the currency of the

primary

econ

omic

environ

ment

in

which

th

e

entity

operates

(its

functional

c

urrency

).

For

the

purposes

of

the

consolidated financial statements, the net income and the financial position of each entity are

st

ated in Argentine

Pesos

(Argentina’s

l

egal

tender

f

or

all

compa

nies

domiciled

in

Argentina),

wh

ich

is

the

Comp

any’s

functio

nal

currency,

and

the

report

ing

curr

ency

o

f

t

he

cons

olidated

financial

s

tatements.

The

f

unctiona

l

currency

of

the

indirectly controlled Urugu

ayan compan

ies is the Urug

uayan Peso.

In

pre

paring

the

financial

statem

ents

of

the

individual

entities, the

transactions

i

n

c

urrencies oth

er

th

an

the

e

ntity’s

functional

c

urrency

(foreign

currency)

are

r

ecorde

d

at

t

he

exchange

ra

tes

pr

ev

ailing

on

t

he

dates

on

which

transactions

are

carr

ied

out.

At

the

end

of

each

reporting

year,

th

e

m

onetary

items

denominated

in

forei

gn

currency are retransl

ated at the exc

hange rates prevaili

ng on such date.

The exchange diff

erences were charg

ed to income (lo

ss) for the period in wh

ich they were

generated.

In

pre

paring

t

he

Company’s

c

onsolidated

f

inancial

statements,

asset

and

liability

balances

of

the

entities

which

functional

currency

is not

the

Argentine pes

o,

express

ed

in

the

ir o

wn

functional

c

urrency

(Uruguayan

Peso)

are

translated

into

Argentine

p

esos

at

the

exchange

r

ate

prevailing

at

the

en

d

of

t

he

year,

while

net

inco

me

is

GRUPO CLARÍN S.A.

-

15

-

translated at

the exc

hange

rate

prevailing

on

the

trans

action

date.

Translation

differenc

es

are

recog

nized

under

other comprehensive

income as “Variatio

n in Translation Diff

erences of Fore

ign Operations”.

2.13 Financial Expens

es on Debt

Financial

ex

penses

on

debt

directly

attributable

to

th

e

a

cquisition,

c

onstruction

or

productio

n

of

assets that

r

equire

a subs

tantial

period

of

time

to

prep

are f

or

their

intende

d use

or

sa

le (“

qualifying

ass

ets”),

are

capitalized

as

part

of

the

cost

of

these

assets

until

they

are

r

eady

for

th

eir

intended

use

or

sale,

a

ccording

to

IAS

23

("Borr

owing

Costs").

The i

ncome,

if

any,

on

the

tempor

ary

investment

of

the

specific

borrowi

ngs i

ncurred

to

finance

qualifying

asse

ts

is deducted from the f

inancial expenses o

n debt to be capital

ized.

All other financial exp

enses on debt

were charged to

income (loss)

for the

period

in which they were

generated.

2.14 Taxes

The income tax charge ref

lects the sum

of current income t

ax and deferred inco

me tax.

2.14.1 Current and D

eferred Income T

ax for the ye

ar

Current

a

nd

deferr

ed

tax

es

are

r

ecognized

as

expense or

inco

me

(lo

ss)

for

the

y

ear

,

except

when the

y

are

relat

ed

to entries debited

or credited to other comprehensive income or

equ

ity, in which

cas

es taxes are

also recogniz

ed

under other c

omprehensive

income

or directly

in equ

ity, respectively. I

n the cas

e o

f a busi

ness

combinat

ion, the

tax

effect

is

taken

into

consideration

i

n

the

calculati

on

of

goodwill

or

in

the

determ

ination

of

the

ex

cess

of

acqu

irer's

interest

in

the

net

fair

value

of

the

acq

uiree’s

identifiabl

e ass

ets,

liabilities

and

cont

ingent

liabilities

over

th

e

cos

t

of the business com

bination.

2.14.2 Current Incom

e Tax

Current

tax

payable

is

based

on

the

taxable

income

rec

orded

during

the

year.

T

axable

income

and

net

income

reported in the consolidated statement of

co

mprehensive income differ due to revenue or

expens

e items that are

taxable or

deductible

in ot

her

fiscal

years

and

items

that are

never

taxable

or d

eductible. T

he curr

ent t

ax liability

is

calcu

lated

using

t

he

tax

rate

in

effect

as

of

t

he

date

of

th

ese

c

onsolidated

fin

ancial

s

tatements.

Current

tax

charge is calculated base

d on the tax ru

les effective in

the c

ountries

in which the consolida

ted entities operate

.

2.14.3 Deferred Incom

e Tax

Deferred tax

is recognized on temporary differences between

the

book value of

the assets and

liabi

lities included

in

these

financ

ial

statemen

ts

and

the

c

orresponding

tax

bas

is

used

to

determine

taxable

income.

Deferred

tax

liabilities

are

general

ly

recognized

for

a

ll

temporary

fis

cal

differences.

Deferred t

ax

assets

are

r

ecognized

for

all

deductible

temporary

differ

ences

to

th

e

extent

t

hat

it

is

probable

that

future

taxable

i

nco

me

w

ill

be

available

against

which

those

dedu

ctible

te

mporary

d

ifferences

can

be

ch

arged.

These

ass

ets

and

liabilities

are

not

recognized if

t

he

tempor

ary differences

arise from

goodwill or

from the

initial recognition

(other than

in a

business

combination)

of

other

assets

and

liabilities

in

a

tran

saction

that

aff

ects

ne

ither

the

taxable

income

nor

the

accounting income.

The book

value

of

a

deferr

ed tax

asset

is

reviewed

at

each

report

ing year

a

nd re

duced to

t

he exten

t that

it is

no

longer probable t

hat suffic

ient taxab

le income will b

e available

in the future

to allow for th

e recovery

of all or

part

of the asset.

Deferred tax is recognize

d on temporary

differences ar

ising from investments

in foreign subsid

iaries.

Deferred tax

assets and

liabilities are m

easured

at the

tax rates

that

are expected

to be

applicable

in the

year

in

which the asset is realized or the

liability is settled, based on the tax rates (and tax laws) that have been enacted

or substantively enacted by the end of the period. The measure

ment of deferred tax liabilities and assets reflects

the t

ax

consequences

th

at

would

follow

from

the

manner

in

w

hich

the

entity

expe

cts,

at

the

end

of

th

e r

eporting

year, to recover or settl

e the book value of

its assets and liabilities.

GRUPO CLARÍN S.A.

-

16

-

Deferred tax

assets

are off

set against

deferred

tax lia

bilities if

effective reg

ulations

allow to

offset,

before th

e tax

authorities, the

amounts recognized

in those i

tems; and i

f the

d

eferred tax

assets and

liabilities arise

from income

taxes levied by the sa

me tax

authority and the Compa

ny intends to sett

le its assets and

liabilities on a net ba

sis.

Under

the

IFR

S,

deferred

income

tax

ass

ets

a

nd

l

iabilities

are

classified

as

non

-current

assets

and

liabilitie

s,

respectively.

2.15 Property, Plant

and Equip

ment

Property,

plant an

d

equi

pment

held

for

use in

the

produ

ction

or

supply of

goods and

services

,

or

for ad

ministrative

purposes,

are

recorded

at

cost,

restated

as

ment

ioned

in

Note

2.1.1,

less

accumul

ated

d

epreciation

and

any

accumulated impairme

nt loss

.

Depreciation

of

prop

erty,

plant

and

equ

ipment

in

use

is

recognized

on

a

strai

ght

-line

basis

over

its

esti

mated

useful life.

The estimated

useful life

, residual va

lue and d

epreciation

method are

reviewe

d at

each year

-end,

with the

effect

of any changes in

estimates acc

ounted for on a prosp

ective basis. Land

is not depreciated.

Works

in

process are

recorded at

cost, restated

as mentioned

in Note

2.1.1, less

any

recognized

impairment loss.

The cos

t inc

ludes

professional

fees

and,

in the

case

of

qualifyin

g ass

ets, c

apitalized

financial

expenses

on

deb

t

in accordance

with t

he Co

mpany’s ac

counting po

licy

(Note 2.13). D

epreciation

of these

assets,

as we

ll as

in the

case of other property, p

lant and eq

uipment, begins wh

en the assets are r

eady for their

use.

Assets

held

un

der

financ

ial

leases

are

depreciated

over

the

short

er

of

th

eir

estimated

useful

life,

which

is

equal

to the rest of the oth

er similar assets, or ov

er the lease term.

Repair and mainten

ance expenses are

expensed as inc

urred.

The gain

or loss

arising

from the

retirement

or disp

osal of

an item

of pro

perty, p

lant and

equipment

is ca

lculated

as

the

difference

between

income

from

the

sale

of

th

e

ass

et

and

t

he

ass

et’s

book

value,

an

d

recogn

ized

un

der

“Other Income and

Expenses, net” in t

he statement

of c

omprehensive inco

me.

The

r

esidual

v

alue

of

an

asset

is

wr

itten

down

to

its

recoverable

v

alue,

if

t

he

ass

et’s

restated

res

idual

value

exceeds its estimated

recoverable v

alue (see Note 2.1

7).

2.16 Intangible Assets

Intangible

assets

include trademarks

a

nd

patents,

exclus

ivity

agreem

ents,

licenses,

software

a

nd

other

rights,

the

purchase

value

of

the

subs

criber

portfolio,

proj

ects

in

-

progress

(main

ly

s

oftware

devel

opment)

and

other

intangible

assets.

The

accounting

policies

regar

din

g

the

recognition

and

measurement

of

such

intangible

assets are described b

elow.

2.16.1 Intangible Ass

ets Acquired Sep

arately

Intangible

ass

ets

acq

uired

separately

are

valued

at

cost,

restat

ed

as

mentioned i

n

Note

2

.1.1,

n

et

of

the

corresponding

accum

ulated

a

mortization

and

impairment

losses.

Amort

ization

is

calculat

ed

on

a

strai

ght-line

basis

over

the

estimated

useful

life

of

the

intangible

assets.

The

Company

reviews

the

usef

ul

lives

applied,

the

residual

value

and

the

amortization

method

at

each

year

-end,

a

nd

accounts

the

eff

ect

of

a

ny

cha

nges

in

es

timates

on a prospective bas

is.

As

sets

held un

der

financia

l

leases

are

depreciated

ov

er

the

shorter

of

th

eir

estimated

useful

life,

which

is

equal

to the rest of the oth

er similar assets, or ov

er the lease term.

2.16.2 Intangible Ass

ets Acquired in a Bu

siness C

ombination

Intangible assets acquired

in a

b

usiness combination are

identified and

reco

gnized separately regarding

good

will

when they

meet

the

definition

of

intangible

assets

and

their

fair v

alue c

an b

e me

asured

reliably.

Such

intangible

assets are recognized

at fair value at acquis

i

tion date.

GRUPO CLARÍN S.A.

-

17

-

After t

he

initial

recognition

,

intangible

assets

acquired

in

a

business

comb

ination

are

valued

at cost,

res

tated

as

mentioned

in

Note

2.1.1,

net

of

ac

cumulated

amorti

zation

and

impairment

losses,

with

the

same

basis

as

intangible assets acq

uired s

eparately.

2.16.3 Internally Gener

ated Intang

ible Assets

Internally generated intangible assets arising from the

development phase of an i

nternal project are recognized if

certain conditions are met, amon

g them, technical feasibility

to complete the

developme

nt of the intangible asset

and the intent to com

plete such develop

ment.

The amount initially recogniz

ed for internally generated intangible assets compr

ises all the expenses incurred

as

from the moment all

the intangible assets meet the above-

me

ntioned recognition cr

iteria. Where it

is not possible

to

recognize an

internally

generated

intangible asset,

the development expe

nses

are

reco

gnized i

n the

s

tatement

of comprehensive inc

ome in the year in wh

ich they are incurred.

After

the

i

nitial

recogn

ition,

interna

lly

developed

intangible

assets

are

valued

at

c

ost,

restated

as

menti

oned

in

Note

2.1.1,

net

of

ac

cumulated

amortization

a

nd

imp

airment

losses,

with

the

same

bas

is

as

intang

ible

assets

acquired separately.

Such assets are i

ncluded under softw

are and proj

ects in-progr

ess.

2.17 Impairment of No

n-Financial

Assets, Except

Goodwill

At

the

end

of

each

financial

statement,

the

Company

reviews

the

book

value

of

its

non

-f

inancial

as

sets

with

definite

useful

life

to

de

termine

the

existence

of

any

evidence

indicating

that

these

ass

ets

c

ould

be

impaired.

If

there

is

any

indication

of

impairme

nt,

the

rec

overable

va

lue

of

t

hese

assets

is

estimated

for

th

e

purposes

of

determining

the

am

ount

of

the

impairment

loss

(in

ca

se

the

recov

era

ble

value

is

lower

than

the

book

value).

Where

it

is

not

possible

t

o

estimate

t

he

recoverab

le

v

alue

of

an

individual

asset,

the

C

ompany

es

timates

the

recoverable

value

of

t

he

c

ash

-generating

u

nit

("

CGU"

)

to

which

such

asset

bel

ongs.

W

here

a

consiste

nt

a

nd

reasonable

alloc

ation

bas

e

can be

identified, corporate

assets are

also

allocate

d

to an

individual cash

-

generating

unit

or,

otherwise,

to

the

smallest

gro

up

of

cash-

generating

units

for

which

a

consistent

allocation

base

can

be

identified.

The

r

ecoverable

value

of

an

as

set

is

the

higher

of

t

he

fair

va

lue

l

ess

selling

expenses

or

its

v

alue

in

use.

In

measuring

v

alue

in

us

e,

es

timated

future

cash

flows

are

discounted

at

their

presen

t

value

using

a pre

-tax

d

iscount

rate,

which

reflects

the

current

market

assessments

of

the

time

value

of

mo

ney

and,

if

any,

the

risks

s

pecific

to

the asset for which est

imated future c

ash flows have

not been adjus

ted.

Assets with an inde

finite useful l

ife (for example,

non-

financial as

sets unavailable

for use) are

not amorti

ze

d, but

are tested for impair

ment on an ann

ual basis.

Non-financial

assets,

ex

cept

for

goodw

ill,

for

w

hich

an

impairment

loss

was

recorded,

are

rev

iewed

at

each

clo

sing

date for a possible revers

al of the impa

irment loss.

2.18 Inventories

Inventories

are

va

lued

at

the

lower

of

acq

uisition

cost

and/or

pro

duction

cost,

restated

as

me

ntioned

in

Not

e

2.1

.1,

or the net realizab

le value. The cost is d

etermined under the w

eighted avera

ge price method.

The pro

duction

cost

is

dete

rmined

under

the

cost

absorption

me

thod,

which

comp

rises

raw

materials,

labor

a

nd

other c

osts

directly

the

producti

on

of

goods.

The net

realizabl

e v

alue

represents

th

e es

timated

selling

price in the ordinary course

of business less

the estimated costs n

ecessary

to make such sale.

The criterion followed t

o expense each o

f these inventory

items is as follows

:

−

Film Rights (series, soap operas

and films) and progr

ams purchased:

The

cost

of

series,

soap

op

eras

and

progra

ms

purchased

to

be

shown

on broadcast

television

is

mainly

expen

sed

against

the

c

ost

of

sal

es

on

the

exhibition

d

ate

or

upon

ex

piration

of

exh

ibition

rights.

Ri

ghts

these

programs

ac

quired

in

p

erpetuity,

if

any

,

are

amortized

ov

er

the

ir

esti

mated

useful

life

(eight

y

ears,

with

a

gra

ce

period of three years an

d are subsequent

ly amortized

on a straight

-li

ne basis over the

next five years).

GRUPO CLARÍN S.A.

-

18

-

Films

are

expensed

against

the

cost

of

sales

on

a decreasing

b

asis,

based

o

n t

he

number

o

f

showings

granted

by the respective rights or

upon expir

ation of exhibition righ

ts.

Film rights acqu

ired in perp

etuity are a

mortized over t

heir es

timated useful

life (sev

en years, with

a grace

period

of four years. They are

subsequently a

mortized on a d

ecreasing basis ov

er the next three years)

.

−

In

-house prod

uction progra

ms and co-

productions:

The cost of

in-house

produc

tion programs

and co

-prod

uctions is m

ainly expens

ed against

the cost

of sales

after

broadcasting

of

the

chapter

or

program.

Rights

r

elated

to

in-h

ouse

prod

uction

programs

and

co

-

pr

oductions

acquired

in

perpetuity,

if

an

y,

are

amortized

over

their

estimated

useful

life

(eight

y

ears,

with

a

grace

period

of

three years and are subs

equently am

ortized on a strai

ght-

line basis over the

next five years).

−

Events:

The cost of events is ful

ly expensed

against the cost of

sales at the time o

f broadcas

ting.

The allowance for impairment is calculated based on the recoverability analysis conducted at the closing of each

year.

The

valu

es

thus

obta

ined

do

n

ot

exceed

t

heir

r

espective recoverable

values

estimated

at

the

closing

of

each

year.

2.19 Other Assets

The assets included in

this item have been va

lued at ac

quisition cost.

Investments

denominate

d

in

fore

ign

currency

subject to

restrictions

on disposition

under

financi

al

c

ovenan

ts

hav

e

been valued at face v

alue plus interest accrue

d as of each year

-end.

2.20. Provisions and Ot

her Charges

Provisions for

Lawsu

its and

Con

tingencies and

the

accrual for

asset retirement are

recognize

d when

the

Company has a present obligation (be it legal or

constr

uctive) as a result of

a past event, when it is

probab

le that

an

outf

low

of

reso

urces

will

be

r

equired

to

settle

t

he

obligation

and

when

the

a

mount

of

th

e

o

bligation

can

be

reliably estimated.

The

amo

unt

r

ecognized

as

a

provision

is

the

best

estimate

of

the

expenditure

r

equired

to

s

ettle

the

present

obligation

at

t

he

en

d

of

t

he

reporting

year,

taki

ng

into

consideration

t

he

corr

esponding

r

isks

and

uncertainties.

Where

a

provisio

n

is

measured

usi

ng

t

he

estimate

d

cash

flow

to

se

ttle

the

pres

ent

obligatio

n,

its

book

v

alue

represents the present va

lue of such cash

flow.

In estimating its oblig

ations, the Com

pany has taken i

nto consideration

the opinion of its le

gal advisors, if any.

2.21

Financia

l Instruments

Financial assets and liabilities

, on initial recognition, are measured at transaction price as of the acquisition date.

Financial

assets

are

derec

ognized

in

the

f

inancial

statement

w

hen

th

e

rights

to

receive

cash

flows

fro

m

them

have

expired

or

have

be

en

transferr

ed

and

the

Co

mp

any

has

tra

nsferred

su

bstantially

all th

e

risks

and

be

nefits

of ownership.

2.21.1 Financial Asset

s

Upon

init

ial

reco

gnition,

in

accordance

with

IFRS

9,

fi

nancial

ass

ets

are

subseque

ntly

me

asured

at

eith

er

amortized cost, or fair va

lue, on the basis

of:

(a) the Company’s b

usiness model for man

aging the financial

assets; and

(b) the contractual cash f

low characterist

ics of the financial ass

et.

A financial asset shall

be measured at a

mortized cost

if both of the follow

ing conditions are m

et:

GRUPO CLARÍN S.A.

-

19

-

(a) the

asset is

held within a bu

sines

s model

whose

ob

j

ective is

to hold

assets in order

to collect

co

ntractual cash

flows, and

(b)

the

contr

actual

terms of

the

financial asset

give

rise,

on

spec

ified

dates,

to

cash flows

that

are

so

lely

p

ayments

of

principal and int

erest on the pr

incipal amount ou

tstanding.

A

financial

asset

that

is

not

meas

ured

at

amort

ized

co

st

accordin

g

to

the

paragraphs

a

bove

is

measured

at

fair

value.

Financial assets includ

e:

Cash and Cash Equiva

lents

Cash

a

nd

cash

equival

ents

includes

C

ash an

d

banks

a

nd

sh

ort-

term

and

highly l

iq

uid

i

nvestments

that

are

rea

dily

convertible

into

cash,

subje

ct

to

an

insignificant

risk

of

chang

es

in

value

and

the

ir

original

matur

ity

or

th

e

remaining

maturity at the date of

purchase does not ex

ceed

three months.

Cash and cash equ

ivalents are recorde

d, according to

their nature, at fa

ir value or amort

ized cost.

Investments

in

mutual

fund

s

are

carried at

fair

value.

Gains

and

l

osses

are

included

in

Oth

er

Financia

l

Results,

net.

Investments

in

G

overnment

Securities

were

v

alued

at

amortized

cost

or

at f

air

value,

acc

ording

to

the

business

model established by t

he Company

.

Balances

in

foreign

c

urrency

have

been

valued

as

me

ntioned

above,

at

the

ex

change

r

ates

effective

at

the

closing

of each year. The exc

hange differences

were charged to inc

ome for each year.

Trade and Other Rece

ivables

Trade and other

rece

ivable

s classified as

eith

er current or non-current assets are initially recognized at fair value

and

subsequently

me

asured

at

amortize

d

cost

using

th

e

effective

interes

t

method,

less

allowances

for

uncollectibility.

Interest

income

is

rec

ognized

using

t

he

effec

tive

interest

rate

method,

except

for

s

hort-

term

balances for which the r

ecognition of

interest is not sig

nificant.

Balances

in

foreign

c

urrency

have

been

valued

as

me

ntioned

above,

at

the

ex

change

r

ates

effective

at

the

closing

of each year. The exc

hange

differences were char

ged to income for e

ach year.

Investments

Depending

on

the b

usiness

mode

l

adopted

by

Management,

Securities

and

Bonds

may be

valued at

amortized

cost or at fair value and

its results are reco

gnized under Other Fi

nancial Resu

lts, net.

Balances

in

foreign

c

urrency

have

been

valued

as

me

ntioned

above,

at

the

ex

change

r

ates

effective

at

the

closing

of each year. The exc

hange differences

were charged to inc

ome for each year.

Impairment of Financi

al Assets

At

the

time

of

initial

r

ecognit

ion

of

financial

assets

(and

at

each

closing),

the

Company

es

timates

the

expected

losses, with an ear

ly recognition of a prov

ision, pursuant to IF

RS 9.

In

the

case

of

trade

receiva

bles,

as

from

January

1,

2

018,

the

Company

measures

the

allowance

for

bad

d

ebts

in an amount equal t

o the lifetime exp

ected credit loss

es.

The

expecte

d

loss

es

to

be

r

ecognized

are

calculate

d

bas

ed

on

a

percentage

of

u

ncollectib

ility

per

maturity ranges

of

each

financ

ial

credit.

F

or

s

uch

purp

oses,

the

Company

analyzes

the

perf

ormance

of

th

e

f

inancial

assets

grouped

by

type

of

market

.

Said

historical

perc

entage

must

cont

emplate

the

future

co

llectibility

expectat

ions

regarding those credits a

nd, therefore, t

hose estimated

changes in perfor

mance.

Given

the

nature

of

Ot

her

r

eceivab

les,

the

Compan

y

c

onducts

an

u

ncollectibil

ity

analysis

for

each

case

in

particular.

GRUPO CLARÍN S.A.

-

20

-

Derecognition of Fina

ncial Assets

The Company derecognize

s a financial asset when the c

ontractual rights to the cash flows of such ass

ets expire

or

when

it transf

ers

the

f

inancial

ass

et

and,

th

erefore,

all

t

he

risks

and

benefits

in

herent

to

th

e

ownership

of

the

financial

asset

are

tra

nsferred

to

another

entity.

If

the

Company

retains

substantially

al

l

the

r

isks

and

benef

its

inherent

to

the

ownership

of

the

tr

ansferred

ass

et,

it

w

ill

contin

ue

to

rec

ognize

it

a

nd

will

reco

gnize

a

liability

for

the amounts received.

2.21.2 Financial Li

abilities

Financial

liabilities

comprise

tr

ade

and

o

ther

payables,

financial

debt,

and

cert

ain

liabilities

included

in

O

ther

Liabilities.

Financial liabilities

are initially recognize

d at fair va

lue and subsequ

ently measure

d at amortized

cost. Amorti

zed

cost represents

the initial

amount

net

of

principal repayments ma

de, adjusted by

the amortization

of an

y

differences between t

he init

ial amount and the m

aturity amount us

ing the effective interest

method.

Balances

in

foreign

c

urrency

have

been

valued

as

me

ntioned

above,

at

the

ex

change

r

ates

effective

at

the

closing

of each year. The exc

hange differences

were charged to inc

ome for

each y

ear.

Derecognition of Fina

ncial Liabilities

The

Company

shall

dereco

gnize

a

financial

liability

(or

part

of

it)

when

it

has

been

extinguished,

i.e.,

when

the

obligation specified

in the correspond

ing agreement is

discharged, cance

led or expires.

2.21.3 Derivatives

Derivatives,

if

any,

are

initially

recognized

at

fair

v

alue

at

the

date

of

execution

of

the

relate

d

contract

a

nd

subsequently

measured

at

fair

value

at

the

end

of

the

reporting

year.

The

resulting

gain

or

loss

is

immed

iately

recognized

in the

statemen

t of

income

unless

the d

erivate

is des

ignated as

a

hedging

instrument,

in wh

ich c

ase

the timing for its rec

ognition will depend

on the nature

of the hedging rela

tionship.

2.22

Ot

her Liabilities

Advances

fr

om

cus

tomers

involving

obligations

to

d

eliver

assets

that

have

not

y

et

be

en

prod

uced

have

been

valued at the higher

of the amounts rec

eived or the share in

the estimated va

lue of the related ass

ets.

The other liabilities hav

e been valued at

nominal value.

2.23 Assets and Li

abilities Held for

Distribution

to Shareholders

Non-current

assets

and

liabilities

(or

disposal

grou

ps)

are

classified

as

assets

and

liabilities

held

for

distribution

to shareholders when an

entity undertakes to distribute them

to its shareholders, to the

ex

tent such distribution is

highly likely to occur a

nd they are ava

ilable for immed

iate distribution

in their then curr

ent conditions.

2.24 Consolidated Statem

ent of Cash Flow

s

For

the

purposes

of

preparing

t

he

c

onsolidated

s

tatement

of

cash

f

lows,

the

item

“Cash

and

Cash

Equiva

lents”

includes

cas

h

and

bank

ba

lances,

certa

in

high

liquidity

short

-

term

inv

estments

(with

original

maturities

shorter

than

90

days).

Bank

overdrafts

pay

able

on

demand

,

if

any,

are

deducted

to

the

ext

ent

they

are

part

of

the

Company’s cash man

agement.

Bank overdrafts are c

lassified as “Financial

Debt” in the consol

idated statement of

financial position.

GRUPO CLARÍN S.A.

-

21

-

Cash a

nd

cash

equ

ivalents

at

each

year

-end,

as

d

isclosed

in

the

conso

lidated

statement

of

cash

flows,

may

be

reconciled against the i

tems related to the co

nsolidated state

ment of financial pos

ition as follows:

December 31,

2021

December 31,

2020

Cash and Banks

2,212,622,435

1,953,352,069

Short-term

investments

with

original

maturities

shorter

than

90 days

2,071,469,690

2,253,757,788

Total

4,284,092,125

4,207,109,857

In

the

ye

ars

en

ded

Dece

mber

3

1,

202

1

and

2020,

the

following

significant

tr

ansactions

w

ere

carr

ied

out

,

whi

ch

did not have an impac

t on cash and cash e

quivalents:

December 31,

2021

December 31,

2020

Acquisition of Equity Interests Pending Settlement

162,578,209

-

Collection of trade receivables through government bonds

17,205,146

87,388,890

New right-

of

-use assets owed

57,843,393

75,342,448

Acquisition of Equity Interests through Capitalization of

Credits

130,561,020

108,342,733

Capital Contributions to a Jointly Controlled Entity through

Capitalization of Loans

58,448,201

-

Settlement of Dividends to Minority Interests through

Settlement of Debt

32,186,620

-

Collection of Trade Receivables with Other Assets

6,367,599

-

2.25 Distribution

of Dividends

The

distribution of

dividends

to

the

Com

pany’s shareholders

is

recognize

d

as a

lia

bility i

n the

fi

nancial

s

tatements

for the year in which th

e distribution of dividen

ds is approv

ed at the Shareholders

’ Meeting.

NOTE 3 - ACCOUNT

ING ESTIMAT

ES AND JUDG

MENTS

In

applying

the

accountin

g

polic

ies

desc

ribed

in

Note

2,

the

Company

has

to

make

ju

dgments

and

prepare

accounting estimates

of the value of

the assets and

liabilities that

may not be o

therwise obtaine

d. The estimates

and related assumptions ar

e based on historical experi

ence and other pertinent factors

. Actual results may differ

from these estimates.

The

underlying

est

imates

and

assum

ptions

are

co

ntinually

reviewed.

T

he

effects

of

the

reviews

of

acc

ounting

estimates are recogn

ized for the year in wh

ich estimates are rev

iewed.

These estimates basica

lly refer to:

Allowance for Bad D

ebts

The

C

ompany calculates the

allowance

for

bad debts for

debt instruments that are

not valued at

fair value,

tak

ing

into account the uncollectibility history, the opinion of its legal advisors, if any, and other circumstances

known at

the

time

of

calculation.

In

additio

n,

and

in

accordance

with

IFRS

9,

for

the

calculation

of

the

allowance

for

bad

debts on trade rece

ivables the Comp

any considers the

expected credit loss

es over their tota

l useful life.

Impairment of G

oodwill

The

C

ompany

assesses

goodwil

l

f

or

impairment

on

an

ann

ual

basis.

I

n

determining

if

there

is

i

mpairment

of

goodwill,

the

Company

ca

lculates

the

value

in

use

of

the

cash

-gen

erating

units

to

which

it

has

been

allocated.

The

calculation

of

the

va

lue

in

use

re

quires

the

determination

by

the

ent

ity

of

the

future

cash

flows

that

should

arise from the cash

-generating un

its and an appropri

ate discount rat

e to calculate

the present value.

GRUPO CLARÍN S.A.

-

22

-

Recognition and Measu

rement of Defer

red Income

Tax Items

Deferred

tax assets

are only

r

ecognized

for temporar

y differences

t

o

the extent

that i

t is

probable that

each

ent

ity,

on

an individual

basis, will

have enough

future taxable

income against

wh

ich

the

deferred tax

assets can

be used.

Tax loss carryforwards from prior

years

are only

recognized when it is probab

le that

each entity will have enough

future taxable income a

gainst which

they can be used

.

Pursuant

to

effective regulations,

the

use of

the subsidiaries’

t

ax

credits i

s based

o

n

a

projection analysis

of future

income.

The

Company

examines

th

e

recoverable

value

of

deferr

ed

tax

assets

based

on

its

business

plans

an

d

book

s

a

valuation

allow

ance,

if

appropriate,

so

tha

t

the

net

position

of

the

deferred

t

ax

ass

et

will

r

eflect

the

proba

ble

recoverable value.

Provisions for Lawsuit

s and Con

tingencies

The

elements

taken

into

consid

eration

for

the

ca

lculation

of

th

e

Provision

for

Laws

uits

an

d

Contingenc

ies

are

determined

based

on

the

pres

ent

v

alue

of

the

estimated

costs

ar

ising

from

the

lawsuits

brought

a

gainst

the

Company, taking in

to consi

deration the opinion of i

ts legal advisors.

Determination of t

he Useful Lives of

Property, Plant and

Equipment and Inta

ngible Assets

The

C

ompany

reviews

the

estimated

useful

life

of

pro

perty,

p

lant

and

equipment

and

intangible

as

sets

at

each

year-e

nd.

Measurement of

the fair value of

certain financial

instruments

The

fair value

of

a financial

instrument is

th

e am

ount

at which

the instrument

could be

purchased or

sol

d be

twe

en

knowledgeable,

willing

parties

in

an

arm

’s

length

tr

ansac

tion.

If

t

here

is

a

quote

d

market

pric

e

availabl

e

for

an

instrument in an active m

arket, the fair value is c

alculated b

ased on that price.

If

there is

no quoted

mark

et price

av

ailable for

a financial

instrument, its fai

r value is

estimated based

on the

pr

ice

established

in

recent

tra

nsactions

involving

the

same

or

similar

instruments

and,

otherwise,

based

on

valuation

techniques

regularly

used

in

financial

mark

ets.

The

Company

uses

its

judgm

ent

to

select

a

v

ariety

of

me

thods

and makes assumpti

ons based on

market conditions at

closing.

Impairment losses of certain assets

other than accounts receivable (including property, plant and

equipment and intang

ible assets)

Certain as

sets,

includ

ing pr

operty,

plant

a

nd

equipment

and

inta

ngible

assets

are

subject to

impairment testi

ng.

The

Company

records

i

mpairment

loss

es

when

it

estimates

th

at

there

is

objectiv

e

evidence

of

such

l

osses

or

when the c

ost of

such loss

es will not

be rec

overed thr

ough future cas

h flows.

The evaluati

on of w

hat constit

utes

impairment is a

matter of significant judgment. The impairment of non-financia

l assets is dealt

with in more depth

in Note 2.17.

GRUPO CLARÍN S.A.

-

23

-

NOTE 4

–

SEGM

ENT INFOR

MATION

The

Com

pany

is

mainly

engag

ed

in

media

and

ent

ertainment

activ

ities,

which

are

carr

ied

out

t

hrough

the

companies in which

it holds a pa

rticipating interest. Based on

the nature, clients, and risks invol

ved, the following

business

segments

hav

e

b

een

identified,

which

are

directly

the

way

in

which

the

Company

ass

esses

its business performance

:

−

Print

an

d

Digital

Publicatio

ns

:

mainly

comprises

the

operations

of

its

subsidiary

AGEA

a

nd

its

subsidiary

Cúspide, the printing

business of OS

A, CIMECO, and

their respective su

bsidiaries.

−

Broadcasting

and

Program

ming:

mainly

comprises

the

operations

of

its

subsidiaries

ART

EAR,

IESA

and

Radio Mitre, and their res

pective subsidiaries

, including Tel

ecor, Pol

-K

a, Auto Sports

, and Carburand

o.

−

Other: mainly comprises the operations of its

contr

olled company GCGC. Additionally, this segment includes

the Company’s own o

perations (typica

l of a ho

lding company)

.

The Company has adopted IFRS 8 - Segment Information, which def

ines operating segments as those identified

based

on

internal

reports

with

respect

to

the

compo

nents

of

the

c

ompany

r

egularly

review

ed

by

the

Board

of

Directors,

the

main

operating

decisio

ns

maker,

to

a

llocate

resourc

es

and

assess

their

performanc

e.

The

Compa

ny

uses adjusted EBITDA to

measure its performance. The Company believes that

adjus

ted EBITDA is

a significant

performance measure of

its businesses, since

it is commonly

us

ed in the

industry to analyze an

d compare media

companies

based

on

operating

performance,

in

debtedness

and

liquidity.

Howev

er,

adjusted

EBITDA

does

not

measure net

inco

me or

cas

h

flows generated

by operations and

should no

t be

cons

idered

as an

a

lternative

to net

income,

an

indicati

on

of

the

Company’s

financ

ial

p

erformance,

a

n

alternative

to

c

ash

flows

ge

nerated

by

op

erating

activities

or

a

measure

of

liquidity.

Since

a

djusted

EBITDA

is

not

defined

by

IFRS,

it

is

poss

ible

that

ot

her

companies may calculate it different

ly. Therefore, the adjusted EBITDA reported by other companies may not be

comparable to the Com

pany’s reported adjus

ted EBITDA.

The following informa

tion as of Dece

mber 31, 2021

and 2020 was

prepared in ac

cordance with

IFRS, except for

the

non-app

lication

of

IAS

29,

due

to

the

f

act

that

the

Board

of

D

irectors

analyzes

the

informat

ion

in

historic

al

currency for the busin

ess segments iden

tified by the C

ompany.

Note

1

to

these

consolid

ated

financia

l

statements

includes

additional

infor

mation

abou

t

the

Co

mpany’s

businesses.

GRUPO CLARÍN S.A.

-

24

-

Information arisi

ng from Consolida

ted Income

Statements as of D

ecember 31, 2

021

Print and Digital

Publications in

Historical

Currency

Print and

Digital

Publications

restated in

Constant

Currency

Broadcasting

and

programming

in historical

currency

Broadcasting

and

programming

restated in

constant

currency

Other in

Historical

Currency

Other restated

in constant

currency

Eliminations

(1)

Total

consolidated

results

restated in

constant

currency

Net Sales to Third Pa

rties

(2)

14,311,467,335

16,992,638,731

18,399,159,988

21,846,137,179

1,103,743,363

1,310,523,357

-

40,149,299,267

Intersegment Sale

s

30,869,442

36,652,655

47,079,459

55,899,526

1,114,782,588

1,323,630,718

(1,416,182,899)

-

Net Sales

14,342,336,777

17,029,291,386

18,446,239,447

21,902,036,705

2,218,525,951

2,634,154,075

(1,416,182,899)

40,149,299,267

Cost of sales -excludi

ng deprecia

tion and amortiz

ation

(7,705,119,556)

(9,148,629,552)

(10,143,747,121)

(12,044,120,017)

(1,306,354,189)

(1,551,092,161)

203,511,859

(22,540,329,871)

Subtotal

6,637,217,221

7,880,661,834

8,302,492,326

9,857,916,688

912,171,762

1,083,061,914

(1,212,671,040)

17,608,969,396

Expenses - exclu

ding depreciatio

n and amortizatio

n

Selling Expenses

(3,451,116,522)

(4,097,663,426)

(844,529,499)

(1,002,747,261)

(70,913,813)

(84,199,110)

101,072,427

(5,083,537,370)

Administrative Exp

enses

(2,336,127,084)

(2,773,787,106)

(2,952,606,200)

(3,505,760,052)

(941,221,615)

(1,117,554,091)

1,111,598,613

(6,285,502,636)

Adjusted EBITDA

849,973,615

1,009,211,302

4,505,356,627

5,349,409,375

(99,963,666)

(118,691,287)

-

6,239,929,390

Depreciation of Pro

perty, Plant a

nd Equipmen

t

(1,261,982,840)

Amortization of Int

angible Assets a

nd Film Library

(3)

(387,017,929)

Amortization of Ri

ght-

of

-Use Assets

(113,523,348)

Other Income a

nd Expenses, net

12,478,875

Financial Expens

es on Debt

(548,243,113)

Loss on Net Mone

tary Position

(1,308,389,870)

Other Financial Re

sults, net

(815,877,758)

Financial Results

(2,672,510,741)

Equity in Earnings

from Associates

447,594,504

Income Tax

(1,200,289,349)

Net Income for t

he Year

1,064,678,562

Additional Consoli

dated Informatio

n as of Decem

ber

31, 2021

Payments for Acquisiti

on of Propert

y, Plant and Eq

uipment

114,708,752

136,198,779

655,489,860

778,292,129

42,808,262

50,822,232

-

965,313,140

Payments for Acquisiti

on of Intangi

ble Assets

205,189,375

243,630,429

53,343,151

63,336,685

31,640,047

37,567,702

-

344,534,816

(1)

Eliminations are related t

o Grupo Cla

rín’s intercompan

y operations.

(2)

Includes also sales to

unconsolidated

companies.

(3)

Amortization of film rights

acquired i

n perpetuity, m

entioned in N

ote 2.18.

GRUPO CLARÍN S.A.

-

25

-

Information arisi

ng from Consolida

ted Income

Statements as of D

ecember 31, 2

020

Print and Digital

Publications in

Historical

Currency

Print and

Digital

Publications

restated in

Constant

Currency

Broadcasting

and

programming

in historical

currency

Broadcasting

and

programming

restated in

constant

currency

Other in

Historical

Currency

Other restated

in constant

currency

Eliminations

(1)

Total

consolidated

results

restated in

constant

currency

Net Sales to Third Pa

rties

(2)

10,970,823,460

19,332,019,916

11,187,544,493

19,713,910,605

660,794,384

1,164,405,776

-

40,210,336,297

Intersegment Sale

s

16,675,270

29,383,998

56,979,877

100,405,966

672,955,019

1,185,834,398

(1,315,624,362)

-

Net Sales

10,987,498,730

19,361,403,914

11,244,524,370

19,814,316,571

1,333,749,403

2,350,240,174

(1,315,624,362)

40,210,336,297

Cost of sales -ex

cluding deprecia

tion and am

ortization

(6,054,669,936)

(10,669,117,064)

(6,476,117,452)

(11,411,762,482)

(825,019,865)

(1,453,792,463)

46,350,539

(23,488,321,470)

Subtotal

4,932,828,794

8,692,286,850

4,768,406,918

8,402,554,089

508,729,538

896,447,711

(1,269,273,823)

16,722,014,827

Expenses - exclu

ding depreci

ation and amortizatio

n

Selling Expenses

(2,754,556,018)

(4,853,886,493)

(450,839,626)

(794,438,145)

(86,535,230)

(152,486,346)

189,175,339

(5,611,635,645)

Administrative Exp

enses

(1,702,238,617)

(2,999,566,165)

(1,929,748,063)

(3,400,467,441)

(505,987,747)

(891,616,317)

1,080,098,484

(6,211,551,439)

Adjusted EBITDA

476,034,159

838,834,192

2,387,819,229

4,207,648,503

(83,793,439)

(147,654,952)

-

4,898,827,743

Depreciation of Pro

perty, Plant a

nd Equipmen

t

(1,395,403,362)

Amortization of Int

angible Assets a

nd Film Library

(3)

(485,533,278)

Amortization of Ri

ght-

of

-Use Assets

(165,019,356)

Other Income a

nd Expenses, net

(1,842,725,857)

Financial Expens

es on Debt

(1,187,461,804)

Loss on Net M

onetary Position

(274,158,673)

Other Financial Re

sults, net

(66,726,194)

Financial Results

(1,528,346,671)

Equity in Earnings

from Associates

874,544,184

Income Tax

(1,058,298,301)

Net Loss for t

he Year

(701,954,898)

Additional con

solidated informa

tion as of Decemb

er

31, 2020

Payments for Acquisiti

on of Propert

y, Plant and Eq

uipment

159,044,559

280,257,228

185,639,620

327,121,191

37,139,972

65,445,469

-

672,823,888

Payments for Acq

uisition of Intangi

ble Assets

137,721,916

242,683,955

8,987,777

15,837,634

1,597,781

2,815,537

-

261,337,126

(1)

Eliminations are related t

o Grupo Cla

rín’s intercompan

y operations.

(2)

Includes also sales to

unconsolidated

companies

.

(3)

Amortization of film rights

acquired in

perpetuity, men

tioned in Note 2.

18.

GRUPO CLARÍN S.A.

-

26

-

NOTE 5 - BREAK

DOWN OF THE M

AIN ITEMS OF T

HE STATEMENT OF FIN

ANCIAL

POSITION

5.1

Property,

Plant and Equip

ment

Original value

Main Account

Balance at the

Beginning

Deconsolidation

of companies

(2)

Additions

Retirements

Transfers

Balances as of

December 31, 202

1

Real Property

(1)

14,567,606,401

(70,357,152)

477,638

(411,509)

59,406,845

14,556,722,223

Furniture and Fixt

ures

2,129,720,147

(24,610,881)

16,073,640

(30,166,301)

2,254,614

2,093,271,219

Telecommunicatio

n, Audio and

Video Equipment

7,616,141,453

(100,778,412)

82,525,205

(18,806)

32,659,172

7,630,528,612

Computer Equi

pment

10,058,612,899

(71,866,193)

452,340,938

(24,946,347)

(8,190,614)

10,405,950,683

Technical Equipme

nt

1,155,317,737

-

36,726,687

-

93,640,769

1,285,685,193

Workshop Machine

ry

7,936,161,520

(57,261,521)

20,239,748

(526,844,446)

(79,523,374)

7,292,771,927

Tools

14,157,850

(246,028)

7,835

-

13,919,657

Spare Parts

421,414,730

-

(8,003,153)

-

413,411,577

Installations

7,467,100,398

(97,950,410)

27,542,127

(26,458,705)

20,702,924

7,390,936,334

Vehicles

265,314,548

(1,109,150)

7,340,606

(38,336,369)

-

233,209,635

Works-

In

-Progress

271,358,630

(818,483)

321,610,842

-

(131,857,785)

460,293,204

Leasehold Impr

ovements

1,131,108,388

(51,493,244)

427,874

(110,045)

(360,516)

1,079,572,457

Allowance for Impairm

ent of

Property, Plant and

Equipment and

Obsolescence of M

aterials

(46,305,930)

-

46,305,930

-

Total as of Decem

ber 31, 2021

52,987,708,771

(476,491,474)

965,313,140

(608,989,751)

(11,267,965)

52,856,272,721

Accumulated Depre

ciation

Main Account

Balance at the

Beginning

Deconsolidation

of companies

(2)

Retirements

and Transfers

For the year

Balances as of

December 31,

2021

Net Book Value

as of December

31, 2021

Real Property

(1)

6,948,795,732

(17,982,674)

(17,139,673)

264,728,164

7,178,401,549

7,378,320,674

Furniture and Fixt

ures

1,982,356,210

(20,129,550)

(10,903,250)

33,237,065

1,984,560,475

108,710,744

Telecommunicatio

n, Audio and

Video Equipment

7,079,271,919

(89,907,536)

(5,503,865)

207,048,259

7,190,908,777

439,619,835

Computer Equi

pment

9,455,252,989

(65,716,695)

(29,842,294)

430,340,842

9,790,034,842

615,915,841

Technical Equipme

nt

1,081,927,057

-

46,146,717

1,128,073,774

157,611,419

Workshop Machine

ry

7,372,950,837

(25,155,951)

(433,416,734)

91,562,263

7,005,940,415

286,831,512

Tools

3,742,181

(212,402)

-

28,331

3,558,110

10,361,547

Spare Parts

406,721,244

-

(8,003,241)

6,962,234

405,680,237

7,731,340

Installations

6,835,370,456

(64,304,692)

(24,289,809)

151,313,668

6,898,089,623

492,846,711

Vehicles

224,516,059

(1,109,150)

(32,338,345)

10,855,706

201,924,270

31,285,365

Works-

In

-Progress

-

460,293,204

Leasehold Impr

ovements

1,003,357,660

(45,884,109)

17,729,813

19,759,591

994,962,955

84,609,502

Allowance for Impairm

ent of

Property, Plant and

Equipment and

Obsolescence of M

aterials

(25,224,199)

-

25,224,199

-

Total as of Decem

ber 31, 2021

42,369,038,145

(330,402,759)

(518,483,199)

1,261,982,840

42,782,135,027

10,074,137,694

(1) includes $1,135.13 million for the fiscal year ended December 31, 2021

, corresponding to real property retired from active use.

(2) Deconsolidation of UNIR and Bariloche TV - Note 12.

GRUPO CLARÍN S.A.

-

27

-

Original value

Main Account

Balance at the

Beginning

Additions

Retirements

Transfers

Balances as of

December 31, 202

0

Real Property

(1)

12,971,750,09

4

12,998,565

-

1,582,857,742

14,567,606,401

Furniture and Fixt

ures

2,127,875,729

1,871,130

(26,712)

-

2,129,720,147

Telecommunicatio

n, Audio and Vi

deo Equipme

nt

7,596,468,006

38,130,468

(18,457,021)

-

7,616,141,453

Computer Equi

pment

9,781,650,684

333,662,549

(53,927,752)

(2,772,582)

10,058,612,899

Technical Equipme

nt

1,147,608,357

8,327,868

(618,488)

-

1,155,317,737

Workshop Machine

ry

7,702,372,870

8,574,930

-

225,213,720

7,936,161,520

Tools

3,810,069

12,697,268

(2,349,487)

-

14,157,850

Spare Parts

421,414,730

-

421,414,730

Installations

7,421,837,813

33,386,395

(7,891,499)

19,767,689

7,467,100,398

Vehicles

285,908,521

7,080,964

(27,674,937)

-

265,314,548

Works-

In

-Progress

2,011,784,490

188,965,723

(66,271,555)

(1,863,120,028)

271,358,630

Leasehold Impr

ovements

1,110,807,533

27,128,028

(15,616,098)

8,788,925

1,131,108,388

Allowance for Impairm

ent of Proper

ty, Plant and

Equipment and Ob

solescence of Ma

terials

(74,845,026)

-

28,539,096

-

(46,305,930)

Total as of Decem

ber 31, 2020

52,508,443,87

0

672,823,888

(164,294,453)

(29,264,534)

52,987,708,771

Accumulated Depre

ciation

Main Account

Balance at the

Beginning

Retirements

and Transfers

For the year

Balances as of

December 31,

2020

Net Book Value

as of December

31, 2020

Real Property

(1)

6,724,490,312

-

224,305,420

6,948,795,732

7,618,810,669

Furniture and Fixt

ures

1,946,355,773

(26,724)

36,027,161

1,982,356,210

147,363,937

Telecommunicatio

n, Audio and Vi

deo Equipme

nt

6,867,582,041

(5,261,925)

216,951,803

7,079,271,919

536,869,534

Computer Equi

pment

8,978,700,515

(55,164,776)

531,717,250

9,455,252,989

603,359,910

Technical Equipme

nt

1,056,940,764

-

24,986,293

1,081,927,057

73,390,680

Workshop Machine

ry

7,245,988,695

-

126,962,142

7,372,950,837

563,210,683

Tools

3,691,062

-

51,119

3,742,181

10,415,669

Spare Parts

385,088,706

-

21,632,538

406,721,244

14,693,486

Installations

6,673,323,528

(5,786,788)

167,833,716

6,835,370,456

631,729,942

Vehicles

227,816,844

(20,117,613)

16,816,828

224,516,059

40,798,489

Works-

In

-Progress

-

271,358,630

Leasehold Impr

ovements

990,855,336

(15,616,768)

28,119,092

1,003,357,660

127,750,728

Allowance for Impairm

ent of Proper

ty, Plant and

Equipment and Ob

solescence of Ma

terials

(41,169,246)

15,945,047

-

(25,224,199)

(21,081,731)

Total as of Decem

ber 31, 2020

41,059,664,33

0

(86,029,547)

1,395,403,362

42,369,038,145

10,618,670,626

(1) includes $1,146 million for the fiscal year ended December 31, 2020

, corresponding to real property retired from active use.

The following table deta

ils the average ye

ars of useful life of the

items

compr

ising Property,

Plant and

Equipment:

Item

Average

Useful Life

(in years)

Real Property

50

Furniture and Fixt

ures

10

Telecommunicatio

n, Audio and Vi

deo Equipme

nt

between 3 and 4

External Network

and Broadcasting

Equipment

between 3 and 20

Computer Equi

pment

3

Technical Equipme

nt

between 4 and 10

Workshop Machine

ry

10

Tools

5

Spare Parts

5

Installations

between 3 and 10

Vehicles

5

Plots

5

Leasehold Impr

ovements

between 3 and 10

GRUPO CLARÍN S.A.

-

28

-

5.2 Intangible Assets

Original value

Main Account

Balance at the

Beginning

Acquisition of

Businesses

(2)

Deconsolidation

of

companies

(1)

Additions

Retirements

Transfers

Balances as of

December 31,

2021

Exploitation Rights

and Licenses

259,533,153

-

259,533,153

Exclusivity Agreeme

nts

464,799,306

-

(100,720,305)

-

364,079,001

Other Rights

1,217,665,330

-

12,200,051

-

1,229,865,381

Acquisition Valu

e of Subscriber Por

tfolio

109,029,839

-

(109,029,839)

-

Software

3,912,791,129

-

(34,047,433)

150,048,291

(131,396,878)

60,216,553

3,957,611,662

Trademarks and Pa

tents

430,505,547

-

(632,014)

4,967,535

(224,642,313)

-

210,198,755

Projects in-Progr

ess

215,585,178

-

(29,160,867)

177,318,939

-

(48,948,588)

314,794,662

Other

1,024,686,813

183,953,025

-

(653,744)

-

1,207,986,094

Allowance for Impairm

ent of Intangi

ble

Assets

(516,342,135)

-

516,342,135

-

Total as of Decem

ber 31, 2021

7,118,254,160

183,953,025

(63,840,314)

344,534,816

(50,100,944)

11,267,965

7,544,068,708

Accumulated Depre

ciation

Main Account

Balance at the

Beginning

Acquisition of

Businesses

(2)

Deconsolidation

of

companies

(1)

Retirements

and

Transfers

For the year

Balances as

of December

31, 2021

Net Book Value

as of December

31, 2021

Exploitation Rights

and Licenses

259,533,153

-

259,533,153

-

Exclusivity Agreeme

nts

427,172,891

-

(99,377,389)

13,700,957

341,496,459

22,582,542

Other Rights

1,115,272,762

-

88,717,471

1,203,990,233

25,875,148

Acquisition Valu

e of Subscriber Por

tfolio

109,029,839

-

(109,029,839)

-

Software

3,599,803,690

-

(28,172,751)

(122,421,604)

234,001,620

3,683,210,955

274,400,707

Trademarks and Pa

tents

199,212,351

-

(632,011)

(8,520,770)

6,007,009

196,066,579

14,132,176

Projects in-Progr

ess

-

314,794,662

Other

1,004,660,833

-

(1,756,420)

43,515,868

1,046,420,281

161,565,813

Allowance for Impairm

ent of Intangi

ble

Assets

(287,421,164)

-

287,421,164

-

Total as of Decem

ber 31, 2021

6,427,264,355

-

(28,804,762)

(53,684,858)

385,942,925

6,730,717,660

813,351,048

(1) Deconsolidation of UNIR and Bariloche TV - Note 12.

(2) Acquisition of URBANO

–

Note 12.

Original value

Main Account

Balance at the

Beginning

Additions

Retirements

Transfers

Balances as of

December 31,

2020

Exploitation Rights

and Licenses

258,720,593

812,560

-

259,533,153

Exclusivity Agreeme

nts

464,799,306

-

464,799,306

Other Rights

1,210,977,487

6,687,843

-

1,217,665,330

Acquisition Valu

e of Subscriber Por

tfolio

109,029,839

-

109,029,839

Software

3,729,668,141

154,697,344

-

28,425,644

3,912,791,129

Trademarks and Pa

tents

425,796,200

4,709,347

-

430,505,547

Projects in-Progress

120,316,256

94,430,032

-

838,890

215,585,178

Other

1,024,686,813

-

1,024,686,813

Allowance for Im

pairment of Int

angible

Assets

(531,855,738)

-

15,513,603

-

(516,342,135)

Total as of Decem

ber 31, 2020

6,812,138,897

261,337,126

15,513,603

29,264,534

7,118,254,160

Accumulated Depre

ciation

Main Account

Balance at the

Beginning

Retirements and

Transfers

For the year

Balances as of

December 31,

2020

Net Book Value

as of December

31, 2020

Exploitation Rights

and Licenses

197,529,159

-

62,003,994

259,533,153

-

Exclusivity Agreeme

nts

413,471,934

-

13,700,957

427,172,891

37,626,415

Other Rights

1,028,080,895

-

87,191,867

1,115,272,762

102,392,568

Acquisition Valu

e of Subscriber Por

tfolio

109,029,839

-

109,029,839

-

Software

3,297,449,399

2,101,108

300,253,183

3,599,803,690

312,987,439

Trademarks and Pa

tents

181,820,639

-

17,391,712

199,212,351

231,293,196

Projects in-Progress

-

215,585,178

Other

1,000,969,443

-

3,691,390

1,004,660,833

20,025,980

Allowance for Impairm

ent of Int

angible

Assets

(287,421,164)

-

(287,421,164)

(228,920,971)

Total as of Decem

ber 31, 2020

5,940,930,144

2,101,108

484,233,103

6,427,264,355

690,989,805

GRUPO CLARÍN S.A.

-

29

-

The following is a deta

il of the average num

ber of years

over which

int

angible assets items

are amortized:

Item

Amortization

Period

(in years)

Exploitation Rights

and Licenses

between 2 and 20

Exclusivity Agreeme

nts

between 5 and 15

Other Rights

between 5 and 20

Acquisition Valu

e of Subscriber Por

tfolio

10

Software

between 3 and 5

Trademarks and Pa

tents

between 3 and 10

Other

between 3 and 20

5.3 Goodwill

The Com

pany

assesses

the

recoverabi

lity

of go

odwill

consider

ing

each c

ompany

for

which

it

records

goodw

ill

as a different cash-

generating unit (“CG

U”).

The

recoverable

a

mount

of

each

CGU

has

been

det

ermined

as

per

its

value

in

us

e,

calculated

based

on

op

erating

cash

flows

estimated

in

the

financial

budget

s

approved

by

Manageme

nt,

which

compr

ise

a

period

ranging

from

one

t

o

three

years.

Cash

flows

not

included

in

those

periods

are

pr

ojected

using

a

growth

rate,

assessed based

on statistical dat

a and histor

ical indicators of Arg

entina, which

does not exc

eed the l

ong

-term

average growth of

each business.

The gros

s

margin us

ed

in e

ach

case

for

the calcu

lation

of

the

value

in

use

allocated

to

each

CGU

arises

from

budgets prepared

by each business for

th

e period under consideration, which

are

in l

ine with the

historical data

and the expectations re

garding market

development and evo

lution of the resp

ective businesses

.

The

discount

rate

used

i

n

each

case

for

the

calcul

ation

of

th

e

value

in

use

a

llocated

to

each

C

GU

tak

es

into

account

t

he

r

isk

-free

rate

,

t

he

c

ountry

risk

premium

and

the

premium

for

risks

s

pecific

to

e

ach

business,

and

the

indebtedness

s

tructure

of

each

CGU.

In particu

lar,

the a

nnual

real

disc

ount

rate

applied

to

the

proj

ections

of I

mpripost’s

and

P

atagonik's

c

ash fl

ows

is

of

approx

imately

15.9%

a

nd

12.9%,

res

pectively.

The

goo

dwill

of

those companies

corresponds

to interests

in joint ventures, w

hich are d

isclosed under “Investm

ents in

Unconsolidated Affi

liates” (Note 5.4).

Main Account

Net Balances

As of December

31, 2021

Net balances a

s

of December 31,

2020

Other

27,489,881

33,317,875

Total

27,489,881

33,317,875

GRUPO CLARÍN S.A.

-

30

-

5.4. Investm

ents in

Unco

nsolidated A

ffiliat

es

Main business act

ivity

Country

Interest (%)

(1)

Value

Recorded as

of December

31, 2021

Value

Recorded as

of December

31, 2020

Included in ass

ets

Interest in Associat

es

Papel Prensa

Manufacturing of

Newsprint

Argentina

49.00

1,856,348,856

(1)

1,623,939,13

2

Urbano

Postal service

s

Argentina

30.00

129,986,236

(2)

-

Other Investmen

ts

53,991,518

77,795,948

Interests in Joi

nt

Ventures

TSC

Exploitation of

events television

broadcasting righ

ts

Argentina

-

(3)

27,198,473

TRISA

Production and e

xploitation of spo

rts

events, adverti

sing agency and

financial and in

vesting operations

Argentina

50.00

1,697,120,713

1,571,726,14

2

Canal Rural

Audiovisual produ

ction and sale of

advertising

Argentina

64.99

95,622,209

78,448,909

Impripost

Variable printing

Argentina

50.00

133,169,349

114,678,776

AGL

Printing

Argentina

50.00

82,692,278

108,969,798

BIMO

Provision of Elec

tronic Payment

Services

Argentina

50.00

102,939,463

163,926

Exponenciar

Organization, holdin

g, production a

nd

commercial exploi

tation of exhibitio

ns

and events, and

/or promotion and/o

r

advertising for

the purposes of

promoting variou

s activities

Argentina

50.00

39,889,673

86,787,322

Ríos de Tinta

Editorial activities

Mexico

50.00

136,123,045

134,281,526

Patagonik

Film producer

Argentina

33.33

171,520,065

234,265,820

Other Interests

in Joint

Operations

400,000

-

4,499,803,405

4,058,255,77

2

(1)

Equity participation in ca

pital and vote

s.

(2)

See Note 12.

(3)

In October 2021, the sha

reholders of T

SC approved the e

arly dissolution

of that com

pany.

Equity in Earnings from A

ssociates

December

31, 2021

December 31,

2020

Papel Prensa

232,404,310

40,320,248

TRISA

253,788,071

701,771,695

AGL

(26,557,189)

(21,092,697)

Canal Rural

55,962,108

33,831,507

Ríos de Tinta

40,758,876

14,453,597

Impripost

18,490,599

70,890,555

BIMO

(1)

(167,995,031)

-

URBANO

(1)

20,800,000

-

Other Companies

19,942,760

34,369,279

447,594,504

874,544,184

(1) See Note 12.

GRUPO CLARÍN S.A.

-

31

-

The

following

is

a

de

tail

of

c

ertain

supplementary

information

req

uired

by

IFRS

a

bout

interests

in

associates

(amounts stated in m

illions of Argentine

pesos):

December 31,

2021

December 31,

2020

Dividends recei

ved

6

Summarized finan

cial information:

Current Assets

5,871

3,022

Non-Cur

rent Assets

5,620

5,040

Current Liabilitie

s

4,955

3,481

Non-Cur

rent Liabilities

2,258

1,218

Revenues

18,672

8,240

Net (Loss) fro

m Continuing Operat

ions

(359)

(62)

Total Comprehen

sive (Loss)

(359)

(62)

The following is a deta

il of certain supp

lementary informati

on required by IFRS

about interests

in joint

operations (amounts s

tated in millions

of Ar

gentine pesos)

:

December 31,

2021

December 31,

2020

Dividends recei

ved

167

160

Summarized finan

cial information:

Assets

Cash and Ca

sh Equivalents

2,926

2,827

Other Curren

t Assets

4,137

3,113

Current Assets

7,063

5,940

Non-Cur

rent Assets

1,484

1,977

Liabilities

Current Financial

Debt

80

183

Other Curren

t Liabilities

3,203

2,949

Current Liabilitie

s

3,283

3,132

Non-Cur

rent Financial Debt

267

-

Other Non-Cu

rrent Liabilities

260

349

Non-Cur

rent Liabilities

527

349

Revenues

10,810

11,058

Depreciation and

Amortization

(194)

(234)

Interest Income

72

38

Interest on Financ

ial Debt

(28)

(18)

Income Tax

(181)

(961)

Net Income from

Continuing Opera

tions

187

1,609

Total Comprehen

sive Income

187

1,609

5.5 Other Investment

s

December 31,

2021

December 31,

2020

Non-Current

Securities

3,167,211

20,283,401

3,167,211

20,283,401

Current

Financial Instruments

413,740,735

905,888,214

Securities

17,699,844

680,701,648

Mutual Funds

1,657,728,955

1,347,869,574

2,089,169,534

2,934,459,436

GRUPO CLARÍN S.A.

-

32

-

December 31, 2021

December 31, 2020

Non-Current

Film Products and Rights

167,068,347

35,367,614

167,068,347

35,367,614

Current

Raw Materials and Supplies

662,065,986

889,418,918

Finished Goods

370,751,121

540,383,231

Film Products and Rights

1,594,235,891

283,207,038

Subtotal

2,627,052,998

1,713,009,187

Less: Allowance for Impairment of Inventories

(Note 5.17)

(44,745,313)

(32,038,663)

2,582,307,685

1,680,970,524

5.7 Other Assets

December 31, 2021

December 31, 2020

Non-Current

Works of Art

10,247,240

11,834,695

Other

70,085,901

56,692,170

80,333,141

68,526,865

Current

Other

276,875,849

170,206,534

276,875,849

170,206,534

5.8 Other Receivables

December 31, 2021

December 31, 2020

Non-Current

Tax Credits

114,405,407

141,874,612

Deposits in Guarantee

15,981,421

21,570,639

Advances

1,125,762

1,699,244

Related Parties (Note 15)

569,481

6,340

Other

1,443,657

2,385,286

Allowance for Other Bad Debts (Note 5.17)

(4,633,699)

(6,140,937)

128,892,029

161,395,184

Current

Tax Credits

1,897,037,700

2,413,985,103

Court-ordered and Guarantee Deposits

22,836,926

25,149,330

Prepaid Expenses

70,068,853

132,618,829

Advances

430,933,129

377,778,135

Related Parties (Note 15)

158,683,537

122,535,888

Sundry Receivables

23,332,825

35,750,763

Other

120,207,497

145,317,609

Allowance for Other Bad Debts (Note 5.17)

(43,890,452)

(69,250,378)

2,679,210,015

3,183,885,279

GRUPO CLARÍN S.A.

-

33

-

5.9 Trade Receivabl

es

December 31,

2021

December 31,

2020

Non-Current

Trade Credits

-

10,880,739

-

10,880,739

Current

Trade Credits

11,131,226,589

11,640,198,304

Related Parties (Note 15)

664,267,623

947,533,751

Allowance for Bad Debts (Note 5.17)

(524,875,859)

(699,285,456)

11,270,618,353

11,888,446,599

5.10 Cash and Ban

ks

December 31,

2021

December 31,

2020

Cash and Imprest Funds

29,123,542

27,102,237

Banks

2,183,498,893

1,926,249,832

2,212,622,435

1,953,352,069

5.11. Provisions and Ot

her Charges

December 31,

2021

December 31,

2020

Non-Current

Provisions for Lawsuits and Contingencies (Note 5.17)

1,639,533,798

1,586,228,427

Accrual for Asset Retirement (Note 5.17)

41,609,383

48,461,879

1,681,143,181

1,634,690,306

5.12 Financial Debt

December 31,

2021

December 31,

2020

Non-Current

Financial Debt

64,906,889

2,128,492,661

For Acquisition of Equipment

21,904,857

44,591,037

86,811,746

2,173,083,698

Current

Bank Overdraft

170,345,364

178,329,795

Financial Debt

1,336,159,065

152,756,225

For Acquisition of Equipment

40,215,239

29,543,013

Related Parties (Note 15)

-

25,791,278

Interest and Restatement

57,248,982

26,158,568

1,603,968,650

412,578,879

GRUPO CLARÍN S.A.

-

34

-

The following table deta

ils the changes

in loans and in

debtedness for the y

ear ended December 31

, 2021 and

2020:

2021

2020

Balances as of January 1

2,585,662,577

3,845,435,681

New Loans and Financing

(1)

602,186,212

1,408,887,079

Accrued Interest

144,831,520

385,221,707

Exchange rate fluctuations

376,433,149

784,174,986

Inflation Adjustment, Cumulative Translation Adjustment and

Other Movements

(928,215,563)

(973,565,095)

Deconsolidation of Subsidiaries - Note 12

(144,078,585)

-

Payment of Interest

(102,402,112)

(420,668,318)

Payment of Principal

(843,636,802)

(2,443,823,463)

Balances as of December 31

1,690,780,396

2,585,662,577

(1)

Mostly loan

s for the pay

ment of debt

with upcoming

maturity, and

for the purcha

se of capital a

ssets and invento

ries.

The following table su

mmarizes the mat

urities of conso

lidated loans (undiscou

nted values) at

year

-end:

Due

Non-Cur

rent Financial Debt

From 1 to 2

years

From 2 to 3

years

From 3 to 4

years

From 4 to 5

years

Over 5

years

Total Non-

Current

Financial Debt

-

25,962,757

12,981,378

12,981,376

64,906,889

For Acquisition

of Equipment

21,904,857

-

21,904,857

Total as of Dece

mber 31,

2021

21,904,857

25,962,757

12,981,378

12,981,376

86,811,746

Due

Current Financial

Debt

Up to 3

months

From 3 to 6

months

From 6 to 9

months

From 9

months

to 1 year

Total Current

Bank Overdraf

t

170,345,364

-

170,345,364

Financial Debt

575,530,109

500,956

410,880,000

349,248,000

1,336,159,065

Loans - Interest and

Restatement

56,762,820

486,162

-

57,248,982

For Acquisition

of Equipment

10,197,502

9,307,439

9,982,073

10,728,225

40,215,239

Total as of Dece

mber 31,

2021

812,835,795

10,294,557

420,862,073

359,976,225

1,603,968,650

The following are the m

ain items of the

Group's

financial debt:

5.12.1

AGEA and subsidia

ries

As of

December 31, 2021,

DLA and

LVI executed overdraft facility

agreements with banks for

u

p to

$ 90

million

and $ 70 million, respectively, which accr

ue interest at an annual fixed nominal rat

e of between 37% and 39%.

On September

5,

2019,

LVI ex

ecuted

a

loan

agreemen

t with J

P Morg

an Chase

Ba

nk, NA

(“JPM”)

for U

S$ 4.5

million.

As

of

D

ecember

3

1,

2021,

JPM

made

a

disburs

ement

of

US$

4

m

illion

under

the

loan.

Said

loan

accrues

interest at

an

annual

rate e

quivalent t

o LIBOR

plus

0.9%

on

the o

utstanding

amo

unt of

the

loan,

payable

on a

quarterly basis. Princ

ipal is due at maturity

, i.e. on July 31, 2022

.

On

O

ctober

2

2,

2019,

AG

EA

executed

a

loan

agreem

ent

w

ith

J

PM

f

or

US$

4.5

million

due

on

July

31,

20

22.

During

fiscal

y

ear

20

19,

JPM

disbursed

the

full

lo

an

amount.

Said

loan

accrues

interest

at

an

annu

al

rat

e

equivalent

to

LIBOR

plus

0.9%

on

the

o

utstanding

a

mount

o

f

the

lo

an,

paya

ble

on

a

quarterly

basis.

As

of

December 31, 2021,

AGEA prepaid principal in

the amount of US$ 444,000, of

whi

ch US$ 320,000

was

settled

during this year.

On

Dece

mber

19,

2019,

LVI

executed

a

loan

agree

ment

with

J

PM

for

U

S$

1.5

million.

As

of

December

31,

2021, JPM ma

de a d

isbursement

of US$

1 million und

er the lo

an. Said lo

an accrues

interest at a

n annual

rate

equivalent

to

LIBOR

plus

0.9%

on

the

outstanding

amount

of

the

loan,

p

ayable

o

n a

qu

arterly

basis.

Princ

ipal

is due at maturity, i.e.

on December 31, 202

2.

On

February

4,

2020,

DLA

executed

a

l

oan

agre

ement

with

J

PM

f

or

US$

0.9

million.

Dur

ing

fiscal

year

2020,

JPM

disbursed

the full

loan am

ount.

S

aid

loan

accrues

interest at

an

annual

rate equivalent

to

L

IBOR

plus

0.9%

GRUPO CLARÍN S.A.

-

35

-

on

the outstanding amount of

the loan,

payable on a

qu

arterly ba

sis. Principal is

due at

ma

turity, i.e.

on Jul

y 31,

2022.

On

May

8,

20

20,

LVI

entere

d

into

a

loan

agreem

ent

wit

h

Banco

de

Córd

oba S

.A.

for

$

5

m

illion,

with

a 12-mont

h

term,

which

acc

rues

interes

t

on

a

monthly

b

asis

at

a

fixed

annual

rat

e

of

29%.

Principal

and

interest

were

payable

in

9

consecu

tive

m

onthly

insta

llments.

Those

i

nstallments

w

ere fully

settled

as

of

J

une

30,

2021.

During

this year, the Company s

ettled installments of

principal in t

he amount of $ 2.8

million.

On November

19,

2020 and

December 17,

2020,

within

the framew

ork of

the Emergenc

y Assistance

Program

for

Work

an

d

Productio

n,

B

anco

Santand

er

Rio

S.A. g

ranted

DLA

loans

at

subs

idized

rate

for

the

paym

ent

o

f

salaries

for

$

2.5

million

and

$

2.

7

million

,

respectivel

y.

Principal

and

inter

est

ar

e

payable

in

12

c

onsecutiv

e

monthly

insta

llments.

The

first

installment

was

due

in

Febr

uary

a

nd

Apr

il

2021,

r

espectively.

During

this

year,

the Company settled

installments of pri

ncipal in the am

ount of $ 4.2 million.

On

January

8,

202

1,

within

the

fra

mework

of

the

Emer

gency

Assistance

Program

for

Work

and

Production

,

Banco

G

alicia

S.A.

granted

Cúspide

loans

at

subsidize

d

rate

for the

payment

of

salaries

for $

6

million.

Princip

al

and

interest

ar

e

pay

able

in

12

consecutiv

e

monthly

installments.

The

first

installment

was

due

in

April

2

021.

During this period, the

Company settled inst

allments

of principa

l in the amount of $ 4 m

illion.

On

September

30,

2021,

AGEA

executed

a

loan

agreement

with

First

Overseas

Bank

Limited

(“FOBAL”)

for

US$

1.

6

m

illion

due

on

December

3

0,

20

27.

Th

e

loan

accrues

interes

t

at

an

annual

r

ate

of

8%

on

the

outstanding

amount

of

the

loan.

The

first

princ

ipal

i

nstallment

was

due

on

December

30,

202

1

for

a

total

of

US$ 800,000. The ou

tstanding bala

nce will be repaid in six e

qual, annual an

d consecutive insta

llments.

5.12.2

GCGC and Subsidiari

es

On

February

26,

2018,

GCG

C

executed

a

loan

agre

ement

with

Banco

Santander

Rio

S.A.

for

$

2.5

m

illion

to

purchase hardware for di

gitalization. It had a term of 3

6 (

thirty-six) months

. The amount of the loan was r

epaid

in

12

(twelve)

equal

qu

arterly

installments,

and

accrue

d

interest

at

th

e

average

Badlar

rate

f

or

Private

Banks

plus 4.5%. Such loan w

as repaid in full dur

ing this year

.

On

March

13,

2

018,

GCGC

executed

a

loan

agr

eement

w

ith

Banco

Sa

ntander

Rio

S.A.

f

or

$

2

million

to

purchase hardware for di

gitalization. It h

ad a term of 36 (

thirty-six) months

. The amount of the loan was r

epaid

in

12

(twelve)

equal

qu

arterly

installments,

and

accrued

interest

at

the

average

Badlar

rat

e

for

Private

Banks

plus 4.5%. Such loan w

as repaid in full dur

ing this year

.

On September 5,

2019, GC

GC execute

d a loan

agreement with J

P Morgan

Chase Bank

NA for US$

3 millio

n,

due

on

July 31,

20

22.

Said loan

accrues

interest at

a rate

eq

uivalent

to LIBOR

p

lus 0.9%.

Such loan

w

as

repaid

in full during this year.

On

October

22,

2019,

GC

execut

ed

a loan

agree

ment

with

JP M

organ

Ch

ase

Bank

NA (

“JPM”)

for

US$

1

million,

due

on

J

uly

31,

2022.

Sa

id

loan

acc

rues

interest

at

a

rate

equ

ivalent

to

LIBOR

p

lus

0.9%.

Such

loan

was repaid in full durin

g this year.

On

January

13,

2020,

GCGC

execute

d

a

loan

agreement

wit

h

JP

Morgan

Chase

Bank

NA

(“

JPM”)

f

or

US$ 800,000, due on Dece

mber 31, 2022. Said loan accrues interest at a rate equivalent to LIBOR p

lus 0.9%.

Such loan was repa

id in full during this y

ear.

During

December

20

20,

GCG

C

and

Banco

Itaú

Argentin

a

S.

A.

entered

in

to

a

lease

-purchase

a

greement

for

computing eq

uipment for

$ 26.7

million.

Such lo

an accrued

interest

at an an

nual nomi

nal rate o

f 41.5%

on the

outstanding balance

as from January

1, 2021, and is

payable in 24 consecu

tive installme

nts.

During

December

2021,

GCGC

and

Banco

Itaú

Argentina

S.A.

entered

into

two

new

lease

-purchase

agreements

for

c

omputing

equipment f

or

$

29.

4

million.

Such

loans

accr

ue

interest

at an

annual

nominal

r

ate

of 41.5% and 41.75% o

n the outstanding ba

lances, and are p

ayable in 24 consecutive insta

llments.

As of

the

date

of

t

hese

financial

stat

ements,

the

Co

mpany

had

r

epaid

the

full

amo

unt

of

princ

ipal

and

interest

accrued thereon.

5.12.3

ARTEAR

On

June

7,

2019,

ARTEAR

and

Banco

de

Galicia

y

Buenos

Aires

S.

A.U.

ex

ecuted

an

agreement

wh

ereby

ARTEAR

is

the

borrower

u

nder

a

bilateral

loan

for

a

princip

al

amount

of

US$

2.5

million,

payab

le

in

a

single

GRUPO CLARÍN S.A.

-

36

-

installment a

t

maturity,

i.e.

on

April

1,

2020.

Pr

incipal

accr

ues interest

at

a

fixed

annual

rate

of

8.25%

paya

ble

at maturity. On April

1, 2020, ARTEAR m

ade a full repay

ment of the loan.

On

June

7,

2

019,

ARTEAR

and

Industrial

and

Commercial

Bank

of

Ch

ina

(

Argentina)

S.A.

ex

ecuted

an

agreement

wh

ereby

ARTEAR

is

the

borrower

under

a

bilateral

loan

f

or

a

principal

amount

of

US$

2

.5

million

,

payable in a single installment

at maturity

, i.e. on April 1,

2020. Principal accrues interest at a fixed annual rate

of 8.5% payable at mat

urity. On April

1, 202

0, ARTEAR mad

e a full repayme

nt of the loan.

On

July

5,

2019,

Pol-ka

Producciones

S.A.

and

I

ndustrial

and

Commercial

Bank

of

China

(

Argentina)

S.

A.

executed

an

agre

ement

wh

ereby

Pol

-ka

Prod

ucciones

S.A.

is

the

borrower

under

bilateral

lo

an

for

a

pri

nci

pal

amount

of

US

$

200,000,

payable

in

a

s

ingle

install

ment

at

m

aturity,

i.e.

on

D

ecember

30,

2019

.

Principal

accrued interest at a fixed annual rate of 7.55%

pay

able at maturity. On January 2, 2020, Pol

-ka Produc

ciones

S.A. made a full repaym

ent of the loa

n.

5.12.4

IESA and Subsidia

ries

On December 20,

2019, IESA executed a loan

agreem

ent with JP

Morgan Chase Bank NA

for US$ 1.5 million,

due

o

n

December

3

1,

2022.

Sa

id

loan

accrues

in

terest

at

a

rate

e

quivalent

to

LIBOR

plus

0.9%

.

Interest

i

s

calculated on outsta

nding bala

nces and is payab

le on a quarterly b

asis.

5.12.5

Radio Mitre

As of

December

31,

2021,

Radio

Mitre holds

a repo

as

c

ollateral

in

the

amount

o

f

$

72

million.

It

was

a

s

hort

-

term transac

tion,

which

as

of

that

dat

e acc

rued

interest

at

an

annual

avera

ge ra

te

of

39.06%.

As

col

lateral f

or

the

loan,

Frecuencia

Produc

ciones

Publicitarias

S.

A.

holds

an

investm

ent

of

US$

0.6

mi

llion

in

the

com

pany

with which Radio Mitr

e executed the tra

nsaction.

In addition, as

of July 16, 2021, Radio Mitre was granted a new

r

epo as collateral in

the amount of $ 70 million.

It was a

short-term transaction, which accrues interest at

an annual average rate of 32.9%. As

collateral for the

loan, Grupo Clarín holds an i

nvestm

ent of US$ 0.5 million

in the company with which Radio Mitre executed the

transaction.

As

of

Decem

ber

31,

2021,

Radio

Mitre

holds

a

loan

with

Banco

Santan

der

a

t

s

ubsidize

d

rate.

The

princ

ipal

amount of that l

oan is $5.6

million, pay

able in 12 mo

nthly installments

at an an

nual nominal r

ate of 27%.

As of

the

date

of

th

ese

f

inancial

s

tatements, the

Company

had

repaid

the

full

amo

unt

of principal

and

interest

accrued

thereon.

5.13 Taxes Payab

le

December 31,

2021

December 31,

2020

Non-Current

Taxes Payable on a National Level

7,431,689

1,422,661

Taxes Payable on a Provincial Level

-

20,378,304

7,431,689

21,800,965

Current

Taxes Payable on a National Level

422,727,760

1,447,894,458

Taxes Payable on a Provincial Level

26,956,357

19,440,534

Taxes Payable on a Municipal Level

8,373,647

9,079,372

458,057,764

1,476,414,364

GRUPO CLARÍN S.A.

-

37

-

5.14 Other Liabilities

December 31,

2021

December 31,

2020

Non-Current

Deposits in Guarantee

207,440

3,019

Call Options (Note 10)

307,560,000

381,052,154

Other

6,423,479

6,272,071

314,190,919

387,327,244

Current

Advances from Customers

800,522,817

552,898,933

Related Parties (Note 15)

11,191,879

8,816,095

Revenues to be Accrued

471,437,178

550,285,414

Other

282,267,529

248,625,685

1,565,419,403

1,360,626,127

5.15 Trade and Oth

er Payables

December 31,

2021

December 31,

2020

Non-Current

Suppliers and Trade Provisions

4,507,150

-

Employer’s Contributions

23,198,833

55,214,504

27,705,983

55,214,504

December 31,

2021

December 31,

2020

Current

Suppliers and Trade Provisions

6,528,065,987

6,521,806,891

Related Parties (Note 15)

300,341,331

302,424,494

Employer’s Contributions

3,304,634,529

3,356,497,282

10,133,041,847

10,180,728,667

5.16 Right-

of

-

Use Assets and Leas

e Liabilities

Certain controlled companies have real property lease agreements, which

pursuant to IFRS 16

(see Note 2.3

),

have

been

reco

gnized

wit

h

the

si

mplified

retrosp

ective

a

pproach

cons

idering

the

acc

umulated

e

ffect

of

th

e

application

as from

January

1,

2019, without

restat

ing

the information

pres

ented for

comparat

ive

purposes. The

Company

recognized

right

-

of

-us

e ass

ets

for the

amo

unt

of

lease

liabilities

as

of

the

date

of

adoption

(equal

to

the present value of the remai

ning lease payments

, which have been d

iscounted at an average

borrowing rate

of

53.82%

f

or

agree

ments

denominated

in

Argentin

e

pesos

and

7.6

8%

for

a

greements

denominate

d

in

U.

S.

Dollars), adjusted by th

e amount of any pre

paid or accr

ued lease payment as of

December 31,

2018.

During

2020

and

2019,

the

Company

a

nd

certai

n

controlled

companies

exec

uted

lease agre

ements

w

h

ich,

i

n

accordance with IFRS

16, have been rec

ognized as from the d

ate of execution of

the agreement.

Right-

of

-use assets

and

leas

e

liabil

ities

re

lated

to

the

above

-mentioned

agreeme

nts

are

disclosed i

n

a

sep

arate

item

of

Assets

an

d

Liabi

lities,

resp

ectively,

in

the

Conso

lidated

S

tatement

of

Financ

ial

Position.

The

amortization of thos

e assets is disclose

d under Amorti

zation of Right

-

of

-Use Assets

.

The following table sho

ws the changes

in the item righ

t

-

of

-use ass

ets:

2021

2020

Balances as of January 1

125,590,589

193,409,800

Additions

57,843,393

108,342,733

Retirements

(1)

-

(11,142,588)

Amortization

(113,523,348)

(165,019,356)

Balances as of December 31

69,910,634

125,590,589

(1)

Included under Other Income and Exp

enses, net in the

co

nsolidated Statement

of Comprehensive Income.

GRUPO CLARÍN S.A.

-

38

-

The following is the evol

ution of Lease Liab

ilities:

2021

2020

Balances as of January 1

130,573,773

192,908,746

Interest

(1)

25,558,390

40,386,122

Other Financial Results

(1) (3)

(2,966,967)

(35,922,851)

Exchange Differences

(1)

4,387,021

13,601,840

Additions

(2)

57,843,393

108,342,733

(Loss) on Net Monetary Position

(38,872,014)

(46,963,314)

Payments

(105,862,066)

(131,786,450)

Retirements

(4)

-

(9,993,053)

Balances as of December 31

70,661,530

130,573,773

(1)

I

ncluded under

financial expenses

on debt in the Consol

idated Statement of Compr

ehensive Income

.

(2)

Dis

counted at

a borrowing rate of b

etween 25% and 31%

for agreements de

nominated in Argen

tine pesos.

(3)

I

ncludes reduc

tions / waivers of install

ments of certain re

al property lease agr

eements.

(4)

I

ncluded under

Other Income and

Expenses, net in the con

solidated Statement

of Comprehensive In

come.

5.17

Changes

in provision

s and allowances

Items

Balance at

the

Beginning

Deconsolidation

of Subsidiarie

s

(7)

Increases

Decreases

(6)

Balances as

of December

31, 2021

Balances as

of December

31, 2020

Deducted fro

m Assets

Allowance for

Bad Debts

774,676,771

(136,965)

154,457,899

(1)

(355,597,695)

(1)

573,400,010

774,676,771

Allowance for

Impairment of Inven

tories

32,038,663

-

25,772,918

(2)

(13,066,268)

(2)

44,745,313

32,038,663

Allowance for

Impairment of Prope

rty,

Plant and Equip

ment and

Obsolescence of

Materials

21,081,731

-

5,021,585

(26,103,316)

-

21,081,731

Allowance for

Impairment of Intan

gible

Assets

228,920,971

-

7,995,639

(236,916,610)

-

228,920,971

Valuation Allowan

ce on Tax Loss

Carryforwar

ds

(5)

400,363,889

-

113,141,797

(81,798,007)

(3)

431,707,679

400,363,889

Total

1,457,082,025

(136,965)

306,389,838

(713,481,896)

1,049,853,002

1,457,082,025

Included in liabi

lities

Provisions for

Lawsuits and

Contingencies

1,586,228,427

(690,631)

919,349,619

(4)

(865,353,617)

(4)

1,639,533,798

1,586,228,427

Accrual for As

set Retirements

48,461,879

-

(4)

(6,852,496)

(4)

41,609,383

48,461,879

Total

1,634,690,306

(690,631)

919,349,619

(872,206,113)

1,681,143,181

1,634,690,306

(1)

Includes net

increases of $ 158

million which have bee

n charged to Selling e

xpenses (see Note

6.3).

(2)

Includes

$

24

million

charged to

Im

pairment o

f Inven

tories a

nd Ob

solescence

of

Materials

under

Production

Expenses

(see

Note 6.3).

(3)

Includes $

166 million charged to

Income Tax.

(4)

Includes $

587 mil

lion correspon

ding to ne

t increases

which wer

e charged

to Contingencies

(see No

te 6.3)

and $ 30

0 million

to Other

Financial Resul

ts, net.

(5)

Includes Valua

tion Allowance for

Deferred Tax Asse

ts,

net.

(6)

Includes the

effect of the Gain (L

oss) on Net Monetar

y Position.

(7)

Deconsolida

tion of UNIR and Baril

oche TV.

GRUPO CLARÍN S.A.

-

39

-

NOTE 6 - BREAK

DOWN OF THE M

AIN ITEMS OF T

HE STATEMENT OF CO

MPRE

HENSIVE INCOM

E

6.1 Revenues

December 31,

2021

December 31,

2020

Advertising Sales

19,287,684,067

16,261,140,104

Circulation Sales

10,388,355,606

11,255,419,458

Printing Services Sales

955,118,883

1,169,388,059

Television Signals Sales

6,658,305,536

7,660,058,486

Sale of Goods

-

30,815,148

Sales of Logistics Services

832,335,128

2,158,698,340

Other Sales

2,027,500,047

1,674,816,702

Total

(1)

40,149,299,267

40,210,336,297

(1)

Includes sales executed through barter transa

cti

ons as of December 31, 2021 and 2020

for $ 480 million and $ 558

million, respectively.

6.2 Cost of Sales

December 31,

2021

December 31,

2020

Inventories at the beginning of the year

1,748,376,801

2,773,058,724

Purchases for the year

6,812,706,943

4,908,116,968

Deconsolidation of Subsidiaries

(1) (2)

(304,595)

-

Production and Services Expenses (Note 6.3)

18,137,986,720

19,255,450,638

Less: Inventories at year-end

(2,794,121,345)

(1,748,376,801)

Cost of Sales

23,904,644,524

25,188,249,529

(1) Deconsolidation of Bariloche TV.

(2) See Note 12.

6.3. Production and Se

rvices, Selling and Admin

istrative

Expenses

Item

Production and

Services

Expenses

Selling Expenses

Administrative

Expenses

Total as of

December 31,

2021

Total

December 31,

2020

Fees for Services

1,700,961,524

681,880,351

859,593,958

3,242,435,833

3,224,718,665

Salaries, Social S

ecurity and Be

nefits to

Personnel

(1) (2)

8,885,212,158

1,439,242,503

3,541,509,182

13,865,963,843

14,106,870,238

Advertising and P

romotion Expense

s

-

872,001,122

4,293,352

876,294,474

717,183,315

Taxes, Duties a

nd Contributions

399,269,886

115,501,281

281,711,194

796,482,361

694,447,101

Bad Debt Expense

s

-

158,098,848

-

158,098,848

399,342,669

Travel Expenses

433,850,032

21,728,882

53,527,157

509,106,071

428,766,794

Maintenance Expe

nses

1,057,822,752

86,769,894

334,589,089

1,479,181,735

1,419,702,840

Distribution Expenses

11,832,276

1,580,428,090

-

1,592,260,366

2,905,388,569

Communication E

xpenses

143,785,723

13,185,012

53,909,283

210,880,018

229,972,807

Contingencies

-

2,070,698

584,842,554

586,913,252

417,198,643

Stationery and Offic

e Supplies

46,712,315

2,481,781

13,687,850

62,881,946

75,766,510

Commissions

-

26,226,094

32,277

26,258,371

31,675,016

Productions and Co

-Productio

ns

1,504,913,315

-

1,504,913,315

1,626,525,024

Printing Expenses

904,386,217

-

904,386,217

1,072,240,201

Rights

33,461,046

-

33,461,046

59,061,937

Services and S

atellites

577,759,566

8,675,485

217,195,368

803,630,419

866,462,164

Severance Paym

ents

91,635,324

19,537,919

146,370,706

257,543,949

129,481,676

Non-Computable VAT

61,293,703

-

61,293,703

62,616,519

Leases

403,472,550

465,230

10,828,191

414,765,971

350,196,152

Amortization of Int

angible Assets

198,569,804

40,983,082

146,390,039

385,942,925

484,233,103

Amortization of Film

Library

1,075,004

-

1,075,004

1,300,175

Amortization of Ri

ght-

of

-Use Assets

113,523,348

-

113,523,348

165,019,356

Depreciation of Pro

perty, Plant a

nd Equipmen

t

1,051,146,497

70,412,469

140,423,874

1,261,982,840

1,395,403,362

Impairment of Inve

ntories and O

bsolescence

of Materials

24,256,219

-

24,256,219

4,221,262

Other Expenses

493,047,461

55,244,180

183,412,475

731,704,116

556,871,561

Total as of Decem

ber 31, 2021

18,137,986,720

5,194,932,921

6,572,316,549

29,905,236,190

Total as of Decem

ber 31, 2020

19,255,450,638

5,750,384,363

6,418,830,658

31,424,665,659

(1)

As o

f Decem

ber 31, 2021 and 2020, it includes a recovery corresp

onding to the allocation

of employer's contribution

s as a tax

credit against VAT by certain

subsidiaries, for a

pproximately $ 1,

417.7 million

and $ 1,402

.25 million, res

pectively, as m

entioned in

Note 20.

(2) N

et

of

accrued

subsidies

in t

he

amoun

t

of

$

16.92 m

illion

an

d

$

681.95

million

as

o

f

Decembe

r

31,

2021

and

2020,

resp

ecti

vely,

a

s

approve

d

under

th

e

Emergency Assista

nce Program fo

r Work and Pro

duction an

d under the the Pr

ogram for Prod

uctive Recovery I

I. See Note 22.

GRUPO CLARÍN S.A.

-

40

-

6.4 Financial Exp

enses on Debt

December 31,

2021

December 31,

2020

Discounts Obtained in Lease Liabilities

2,966,967

35,922,851

Interests

(170,389,910)

(425,607,829)

Exchange Differences

(380,820,170)

(797,776,826)

Total

(548,243,113)

(1,187,461,804)

6.5 Other Financial Re

sults, net

December 31,

2021

December 31,

2020

Exchange Differences, net

33,874,458

47,987,770

Interests

172,610,155

154,538,699

Financial Discounts on Assets and Liabilities

(18,959,213)

1,684,119

Other Taxes and Expenses

(419,609,648)

(451,786,685)

Results from Operations with Notes and Bonds

(583,793,510)

180,849,903

Total

(815,877,758)

(66,726,194)

6.6 Other Income and

Expense, net

December 31,

2021

December 31,

2020

Income from Sale of Property, Plant and Equipment and Inta

ngible

Assets

(33,355,384)

(2,540,968)

Impairment of Property, Plant and Equipment, Intangible Assets and

Tax Credits

-

28,107,652

Impairment of Goodwill (Note 22)

(66,513,931)

(1,955,755,671)

Other

112,348,190

87,463,130

Total

12,478,875

(1,842,725,857)

NOTE 7 - INCOME

TAX

The following table

shows the reconciliation between the consolidated income tax charged

to net income (loss)

for

the

ye

ars

ended

December

31,

2021

and

2020

and

the

incom

e

tax

l

iability

that

would

res

ult

from

applying

the

c

urrent

tax

rate

on

c

onsolidated

income

(

loss)

before

income

tax

and

t

ax

on

ass

ets

and

the

income

tax

liability assessed for e

ach year (amounts stated

in thous

ands of Argentine Pesos)

:

December

31, 2021

December

31, 2020

Income (Loss) before Income Tax

2,264,968

356,343

Rate

32.22%

30%

Income Tax Assessed at the Current Tax Rate on Income (Lo

ss) befo

re

Income Tax

(729,878)

(106,903)

Permanent Differences:

Equity in Earnings from Associates

136,836

262,364

Gain (Loss) on Net Monetary Position

(331,546)

(549,298)

Non-Deductible Expenses

(2)

(85,337)

(586,363)

Effect of the change in the tax rate

(1)

4,368

(121,934)

Other

(7,909)

(2,205)

Subtotal

(1,022,202)

(1,104,339)

Expired Tax Loss Carryforwards

(10,377)

(17,570)

Unrecognized Deferred Tax Assets

(167,710)

72,995

Total Income Tax

(1,200,289)

(1,048,914)

Deferred Tax

(252,836)

580,888

Current Tax

(947,453)

(1,629,802)

Income Tax Assessed for the Year

(1,200,289)

(1,048,914)

Valuation Allowance for Other Tax Credits

-

(9,384)

Total

(1,200,289)

(1,058,298)

GRUPO CLARÍN S.A.

-

41

-

(1)

Corresponding

to the

effect o

f applying

t

he

changes in

the income

t

ax

rates, a

s per

the ta

x reform

detailed

in Note 2

0, to d

e

ferred ta

x

assets and liabi

lities according to t

he year in which the

y are expected to be

realized.

(2)

As of December 31, 2020, i

t includes $ 586 mi

llion corresponding

to impairment of goodwil

l.

Breakdown of Consol

idated Deferred Tax

(in thousands

of Argentine

pesos):

December 31, 2021

December 31, 2020

Changes

Deferred Tax Assets

Tax Loss Carryforwards

895,330

996,656

(101,326)

Provisions and Other Charges

530,522

389,393

141,129

Trade Receivables

192,239

229,600

(37,361)

Deferral of the Inflation Adjustment for Tax

Purposes (Note 20)

561,259

774,409

(213,150)

Other Liabilities

171,942

157,891

14,051

Accounts Payable

78,086

102,948

(24,862)

2,429,378

2,650,897

(221,519)

Deferred Tax Liabilities

Property, Plant and Equipment

(1,118,377)

(1,117,895)

(482)

Intangible Assets

(12,792)

(38,957)

26,165

Inventories

(27,849)

(9,588)

(18,261)

Other Investments

(15,264)

(34,200)

18,936

Other Assets

(40,783)

(35,014)

(5,769)

Subtotal

(1,215,065)

(1,235,654)

20,589

Valuation Allowance on Tax Loss

Carryforwards - (Charges)

(432,955)

(400,364)

(32,591)

(1,648,020)

(1,636,018)

(12,002)

Total Net Deferred Tax Assets

781,358

1,014,879

(233,521)

(1)

(1) Includes $19,351 corresponding to the

net effect of the consolidation/deconsolida

tion of subsidiaries.

The following is a deta

il of net deferred tax ass

ets taking i

nto consideration t

he deferred tax

position of each

legal entity (in tho

usands of pesos

):

December 31, 2021

December 31, 2020

Deferred Tax Assets

1,415,654

1,300,116

Deferred Tax Liabilities

(634,296)

(285,237)

Total Net Deferred Tax Assets

781,358

1,014,879

As

of

Decem

ber

31,

2021,

the

C

ompany’s

and

its

su

bsidiaries’

accumulated

co

nsolidated

tax

loss

carryforwards

amounted

to approximately $

2,937 million,

which

ca

lculated

at the

tax

rate that

w

ill be

in

effect

at the

time

each

company expects

it will use

them amount

to $ 895 m

illion. The

following tab

le

sho

ws the exp

iration date of t

he

accumulated tax loss carry

forwards pursuant to statutes of limitations (amounts stated in thousands o

f

Argentine Pesos):

Expiration year

Tax

Loss Carryforwards

2022

780,303

2023

109,106

2024

480,788

2025

1,059,118

2026

508,390

The Company estimat

es that the tax

loss carryforwards

are recoverable for the

net amounts disclose

d.

NOTE 8 - PROVISION

S AND OTHER

CONTINGENC

IES

8.1 Claims and Di

sputes with Go

vernmental Agencies

a.

In con

nection

with

the

decisions

made

at

the

Co

mpany's

Annual

O

rdinary

Shareholders'

Meet

ing

held

on

April

28,

2011,

o

n

Septem

ber

1,

2011

th

e

Comp

any

wa

s

served

n

otice

of

an

injunction

iss

ued

in

re

“N

ational

Social Security

Administrati

on

v. Grupo

Clarín S.A. re

o

rdinary proceed

ing” whereby the

Company may no

t

in any way dispose, in part

or in whole, of the $ 387,02

8,756 in historical currency

as of that date recorde

d

under the retained earn

ings account, other tha

n to distribute d

ividends to the share

holders.

GRUPO CLARÍN S.A.

-

42

-

On

the

sam

e

date,

the

Company

w

as

served

notice

of

a

claim

brought

by

Arg

entina’s

National

Social

Security

Administration

requesting

the

nul

lity

of

t

he

decision

mad

e

on

item

7

(Appropriation

of

R

etained

Earnings) of

the agenda

of the

An

nual

Ordinary Shareholders’

Meet

in

g

h

eld on

April 22,

201

0.

O

n

December

2,

2019,

a

deci

sion

was

issue

d

admitting

the

claim

bro

ught

by

Argentina's

National

Social

Security

Administration

and

declarin

g

the

nullification

of

the

decis

ion

mad

e

on

item

7

(Appropriati

on

of

Retained

Earnings)

o

f

the

agen

da

of s

aid

Share

holders’

Meeting,

at

which th

e s

hareholders

had

r

esolved

that the profi

ts for the year

2009, of $

290,146,53

9 in

historical currency as of tha

t date, be appropriated as

follows:

(i)

$

1

4,507,327

to

the

Legal

Reserve

and

(ii)

$

275,

639,212

to

Retained

Earnings.

On

t

he

s

ame

date,

the

Compa

ny

filed

a

n

appeal

aga

inst

such

deci

sion.

On

April

29,

2021,

the

Company

was

served

notice

of

the

decision

re

ndered

by

Chamb

er

“B”

of

the

Nat

ional

Court

of

Appeals

on

Commerc

ial

Matters,

whereby that court

dismiss

ed the

appeal filed by the

Company

and

confirme

d the decision

rendered by the

court of

first instanc

e, de

claring the

nullification

of Ite

m 7

of the

Agenda

of the G

eneral

Ordinary

Shareholders’ Meeting

of the

Company held

on April

22, 2010

. As

of

the date

of these

financial statements,

the Company is ana

lyzing with its legal adv

isors the effects

of such decision.

On November 1, 2011, the CNV issued

Res

olution No. 593, which provides that at shareholders’ meetings

in

which

financi

al

s

tatements

are

consi

dered

shareholders

must

express

ly

decid

e

to,

either

distri

bute

as

dividends any retained

earnings that are not

subject to distribution restrictions and that

may be disposed of

pursuant

to

applicabl

e

law

or

c

apitalize

such

retained

earni

ngs

and

iss

ue

shares,

or

appropri

ate

them

to

set up reserves other t

han legal reserves

, or a combination of

the above.

On

July

12,

2013

t

he

Company

was

served

notice

of

Resol

ution

No.

17,13

1;

dated

as

o

f

July

11,

2

013

whereby

the

CN

V

declared

that

t

he

administrative

effects

of

the

dec

isions

adopte

d at

t

he

Annual

G

eneral

Ordinary Shareholders’ Meeting held on April 25, 2013 were

irregul

ar and ineffective, based on allegations

that

are

a

bsolutely

false

and

irrelevant.

According

to

the

Company

and

its

legal

advisors,

Re

s

olution

No.

17,131

is,

among

other

thin

gs,

nu

ll

a

nd

void,

because

it

lacks

sufficie

nt

grounds

and

its

enactme

nt

is

a

cl

ear

abuse

of

authority

and

a

f

urther

step

in

the

N

ational

Governme

nt's

attempt

to

intervene

in

the

C

ompany.

On

October

11,

2013

C

hamber

No.

V o

f

the

N

ational

Court

of

Appeals

on

F

ederal

Administrative

M

atters

issued

a

n

injunction

in

re

“

Grupo

Clarín

S.A.

v

.

C

NV –

Resol

No.

17,131/13

(File

73

7/13)”

File

No.

29,563/2013,

where

by

it

su

spended

the

e

ffects

of

Res

olution

No.

17,131/2013

da

ted

Ju

ly

11,

2013

which

had

rendered

irregular

and

with

no

effect

for

adm

inistrative

purposes

the

Company’s

Annual

Ordinary

Shareholders’

Meeting

he

ld

on

April

25,

2013.

As

of

the

date

of

consol

idated

these

financial

statements,

the injunction is still

in effect

.

In

August

201

3,

the

Com

pany

was

s

erved

notice

of

a

nullification

claim

brought

by

Argentina

’s

Nat

ional

Social

Security Administration

relating

to the

Annua

l

Ordinary

Shareholders' Meeting

held on

April

28, 2011

whereby it

requested

the

nullity o

f all

th

e

decisions

made

at suc

h me

eting and

, as

a

default arg

ument,

the

nullity

of

the

decisions

ma

de

on

points

2,

4

a

nd

7

of

that

meeting's

agenda

,

as

wel

l

as

the

nullity

of

the

decisions m

ade at

the

Extraordi

nary Meet

ings of

C

lass A,

B

and

A an

d B

Shareh

olders.

As

of

the

date

of

these financial stateme

nts, the proceed

ing was in the d

iscovery stage.

On

Septe

mber

17,

2013,

t

he

Co

mpany

was

s

erved

notice

of

a

nullification

claim

brought

by

Argenti

na’s

National Social S

ecurity

A

dministr

ation

re

lating to

the Annual Ordinary Shareholders' Meeting held

on April

26,

2

012

w

hereby

it

requested

the

nu

llity

of

a

ll

t

he

d

ecisions

made

at

such

meeting

and,

as

a

default

argument,

the

nullity of

the decisions

made on

points 8

and

4

of

that meeting's

agenda,

as

well as

the nullit

y

of

the

decisions

made

at

the

Extraordinary

Meetings

of

Class

A,

B

and

A

an

d

B

Shareholders.

As

of

the

date of these consolidat

ed financial stateme

nts, the proceeding w

as in the discove

ry stage.

On

March

21,

2

014,

the

Company

was

served

notice

of

a

clai

m

brought

by

Argentina’s

National

S

ocial

Security Administration in re “

National Social Secur

ity Administration v. GRUPO

CLARÍN S.A. on Ordinary

Proceeding”

File

No.

74,429,

pending

before

National

Court

of

First

Insta

nce

on

Commerc

ial

Matters

No.

17,

Cler

k

’s

Office

No.

34.

This

claim

seeks

to

nul

lify

and

challeng

e

the

corporat

e

decisions

made

at

the

Shareholders'

M

eeting

he

ld

on

April

25,

201

3

and

those

made

at

the

Board

of

Dir

ectors’

Meet

ing

held

on

April 26, 2013. As of

the date of these financial statem

ents, discovery proceedings have been initiated and

evidence is being produce

d.

On

Septe

mber

16,

2014,

the

Co

mpany

received

a

comm

unication

fro

m

its

contr

olling

share

holder,

GC

Dominio

S.A.,

whereby

that

company

informed

that

it

had

been

summoned

to

cour

t

as

a

th

ird

party

in

re

“National Social Security

Administrat

ion v. Grupo Clarí

n S.A. on Ordinary Proce

eding”, pending b

efore the

National

Court

of

First

Instance

on

Co

mmercial

Matter

s

No.

17,

C

lerk’s

O

ffice

No.

33.

As

of

th

e

d

ate

of

these

cons

olidated

f

inanci

al

s

tatements

and

as

informed

by

GC

Dominio

S.A.,

th

at

com

pany

has

file

d

a

response to the above

-men

tioned claim and t

he proceeding

is in the discovery

stage.

GRUPO CLARÍN S.A.

-

43

-

On November 10, 2016, the Company was served notice of a

claim brought by Argentina’s National Social

Security Administration in

re “National

Governme

nt

- Mini

stry

of Economy and

Fina

nce v.

GRUPO CLARÍN

S.A.

on

Ordinary

Proceeding”

File

-

22,658/2015,

pending

before

the

Nationa

l

Court

of

F

irst

Instance

on

Commercial

Matters

No.

17,

Clerk’s

Office

No.

3

4. This

claim se

eks

to

nullify

and

challenge

the

corporat

e

decisions

made

at t

he

Shareholders'

Me

eting h

eld

on

April

28,

2015.

As

of

the

date

of

these

consolid

ated

financial statements, th

e Company has f

iled a response, prod

uced evidence a

nd made its final stat

ement.

On

April

03,

2017,

th

e

Company

was

served

notic

e

of

a

cla

im

brought

by

Argentina’s

National

Social

Security Administration in

re “National

Govern

ment - Mini

stry

of Economy and

Fina

nce v.

GRUPO CLARÍN

S.A.

on

Ordinary

Proceeding”

File

-

22,832/2014,

pending

before

t

he

National

C

ourt

of

First

Ins

tance

on

Commercial

Matters

No.

17,

Clerk’s

Office

No.

3

4. This

claim se

eks

to

nullify

and

challenge

the

co

rporate

decisions

made

at t

he

Shareholders'

Me

eting h

eld

on

April

29,

2014.

As

of

the

date

of

these

consolid

ated

financial statements, th

e Company has f

iled a response, prod

uced evidence a

nd made its final stat

ement.

Notwithstanding

the

foregoing

with

r

espect

to

t

he

d

ecision

rendered

by

t

he

Court of

Appeals

on

Co

mmercial

Matters,

the

Co

mpany

and

its

lega

l

advisors

believe

th

e

o

utstanding

claims

requesting

the

n

ullification

of

the Shareholders’ Meetings have no l

egal grounds. Therefore, they believe that th

e Company will not have

to face adverse econom

ic consequences in th

is regard.

b.

The Argentine Federal Revenue Serv

ice (“AFIP”) serv

ed the subsidiary CIMECO

with a notice challeng

ing

its

income

tax assessment

for

fiscal

ye

ars

2000,

2

001

and

2002.

In

s

uch

notice,

th

e

AFIP

ch

allenged

mainly

the deduction

of interest and

exchange differen

c

es in

the tax returns

f

iled for

those years.

If AFIP’s position

prevails,

CIM

ECO’s

maxim

um

contin

gency

as

of

December

31,

2021

would

am

ount

to

approxi

mately

$

12.3 million for taxes

and $ 67.5 million for

interest.

CIMECO filed a response, which

w

as dismissed by the tax

authorities. The tax authorities issued their own

official

ass

essment

and

imposed

penalties.

CIM

ECO

appealed

the

tax

authorities

’

resolution

bef

ore

t

he

National Tax Court o

n August 15, 2007.

During

the

y

ear

ended

December

31,

2010,

CIME

CO

received

a

pro

forma

income

tax

assessment

from

the

AFIP for

f

iscal pe

riods 2003 through

20

07,

as a

co

nsequence of

AFIP’s

cha

llenge

to CIMECO’s i

ncome

tax

assessments

f

or

the

periods

2

000

thro

ugh

2002

mentioned

above.

CI

MECO

f

iled

a

respo

nse

before

AFIP,

reject

ing

such

asses

sment

and

requesting

the

suspensio

n

of

a

dministrativ

e

procee

dings

unt

il

the

Federal Tax Court ren

ders its decision o

n the merits.

During

2011,

the

AFIP

served

CIMECO

wit

h

a

notice

stating

the

income

tax

charges

asses

sed

for

years

200

3

t

hrough

2007

and

ordering

the

initiation

of

s

ummary

proceedings.

T

he

AF

IP’s

assessment

shows

a

difference in

its favor

in the Income

Tax liab

ility for the

periods ind

icated above

for an a

mount in exces

s of

the

amount that

had been estimated

or

iginally, as a

result of

the method

used to

calculate certain

deductions. CIMECO responded to

th

e assessment rejecting

all of the

adjustme

nts and

requesti

ng

that

the

proceedings be rendere

d without effect a

nd filed, with

no further actions to be

taken.

On

April

26,

20

12,

the

AFI

P

issued

a

new

off

icial

assessment

com

prising

the

fis

cal

years

2003

thro

ugh

2007, i

n which it

app

lied the

same method

for the

calcul

ation as

th

at used

for the

administrative settlement,

claiming a total liability

of $ 120 million. On M

ay 21,

2012, an a

ppeal was filed wit

h the Federal Tax

Court.

On

December

1

8,

2017,

the

company

was

serv

ed

notice

of

Resolution

No.

132/2017

(DV

MRRI)

w

hich

imposed on

CIMECO

a

fine of

approx

imately $

33 million

in

historical currency

as

of tha

t date

for an

alleg

ed

omission of income tax

for fiscal periods 200

3-

2007, purs

uant to Section 45 of

Law No. 11,683.

CIMECO and its legal

and tax advisors believe CIMECO has strong grounds to

de

fend the criteria adopted

in

its

tax

returns.

Such

criteria

wou

ld

also

prov

ide

a

r

easonable

basis

to

hold

th

at

the

fine

imposed

was

illegitimate.

Therefore,

CI

MECO

c

onsiders

that

AFI

P’s

c

laims

will

not

prosper

before

a

judic

ial

co

urt.

Accordingly,

CI

MECO

h

as

not

booked

an

allowance

in

connection

w

ith

the

effec

ts

such

c

hallenges

may

ha

ve.

c.

By means of Resolution 16,364/2010, da

ted and notifie

d to AGEA as of July 15, 2010, the CN

V’s Board of

Directors

decided

to

initiate

summary

proceedings

a

gainst

AGEA

and

certa

in

members

as

of

the

date

of

initiation

of

su

mmary

pro

ceedings

and

former

me

mbers

of

its

b

oard

of

dir

ectors

and

sup

ervisory

commission, for alleged infr

ingement of the Ar

gentine Business Associat

ions Law, Decree No. 677/

01 and

Law N

o, 2

2,315.

AGE

A, a

nd

the

members

as

of

th

e d

ate of

initiation

of

summary

proceedings

and

form

er

members

of th

e B

oard

of

Directors an

d

supervisory

commission

who

are s

ubject

to t

he s

ummary

proceedings, duly

filed their

res

pective

responses.

Subsequently,

the

file was

sub

mitted

to the

Legal Affairs

GRUPO CLARÍN S.A.

-

44

-

Division of the CNV. As of t

he date of these financial st

a

tements, it is current

ly pending before the M

inistry

of

Economy On

September 9,

2

019,

the CNV

received the

file

fr

om

the Criminal

and Correctional

Court No.

11,

which

had

been

previously

held

by

the

Ministry

of

Economy.

Subsequen

tly,

the

CNV

set

the

date

f

or

the preliminary hearing for March 11,

2020, which was suspended by a decision rendered on

February 14,

2020 until it has been duly clarified h

ow each of the pa

rties subject to the summar

y proceedings exerc

ised

its due process rights.

d.

Through the

Joint

Confid

ential

Resolution

dated

October

30,

2017

(No.

RRFCO

-2017-

12

-APN-DIR-CNV),

subsequently

supplem

ented wit

h th

e

Joint

Confidenti

al

Resolution

dated

Nov

ember

24,

201

7 (No.

RRFC

-

2017

-

16

-A

PN-DIR,

served

on

the

Company

o

n

December

4,

2017,

the

CNV

dec

ided

to

in

itiate

summary

proceedings against the Co

mpany and the memb

ers of its Board of D

irectors, Superv

isory Committee and

Audit

Committee

as

of

the

date

of t

he

alleged

breach f

or

alleged

infringement

of

their

duty

to

disclose

t

he

execution

of

an

irrev

o

cable

contribution

agreeme

nt

with

the

C

ompany’s

su

bsidiary

AGEA

on

June

24,

201

4,

as

a

relevant

fac

t,

p

ursuant

to

Section

1,

2

and

3,

s

ubsection

16),

Chapter

I,

Title

XII

of

the

Rules.

The

subsidiary

of

the

Company,

AGEA,

as

well

as

its

directors

and

syndi

cs

are

also

subject

to

summary

proceedings.

Each

o

f

them

filed

their

respect

ive

responses

in

due

time

a

nd

form.

On

April

25,

20

18,

the

preliminary

hearing

was

h

eld

and

the

procee

dings

moved

on

to

t

he

presentation

o

f

evidence.

On

Octo

ber

9,

2018,

the

parties

to

the

summary

proceeding

sub

mitted

the

correspond

ing

legal

brief.

On

January

25,

2021,

the

Co

mpany

was

notified

o

f

the

appointment

of

an

expert

accounta

nt

to

perform

an

acc

ounting

expert r

eview

as

a

measur

e

to

furnish

add

itional

evidence.

AGE

A r

equested

t

he

recusation

of

said

exp

ert

accountant

on

gr

ounds

of

bias,

appointed

its

own

exp

ert

accountant,

and

added

n

ew

items

subj

ect

to expert

review. On Februar

y 08, 20

21, AGEA was n

otified of

a decision render

ed on Febru

ary 05, 20

21, whereby,

among

other

issues

,

the

expert

accountant

was

served

not

ice

of

the

r

equest

fo

r

ecusation.

The

expert

accountant

must

state

whet

her s

he fa

lls w

ithin th

e grou

nds

for

recusation

provide

d

under

Article

17

of

the

Civil

and

Co

mmercial

Procedure

Cod

e

of

Arg

entina.

On

May

5,

2021

,

the

CN

V

serv

ed

not

ice

to

AGEA

of

its

decision

d

ated

Apri

l

3

0,

2021,

whereby

the

CNV

dismissed

the

objections

filed

aga

inst

the

decis

ion

served

on

Jan

uary

25,

2021,

dism

issed

the

r

ecusation

of

the

expert

account

ant

appointe

d

by

th

e

CNV,

appointed

t

he

C

PA

Silvin

a

Contini as

party

-appoi

nted

tec

hnical

adv

isor,

and admitted

the

new

items

s

ubject

to expert

review that had been proposed by those

subje

ct to the

summary proceedi

ngs. On June

7 and 14,

2021,

CNV

Accountant

M.

Masotto

and

Accountant

Contini,

respectively,

filed

their

accountin

g

expert

reviews.

AGEA

did not

cha

llenge

t

he

expert review

of the

expert accountant

appoint

ed

by

the CNV.

On

July

28,

202

1,

AGEA

w

as

served

with

a

Decision

rendere

d

by

the

CNV

o

n

July

19,

2021,

w

hereby

t

he

CNV

requested

AGEA

t

o

provide

additional

inform

ation

regarding

the

Legal

Brief

r

elating

to

the

accounting

ex

pert

reviews

it

had

f

iled.

On

A

ugust

18,

2021,

AGEA

filed

the

supplemen

t

to

the

Legal

Br

ief

r

elating

to

the

accounting expert revi

ew. As of the date of t

hese financial state

ments, such app

eal is pending res

olution.

In ad

dition,

through

the

Joi

nt Co

nfidential

Resolutio

n

No.

RRFCO

-2

017-

11

-APN-DIR#CN

V d

ated

October

30,

20

17

s

erved

on

Dece

mber

1,

20

17,

th

e

CNV

d

ecided

t

o

in

itiate

s

ummary

procee

dings

against

the

Company and

the

memb

ers of

its Board of

Direct

ors, Supervisory Committee

a

nd Audit

Committee and

the

Market

Relations

Officer

as

of

the

date

of

t

he

alleged

br

each

for

a

lleged

infri

ngement

of

t

heir

duty

to

disclose

the appeal

filed against the injunction

issued on December

20, 2011 in

re “Supercanal S.A. vs.

Cablevisión

S.A. and Other

on Comp

laint for the pr

otection of cons

tituti

onal ri

ghts, Injunction”,

and the d

ismissal of t

he

appeal

by

the

Federal

Cou

rt

of

Appeals

of

Mendoza,

as

a

releva

nt

fact,

pursua

nt

to

Sec

tion

1,

2

and

3,

subsection

16),

Chapter

I,

Title

XII

of

t

he

R

ules.

Cablevisión,

as

well

as

its

direc

tors

and

members

o

f

the

Supervisory

Co

mmittee

an

d

the

Mark

et

Relat

ions

Officer

as

of

th

e

date

o

f

the

alleged

breach

are

a

lso

subject

to

the

summary

proceedings

.

As

of

the

date

of

these

financ

ial

statem

ents,

each

of

them

had

f

iled

their

respective

r

esponses

in

due time

a

nd

f

orm.

On

April 25

,

2018,

the

preliminary

hearing was

held

and

the

proc

eedings moved

o

n

to

the

pr

esentation

of

ev

idence. On

October 9,

2018, the

parties

to the

summary

proceeding

s

ubmitted

the

corres

ponding

lega

l

brief.

On

Janu

ary

25,

2021,

the

C

ompany

was

s

erved

with

Resolution

RRFCO

-2020-

140-A

PN-DIRCNV,

whereby

the

C

NV

imposed

fines

in

the

a

mount

of

$100,000

and $200,000 to Cablevisión and Grupo Clarín, res

pectively. On February 17, 2021, they filed the

respective

appeals,

which

are

pending

before

C

hamber

N

o. I

of

the

Nat

ional

Court

of

Appeals

on Federa

l

Civil

and

Commercia

l

M

atters,

in

re:

SATTER,

MUN

EER

AND

OTHER

VS.

ARGENTINE

SECURITIES

COMMISSION

ON

APPEA

L

AGAIN

ST

ADMINISTRA

TIVE

D

ECISION.

As

of

the

date

of

these

financia

l

statements, those a

ppeals are pe

nding resolutio

n.

e.

The

subsid

iary

AGEA

received

several

inspections

from

the

AFIP

aimed

at

verifying

complianc

e

with

the

so

-called

competitiveness

plans

impl

emented

by

t

he

National

Executive

Branc

h.

After

severa

l

reports

issued by

the

AFIP

and

the

corresp

onding

Resolutions

iss

ued by

the

Ministry

of

Ec

onomy, s

uch ag

encies

allege that cert

ain ac

ts performed

by

AGEA dur

ing 2002

lead to t

he nullity

of some

of the

benefits gr

anted

under

s

aid

plans for

an estimated

total amount

of $

88 million

in

h

istorical

curr

ency

as of

that

date, including

adjustments

and

accessory

amounts.

In

April

2013, A

G

EA

was

s

erved

notice

of

AFIP

Res

olution

No.

03/13,

whereby such ag

ency decided to excl

ude AGEA from

the Registry of B

eneficiaries of the Co

mpetitiveness

GRUPO CLARÍN S.A.

-

45

-

and

Employme

nt

Gene

ration

Agreements

under

t

he

Cultural

S

ector

Agre

ement,

as

from

March

4,

2002.

The AFIP ordered the restatement of the tax returns an

d the deposit of the corresponding amounts. AGEA

filed an appeal ag

ainst such resoluti

on. Notwithstand

ing the forego

ing, in

re “

AEDBA and Oth

er v. Ministry

of Economy Resolution No.

58/10”, the Federal Court

on Administrative

Matters No. 6 issued an injuncti

on

ordering

AFIP

to

re

frain

from initiating

and/

or

continuing with

the administrative

proceeding/s and/or

any

act

that wou

ld entai

l the

enforcemen

t of

the a

mounts p

ayable un

der R

esolution N

o. 3/

13, unt

il a f

inal dec

ision

is

rendered.

Notw

ithstanding

the

forego

ing,

AGEA

c

annot

assure

that

th

e

appeal

wi

ll

b

e

resolved

in

its

favor. Subsequent

to the is

suance of the

injunction

me

ntioned abov

e, the Nati

onal Governm

ent requested

that the i

njunc

tion be

declar

ed expired due to

the application of

the time limitations provided under article 5

of Law No. 26,854. The interv

ening court lifted the injunc

tion. AGEA filed an appe

al against s

uch decision

but the a

ppeal was

dism

issed on

June 4,

2019.

On N

ovember

28, 2018,

upon

new req

uests ma

de by

the

AFIP,

th

e

Company

requested

a

new

injunction

in

the

case,

requesting

that

AFIP

be

ordered

t

o

sus

pend

the

debt

assessment

proc

edures

initiated

by

that

agency.

On

May

21,

2019,

the

Comp

any

requested

an

interim

injunct

ion

ord

ering

the

suspension

of

the

effects

of

AFI

P

Resoluti

ons

Nos.

24/19

and

25/19

under

which

AGEA

was

dem

anded

to

pay

,

as

well

as

the

s

uspension

of

any

ex

isting

deadlines

an

d

any

oth

er

activity

by

AFIP

seeking

to

ass

ess

debt

or

to

collect

any

amounts

i

n

conn

ection

with

the

tax

benefits,

the

expiration

of

w

hich

had

be

en

challenged.

Such

inju

nction

was

issue

d

on

M

ay

23,

201

9,

and

on

May

28,

2019,

the

court

ren

dered

a

decision

whereby

it

clarifi

ed

th

at

the

suspens

ion

of

the

effects

included

the

calculation

of

th

e

deadlines to

file

an

appeal

w

ith

the

Na

tional

T

ax

Court.

The

AFIP

r

equested

t

he

revoc

ation

of

the

new

injunction

requested

in

November

2018

and

the

immedia

te

lifting

of

the

inter

i

m

injunction.

On

July

18,

201

9,

the

Court

of

App

eals

revoked

the

interim

inju

nction.

As

a

result,

A

GEA

has

fi

led

an

a

ppeal

with

the

National

Tax

C

ourt.

On

July

19,

2019,

the

Court

of

Appeals

decid

ed

t

hat

the

case

was

ready

for

resolution

in

c

onnection

wit

h

the

injunction

requested

in

N

ovember

2

018.

AGE

A’s

lega

l

advisors

believe

that there are reasonab

le possibilities th

at the outcome will be f

avorable.

f.

Pursuant to

Resol

ution No. 17,522 issued on

Septemb

er 18, 2014 and

notified to AGEA on September 24,

201

4,

the

Board

of

Directors

of

the

CN

V

decided

to

initiate

summary

proceedings

against

AGEA,

certain

current

and

former

membe

rs

of

its

Board

o

f

Directors

and

supervisory

c

ommission

–

who

occ

upied

those

positions between S

eptem

ber 19,

2

008 and

the date

of initiation of

summ

ary proceedings- and

against that

company's

Head

of

Market

Relations,

f

or

an

alleged

f

ailure

to

co

mply

wit

h

the

d

uty

to

inform

that

AGEA

was

a

co-

defendant

in

re

“

CONSUMIDORE

S

FINA

NCIEROS

ASOCIACION

CIVIL

PARA

SU

D

EFENSA

AND

OTH

ER

V

.

GRUPO

C

LARIN

S.A.

AND

OTHER

on

EXPEDIT

ED

SUMM

ARY

PROCEEDING”

(Fi

le

No.

065441/08). The summary proceeding is grounded on an alleged failure to comply

with Section 5,

subsection a), the first part of Sect

ion 6 and Section 8, s

ubsection a) paragraph

V) of the Annex

to Decree

No.

67

7/01;

w

ith

Sections

1,

2

and

3,

subsection

9)

of

Chapter

XXI

of

the

REGU

LATIONS

(T.R.

2001

as

amended)

–

now

Section

1

of

Part

I,

Chapter

I,

T

itle

XII

of

the

REGULATION

S

(T.R.

2013

as

amended);

with

Sections

2

and

3

s

ubsection

9)

of

Part

II

,

Chapter

I,

Title

XII

of

the

R

EGULATIONS

(T

.R.

2013

as

amended);

with

Section

1

subsection

a.12)

of

Chapter XXVI

of

the

REGULATIONS

(T.R.

2

001

as

amended)

–

now

Sect

ion

11

subsection 13)

of Part

IV, Chapter

I, Title

X

V

of the

R

EGULATIONS

(T.R. 2013

as amend

ed); wi

th S

ection

99 and

100

of

Law

No. 26

,831;

and

with

Sections

59

and 29

4 subs

ection

9)

of

Law N

o. 1

9,550.

AGE

A, a

nd

the

members

as

of

th

e d

ate of

initiation

of

summary

proceedings

and

form

er

members

of the

Board

of

Directors

and

supervisory

c

ommissio

n

who

are s

ubject

to t

he s

ummary

proceedings, duly

filed their respective

res

ponses. On

February 11,

2015, the

preliminary

hearing

was

hel

d

pursuant

to

Article

8,

subs

ection

b.1.),

Title

XI

II,

Ch

apter

II,

Section

II

of

the

Re

gulations

(

T.R

2013,

as

amended).

On

August

19,

2015,

the

company

sub

mitted

the

legal

brief

for

the

disc

overy

stage.

On

June

22, 2015, the judge ordered discovery proceed

ings. On August 19, 2015, the company submitted the legal

brief

for

t

he

disc

overy

stag

e.

On

J

une

9,

2021,

the

Company

was

s

erved

wi

th

the

Disciplinary

Resolutio

n

upon

the

conclusion

of

the

Summary

Proce

edings

R

RFCO

-

2021

-158-APN-DIRC

NV

date

d

May

18,

2021,

whereby

the

CNV

declared

the

claim

filed

against

Saturnino

Herrero

Mitjans

extinguished,

dismissed

the

nullity

and

unconstitutionality

claims,

an

d

acqui

tted

the

Company,

its

permanen

t

directors

,

the

p

ermanent

members of the Superv

isory Committee a

nd the Head of Market

Relations.

g.

On

February

27,

20

13,

the

AFIP

serv

ed

IESA

with

a

notice

stat

ing

the

income

tax

and

v

alue

add

ed

tax

charges

ass

essed

for

fisc

al

per

iod

20

08

and

orderi

ng

the

initiati

on

of

summary

proceedings

f

or

al

leged

omitted

t

axes.

The

AFIP

mainly

challenged

the

ded

uction

of

certain

expenses

and

fees,

as

well

as

the

calculation

of

t

he

c

orrespo

nding

tax

cr

edit.

IESA

filed

an

appeal

in

connectio

n

w

ith

suc

h

ord

er,

w

hich

is

currently

pending

bef

ore

the

National

Tax

Court.

The

official

asses

sment

amounts

to

$

6.2

millio

n

for

income

tax and $ 5.7 million for l

ate

-payment interest and f

ines, calculated as of

December

31, 2

021.

The

official

va

lue-added

tax

ass

essment

amounts

to

$

0.8

million

for

tax

differences

and

$

3.

4

million

f

or

late-payment interest

and fines, calculated as

of December 31, 2

021.

GRUPO CLARÍN S.A.

-

46

-

On

October

21,

2015,

the

AFIP

served

I

ESA

with

a

notice

stating

the

incom

e

tax

and

value

added

tax

charges

ass

essed

for

fisc

al

per

iod

20

09

and

orderi

ng

the

initiati

on

of

summary

proceedings

f

or

al

leged

omitted

taxes.

The

AFIP

mainly

c

hallenged the

deductio

n

of

fees,

as

we

ll

as the

calculation of

the

corresponding

t

ax

credit.

IESA

filed

an

appeal

i

n

con

nection

wi

th

such

ord

er,

w

hich

is

currently

pend

ing

before

th

e

Nat

ional

Tax

C

ourt.

T

he

off

icial

assessment

amounts

to

$

1.2

milli

on

for

incom

e

tax

and

$5.2

million for

late-payment i

nterest and fines, calcu

lated as of Dec

ember

31, 2021.

The

official

va

lue-added

tax

ass

essment

amounts

to

$

0.5

million

for

tax

differences

and

$

2.

1

million

f

or

late-payment interest

and fines, calculated as

of December 31, 2

021.

IESA a

nd

its

legal

and

tax

advisors believ

e th

at i

t has

strong

argu

ments i

n its

f

avor

to d

efend

the

criterion

adopted in its tax returns

.

h.

Pursuant

to

CNV

Resolut

ion

No.

16,834

dated

J

une

14,

2012

notified

t

o

the

Company

on

June

27,

20

12,

the

CN

V

ordered the

initiati

on

of summary

proceedings against

the Company

and

t

he

me

mbers of

its

Board

of

Directors,

Superv

isory

Committee

an

d

Audi

t

Comm

ittee

in

office

at

th

e

time

of

the

occurr

ence

o

f

the

events th

at

motivated

the

p

roceedings

(Septemb

er

19,

2008)

for

alleged

f

ailure

to

comply

with

th

e d

uty

to

inform.

Under

sai

d R

esolutio

n,

the

CN

V

argues

that

t

he

Company

a

llegedly

failed

to

comply

with

th

e

duty

to

disclose

t

he

filing

of

a

claim

against

it

entit

led

“Consumidores

Financieros

Asociación

Civil

para

su

defensa

and

o

ther

v

.

Grup

o

Clarín

o

n/Ordinary”,

which

the

CNV

c

onsiders

rel

evant.

On

July

25,

2012,

Cablevisión

fi

led

a

respons

e

petitioni

ng

that

its

defenses

be

sus

tained

and

that

all

charg

es

against

it

be

dismissed.

On March

13,

2020, the

Compa

ny was

s

erved

with Resolution

RRFCO

-

2020

-

112

-

APN

-

DIR#CNV,

whereby the

CN

V

i

mposed

a

f

ine

of

$300,0

00

on

th

e

Co

mpany

and,

on a

j

oint

a

nd

sev

eral

basis,

on

its

Directors

and

members

of

the

Supervisory

Co

mmittee.

O

n

June

11,

2020,

the

r

espective

appea

ls

were filed,

which

are

pending before

Ch

amber II

of t

he Co

urt of

Appeals

on Fe

deral C

ivil a

nd

Commercia

l

Matters

in

re

“MENZANI,

CARLO

S

A

AND

OTHER

VS.

CNV

ON

APPE

AL

AGAINST

ADMINISTR

ATIVE

RESOLUTION”

File

No.

2,

224/2021.

The

Company

a

nd

its

legal

advisors

believe

that

the

com

pany

has

strong

arguments in

its

favor

.

Nevertheless, the

Company cannot

assure that

the outcome

o

f

said

summary

proceedings will be favor

able.

i.

On

Dece

mber

29

,

2020,

GCGC

was

not

ified

of

a

dec

ision

rendere

d

by

th

e

Directorat

e

-G

eneral

of

R

evenues

(“DGR”,

for

its

Spanish

acronym)

of

the

P

ublic

Revenue

Adm

inistration

for

the

C

ity

of

Buenos

Aires,

whereby said agency challenged the turnover tax returns corresponding to fiscal period 2014 of

Comp

añía

de

Medios

Dig

itales

(CMD

)

S.A.

(a

com

pany

merge

d

into

GCG

C

effective

as

of

Janu

ary

01,

2019).

Accordingly, said

agency iss

ued an of

ficial tax ass

essment. Th

e DGR consi

dered that t

he TV trivi

a games

over text messages do not fall within the definition of Information and Commu

nication Technologies

(ICTs)

activities,

therefore,

CMD

i

s

not

ent

itled

t

o

the

benefits

granted

by

the

Techno

log

ica

l

District

(Law

No.

2,972), which is co

ntrary to the prov

isions of the enforc

ement author

ity of the above

-mentioned law.

The official tax assessment amounts to $ 8.8 million for turnover tax differences for fiscal pe

r

iod 2014, with

an estimated $ 27.9

million

in late-payme

nt interest.

On

that

same

date,

GCGC

was

served

with

a

decis

ion

rendered

by

th

e

DGR

,

whereby

it

or

dered

the

initiation of the official tax assessment procedure

regarding turnover tax liabilities of CMD for fiscal periods

2015 and 2016.

On

Febru

ary

03,

202

1,

GC

filed

an

appeal

with

s

uch

agency

regarding

th

e

of

ficial

tax

asses

sment

for

fiscal p

eriod

2014

and

ans

wered t

he or

der

for

the

initiation

of

the

official tax

asse

ssment

for

fiscal

periods

2015 and 2016.

GCGC

and

its

legal

an

d

ta

x

advisors

believe

th

at

it

has

strong

grounds

to

defend

the

criter

ion

adopted

in

its

tax

returns.

Ac

cordingly,

it

has

not

booked

an

al

lowance

in

connection

with

th

e

effects

that

the

above

-

mentioned situations

may have.

j.

The AFIP notified Pol-

ka of th

e “Inspec

tion Report on

Social Security Co

ntributions

”, whereby said ag

ency

claimed

differences

in

employer

contr

ibutions

for

the

periods

June

2009

to

May

2021.

The

AFIP

claimed

that

Pol-ka

did

not

qualify

for

the

rate

applicable

to

the

industr

ial

activity

as

provided

by

Decree

No.

814/2001, and stated that the differences in employer contribut

ions corresponding to these periods

amounted to $ 79 m

illion plus late

-payment

interest and infringem

ents of the social sec

urity regime.

GRUPO CLARÍN S.A.

-

47

-

On

Decem

ber

2

3,

2021,

P

ol-ka

f

iled

a

n

a

ppeal,

c

hallenging

the

above

-

me

ntioned

“Ins

pection

Report

on

Social Security Contributions”

, claiming the

nullity of the administrative actions,

the qualification of Pol

-ka's

activities as industrial activit

ies, and the expiration o

f the s

tatutes of lim

itation regarding the AFI

P's powers

to assess and claim d

ifferences for the

periods June 2

009 to November 201

1.

If AFIP’s

assessmen

t prev

ailed,

considering

Pol

-k

a's pos

ition regard

ing t

he

above

-mentioned

per

iods, th

e

maximum contingenc

y would a

mount to $284 mi

llion as of Decem

ber 31, 2021.

Pol-Ka

a

nd

its

legal

an

d

ta

x

advisors

believe

Pol-

Ka

has

s

trong

groun

ds

to

defend

the

criteria

adopted

in

its

tax returns. Therefore, Pol-

Ka considers that

AFIP’s claims will

not prosper. Accordingly, Pol

-K

a has

not

booked an allowance

in connection with the

effects such chal

lenges may have.

8.2 Other Claims and

Disputes

a.

Pursuant

to

a

n

otarial

cert

ificate

issued

on

Septembe

r

19,

2008,

AGEA

and

the

Company

w

ere

s

erved

notice

of

a

legal

ac

tion

brought

by

an

entity

re

presenting

co

nsumers

and

a

lleged

financial

vict

ims (

and

by

six

other

individuals).

Claimants

ar

e

Mul

ticanal

not

eholders

who

c

laim

to

be

a

llegedly

aff

ected

by

Multicanal’s A

PE. Th

e claim

is

grounded o

n a

Consu

mer Defens

e La

w that,

in

genera

l terms,

provides

for

an ambiguous proce

dure that is very

strict against the

defendant.

The C

ompany,

AG

EA

and

certain d

irectors

and

me

mbers

of

the

sup

ervisory

com

mittee

and

shareho

lders

have

bee

n

s

erved

notice

of the

claim. A

fter

rejecting

certain

p

reliminary

defenses

presented

by

th

e

defendants,

such

as

the

application

of

statut

es

of

limit

ation

a

nd

t

he

f

ailure

to

co

mply

w

ith

prior

me

diation

procedures,

t

he

claim

followed

ordinary

proc

edure

and

the

a

bove

-ment

ioned

pers

ons

duly

filed

the

ir

respective responses

.

On

Septem

ber

4

,

2017,

th

e

Court

of

First

Instance

rejec

ted

the

c

laim

brought

by

the

entity

repr

esenting

consumers

an

d

alleged

financial

victims

and

by

indiv

iduals.

As

of

the

dat

e

of

t

hese

consol

idated

financia

l

statements,

both

parties

filed

a

n

a

ppeal

agains

t

that

decision

and

the

f

ile

is

curr

ently

pending

f

or

its

resolution before the C

ourt of Appeals.

On September 12, 2019,

Chamber D of the Commercial Court of Appeals confirmed the de

cis

ion rendered

by the

court

of f

irst instanc

e th

at ha

d rej

ec

ted t

he cla

im bro

ught

by the

entity

representing

consum

ers and

alleged

financial

victims.

O

n

October

7,

2019,

th

e

entity

representing

con

sumers

filed

a

federal

extraordinary appeal agains

t this decision. AGEA and the Company filed a response on October 2

8, 2019.

As of the date

of these co

nsolidated f

inancial statem

ents, the ch

amber is an

alyzing the

admissibility of t

he

extraordinary appeal.

b.

On

September

16,

2010

th

e

Company

was

s

erved

notice

of

a

c

laim

brought

against

it

by

Consumi

dores

Financieros

Asociación

Civil

para

s

u

Defensa.

The

plaintiff

c

laims

a

reimburs

ement

of

the

d

ifference

between

the

v

alue

of

the

shares

of

the

C

ompany

purc

hased

at

t

heir

initial

pu

blic

offering

an

d

the

va

lue

of

the

shares

at

the

time

a

de

cision

is

r

endered

in

the

ca

se.

The

Company

has

duly

r

esponded

t

o

the

claim

and

the

intervening

Court

h

as

deemed

the

claim

resp

onded.

The

proce

eding

is

curr

ently

in

the

disc

overy

stage.

c.

On

April

25,

2013,

G

rupo

Clarín

S.A.

held

its

Annua

l

Ordinary

Shareholders

'

M

eeting.

As

a

result

of

the

issues

raised

at

this

Meeting,

some

of

th

e

permanent

d

irectors

informed

the

Compa

ny

that

they

ha

d

pressed

criminal charges aga

inst the represe

ntatives of the sh

areholder AN

SES and of th

e CNV (Messrs. Rep

oso,

Kicillof,

Moreno,

Vanoli,

Far

di

a

nd

H

elman)

for

m

aking

statemen

ts

and

inte

llectual

constr

uctions

which,

under the ap

pearance of

being include

d in the

new r

egulations of

the Arge

ntine Capi

tal Markets

Law, only

sought

to

discr

edit t

he

Boa

rd

of

Directors

and c

aricature

its managem

ent,

creatin

g

pretexts

that m

ay

lead

to

an

interve

ntion

of

t

he

Co

mpany

without

j

udicial

cont

rol;

pursuant

to

the

new

p

owers

vested

in

the

CN

V

by

Capital

Markets

Law

No.

26,831.

On

April

26,

201

3,

the

Board

of

Directors

decided

to

pres

s

charges

grounding its claim o

n the s

ame events that disr

upted a legitimate

meeting.

Consequently, t

he Com

pany

sent a

letter

to the

CN

V, in

which

it c

learly s

tated tha

t what

had

happened

at

that

Meeting

could

not

be

considered

in

any

way

as

an

acknowledgme

nt

of

the

legitimacy

of

the

powe

rs

vested

in

the

CNV

by

Law

No.

26,831

and/or

th

e

regulations

that

may

be

issued

in

the

future.

The

letter

also stated t

hat the

Compa

ny reserv

ed its ri

ght to

file t

he pertinent

legal

actions

at any

time to

request

the

declaration

of

t

he

evident

u

nconstituti

onality

of

tha

t

law.

It

also

re

quested

the

CNV

to

r

efrain

from

perfor

ming

any

act

or

issuing

any

reso

lution

t

hat

would

lea

d

t

o

t

he

execution

of

the

plan

of

whic

h

they

ha

d

been

accus

ed

before the courts.

GRUPO CLARÍN S.A.

-

48

-

d.

In

February 2016,

Radio

M

itre

was

served no

tice of

a

c

laim

seeking

to

exte

nd

to

Radio

Mitre

the

bankruptcy

of one of its subsid

iaries, Cadena

País Producciones

Publicitarias S.A.,

in connection with a case

pending

before one of t

he National

Courts of Firs

t Instance o

n Commerc

ial Matters of

the City o

f Buen

os Aires. On

April

30, 2020, the

court of first

instance dismissed the clai

m brought against

Radi

o

Mitre and Cadena

País

Producciones

P

ublicitarias

S.A.

The

claimant

f

iled

a

n

appeal

against

such

dec

ision.

Our

legal

a

dvisors

believe

that Radio

Mitre has

suf

ficient legal

and

factua

l grounds

to support

its position

co

ntrary

to that

cl

aim

and, therefore, they d

o not foresee any

adverse effect

s that may be derived fro

m this situat

ion.

e.

The

shareho

lders

of

P

ol-Ka

Pro

ducciones

S.A. approv

ed

a

capital

increase,

whereby

ARTEAR

incre

ased

its equity interest in such

company to 91.3%. ARTE

AR paid in

the full amount subscr

ibed. Notwithstanding

the

forego

ing,

the

effects

of

the

above-

mentioned

capital

increase

w

ere

suspended by

an

injunc

tion

grant

ed

at the req

uest of a

minority

shareholder of

Pol

-Ka

Producciones

S.A. pend

ing befo

re the Nat

ional Court

of

First

Instance

on

Com

mercial

Ma

tters

No.

3,

Secretariat

No.

6

o

f

th

e

C

ity

of

Bue

nos

A

ires.

Acc

ordingly,

ARTEAR

exerc

ises

its

po

litical

and

econom

ic

rights

in

P

ol

-ka

Producciones

S.A.

for

a

number

of

sh

ares

representing

55%

of

the

ca

pital

s

tock

and

votes

of

t

hat

company.

Pol

-Ka

Pro

ducciones

S.A.

and

its

legal

advisors believe that the claim lacks legal grounds and that Pol

-Ka Producciones

S.A. will not ha

ve

to face

adverse consequences

in this regard.

8.3 Matters concerning

Papel Prensa

I. Papel Prens

a suspended

its operations w

ith related

parties betwee

n March 9 a

nd April 21, 20

10 pursuant

to

an

injunction

issued

on

Ma

rch

8,

2010

by

Judge

Malde.

In

h

is

ruling,

Judge

Malde

d

ecided

to

suspend

the

Board of

Directors

’

resolution of

December 23,

2

009, which

had

approved the

terms

and conditions

of

transactions

with

ties for

th

e year

2

010. O

n

April

21,

2010,

the

Boar

d o

f

Directors

of

Papel

Prensa

,

following

a

proposal

made

by

the

court

-appo

inted

superv

isor

(interventor)

and

co

-

administrator,

approv

ed

th

e

resumption

of

Papel

Prensa’s

transactions

with

re

lated

parties

under

provisional

c

onditions

for

as

long

as th

e

decision

re

ndered

by

th

e

Board

o

n

D

ecember

23

,

2009

rema

ined

s

uspended

and/or

unti

l

Papel

Prensa’s

corporate bodies established a business practice to follow with

related parties

. Such approval involved

suspending

the

ap

plication

of

volume

disc

ounts

in

con

nection

w

ith

purchases

made

by

s,

which

could

be

reco

gnized

in

their

favor,

subject

to

the

c

ourt’s

decision

on

the

appeal

filed

by

Papel

Prensa

a

gainst

Judge

Malde’s

injuncti

on

of

March

8,

2010.

As

from

April

21,

201

0,

transactions

with

were

resumed under the prov

isional co

nditions approv

ed by the

Board on April 21,

2010.

At

a

me

eting

held

on

Dece

mber

23,

2010,

P

apel

Prensa’s

Board

of

Directors

approved

n

ew

conditions

th

at

must be

fulfilled for

the rec

ognition a

nd payme

nt of vo

lume

discounts

that may

be

applicable

to rel

ated

parties

in

co

nnection

with

purchases

of

paper

made

as

fr

om

April

2

1,

2010.

Th

ese

new

c

onditions

are

as

follows:

(i)

the

lifting

of

the

provisional

suspension

of

the

resolutions

adopt

ed

by

the

Board

at

the

meeting

of

D

ecember

23, 2009,

as

explained

in

the pr

evious

paragraph,

and

(ii) the

resoluti

on or

end,

by

any means,

of

any s

tate

of

uncertainty that ma

y eventually exist

about the conditions ap

pr

oved by

Papel Prensa’s Board i

n the fi

rst item of

the

a

genda

of

t

he

meeting

held

on

Apri

l

21

,

2010,

a

s

a

co

nseq

uence

of

the

cl

aim

brought

by

the

Nation

al

Government in re “National Government –

Secretariat of Domestic Trade

–

v./ Papel Prensa S.A.I.C.F. y de M.

on/

Ordinary

”,

File

No.

97,564,

curr

ently

pending

be

fore

Federal

Co

mmercial

Court

of

First

Instance

N

o.

2

6,

Clerk’s Office

No.

52. Und

er this

proceeding,

the

National G

overnment s

eeks to

obtain,

among

other t

hings,

a

declaratory

j

udgment

of

n

ullity

of

the

provisional

co

nditions

for

the

resumption

of

trans

actions

with

in co

nnection

with

the

purc

hase a

nd s

ale

of

paper

that

was

approved by

t

he B

oard

of

Papel

Prensa

i

n

the first item of the ag

enda of the

above-me

ntioned me

eting held on Apr

il 21, 2010.

Furthermore,

at

t

his

meeting

hel

d

on

Decem

ber

23,

2010,

Papel

Prensa’s

Board

d

ecided

to

ma

intain

the

approved

s

ales

policy,

but

to

subject

the

accrua

l

and

enforceability,

and,

c

onsequently,

the

r

ecognition

and

payment t

o the

clients,

of

the

eventual

volume

discounts

that

may

be

applicable t

o them

with

respect

to

paper

purchases

m

ade

between

J

anuary

1,

2011

a

nd

Dec

ember

31,

2011,

to

a

final

f

avorable

ruling

in

the

claim

brought

by

Pa

pel

Prensa

against

the

const

itutionality

of

SCI

Resoluti

on

No.

1/20

10,

or

to

the

fina

l

nullification

of such Resolut

ion No. 1/2

010 in any ot

her way or

by any other

legal means,

whichever oc

curs first. In v

iew

of

the dec

isions

rendered

in

this

case,

the

substant

ive c

laim,

in t

his

aspect,

is

now

subject

to

the

outcome

of

the

claim brought

by

Papel Pre

nsa against t

he co

nstitutionality

of Law

No. 26

,736.

With respect

to r

elated part

ies,

the

Board

of

D

irectors

of Pape

l

Prensa

approve

d

the

same s

ales

policy

an

d

conditions

as those

approved

for

the other customers i

n general.

In a meeti

ng held on Dece

mber 27, 2011, the Board o

f Directors of Papel Prensa decided to mainta

in for 2012

the

same

s

ales

p

olicy

that

had

been

approved

for

2011

–

under

the

same

terms

and

conditions

mentioned

in

the previous paragraph

–

for

all of its customers in general (includ

ing related parties)

, which was maintained in

subsequent years and,

to date, no changes

have been intro

duced.

GRUPO CLARÍN S.A.

-

49

-

The

com

mercial

policy

approved

by

Papel

Pre

nsa

was

affecte

d

by

Law

26,736

–

effective

as

fro

m

Jan

uary

5,

2012

–

which

dec

lared

that

the

prod

uction,

sale

and

di

stribution

of

wood

pu

lp

and

newsprint

were

matters

of

public interes

t

and set

forth

the r

egulatory

framework

to

be

adopted

by

the prod

ucers,

sellers,

distributors

and

buyers of such inputs.

Among

other

things,

the

L

aw

set

limi

ts

and

establ

ished

c

onditions

applicab

le

to

P

apel

Pr

ensa

for

the

productio

n,

distribution

and

sa

le

of newsprint

(including a

form

ula

to de

termi

ne

the

price of

pap

er),

and

created the

Nat

ional

Registry

of

Prod

ucers,

Distributors

and

Se

llers

of

W

ood

P

ulp

and

Newspri

nt

where

all

producers,

sellers,

distributors

a

nd

b

uyers

shall

be

registered

as

a

mandatory

require

ment

i

n

orde

r

to

produce,

sell,

distribut

e,

and/or purchase newspr

int and wood pu

lp.

On

February

10,

2012,

AGEA

r

egistered

with

t

he

Nati

onal

Reg

ist

ry

of

Producers

,

Distributors

and

Sel

lers

o

f

Wood

Pulp

and

Ne

wsprint

(Record

No.

63

in

File

No

.

S01:0052528/

12),

clearly

s

tating

that

the

dec

ision

to

register

shall

not

be

cons

trued

as

an

acknowle

dgment

or conformity

wi

th

the

legitimacy

of

Law

2

6,736,

Resolution

No.

9/20

12

issued

by t

he

Ministry

of

Econ

omy

and

Public

Fi

nance

and

SCI

Res

olution

No.

4/2012

issued

in

connec

tion

with

s

uch

Law

and/

or

any

other

issued

in

the

f

uture,

since

t

hey

serious

ly

affect

severa

l

rights and guarantees

of AGEA which

are recog

nized

and protected by t

he Argentine National Cons

titution.

On January

10, 2019,

Law No.

27,498 w

as published

in the O

fficial Gaze

tte. This

law repealed c

ertain art

icles

of

Law

No.

26,736,

allowi

ng

companies

to

of

fer

their

customers

discounts,

benefits

or

promotions

based

on

purchase

vol

umes.

On

the

other

ha

nd,

sa

id

law

establishes

parameters

for

granting

extensions

of

payment

terms,

and

prohibits,

for

a

term

of

10

ye

ars,

to

make

changes

to

the

w

ood

pulp

and

ne

wsprint

imp

ort

dutie

s

currently in effect, wh

ich are set at z

ero percent (0%).

II.

In March

2016, the

C

ommercial Court

of Appeals

–

Chamber C

–

summ

oned Papel

Prensa, the

CNV, and the

shareholders, the Nationa

l Government, S.A. La Nac

ión CIMECO an

d AGEA to attend a hearing

to be held on

April

7,

2016,

solely

for

conc

iliatory

purposes

a

nd

with

th

e

a

im

of

finding

a

compreh

ensive

solut

ion

to

t

he

c

onflict.

The

hearin

g

was held on

t

hat date

and a

n

ew date

w

as set

to resume

the hearing

on June

2, 2016

for the

same

purposes and

effects. It was

subsequent

ly postponed un

til June 3,

2016. At that hearing, held on

Ju

ne 3,

2016,

Papel

Prensa,

AG

EA

and

t

he

other

sh

areholders

pres

ent

a

t

the

h

earing

(the

N

ational

Gov

ernment,

S.A.

L

a

Nación

and

CIMECO)

requ

ested

that

the

procedural

periods

re

main

susp

ended

i

n

connection

with

the

c

laims

pending

before

th

at

C

ourt

of

Appeals,

and

also

req

uested

the

court

to

order

a

shar

eholders’

meeting

of

P

apel

Prensa

to

be held

on September

20, 2016

to address,

basically, the

issues included

under

subsecti

ons

1, 2

and

3

of

Sect

ion

234

of

Law

N

o.

19,550,

as

amended,

corres

ponding

to

fiscal

ye

ars

ended

D

ecember

31,

2010,

2011,

2012,

2013,

2014

and

20

15.

On

Septem

ber

5,

2016,

the

C

ourt

of

Appeal

s

c

alled

f

or

a

share

holders’

meeting

as

requested at

t

he

hearin

g held

on June

3, 2016,

an

d at

the request

of Papel

Prensa and

t

he Nat

ional

Government

–

in

v

iew

of

th

e urg

ent

and

im

pending

ter

ms

to

make

the

r

equired

publications

–

on

September

8,

2016 it postponed the date of the shareholders meet

ing until October 19, 2016. On that date, the sharehold

ers

of

Papel

Prensa

duly

held

t

he

court-

c

onvened

Sharehold

ers’

Meeting

of

t

hat

company.

At

that

Shareholders’

Meeting,

the

sharehold

ers

approved

the

financial

statements

of

Papel

Prensa

fo

r

the

years

ended

Dece

mber

31, 2010, 2011,

2012, 2013

, 2014 and 2

015 and oth

er accounting

documentat

ion und

er subsection 1,

Section

234

of

Law

No.

19,550,

as

amen

ded,

appointed

direct

ors,

statut

ory

audi

tors

and

members

of

t

he

superv

isory

committee

f

or

the

year

2016

,

approve

d

the

capital

ization

of

the

capital ad

justme

nt

f

or

$

123,293,385

in

historical

currency

as

of

that

date,

iss

ued

a

decision

on

the

approval

and

disapproval

of

the

performance

of

certai

n

directors,

statutory

au

ditors

and

mem

bers

of

the

su

pervisory

committe

e

during

the

fu

ll

fiscal

years

under

consideration,

and

unanimously

appointed

external

audit

ors

engaged

with

issuing

a

n

o

pinion

on

the

fina

ncial

statements

of

Papel

Prensa

as

of

Dece

mber

31,

2

016

and

March

31

,

2017.

O

n

March

3

0,

2017,

th

e

hearing

that had be

en called by

Chamber C

of the

National C

ourt of

Appeals on

Commerc

ial Matters

was held.

A

t that

hearing,

Papel

Pre

nsa

requested

th

at

the

majority

of

the

claims

involving

Papel

Prensa

be

d

eclared

moot

considering

the

decisions

r

endered

at

the

S

hareholders

’

Meeting

held

on

Oc

tober

19,

2016.

O

n

Octo

ber

4

,

2017,

the

Court

of

App

eals

rendered

a

dec

ision

on

m

ore

than

90

proceed

ings

declar

ing

t

hem

moot

as

requeste

d

by P

apel Prensa

and revoking -

among others- Resolutions No.

16,64

7,

16,671 and 16,691

iss

ued

by the

CNV.

Both

d

ecisions

rendered

by

the

C

ourt

of

Ap

peals

became

final.

Papel

Pre

nsa

s

ubmitte

d

the

same

re

quest

to

the Court of First Instance on Commerc

ial Matters regarding most of th

e proceedings pending before the cou

rt

and

that

were

not

submitted

to

the

Court

of

Appe

als,

at

the

request

of

the

Court,

for

the

purposes

desc

ribed

above.

At th

e h

earing

held

on

April

24,

2018,

the

National

Governm

ent

agreed

on t

hat

request,

and

subsequently, the Judge of the

Court of First Instance issued a favorable decision on the

request and declared

moot all

of

the c

laims w

ithin th

e scop

e of

that

request.

At

the

General

Annual

Ord

inary Sh

areholders’

Meeting

that

appr

oved

the

financi

al

statem

ents

of

Papel

Prensa

for

the

year

end

ed

Decem

ber

31,

2016,

the

shareholders d

isapproved t

he managem

ent of

the repres

entatives of th

e Natio

nal Governmen

t in the

Board

of

Directors

and

in

the

Ov

ersight

Board

who

he

ld

office

until

February

2016,

as

well

as

the

perfor

mance

of

t

he

syndics

who

held

off

ice

until

t

he

S

hareholders’

Meeti

ng

of

Oc

tober

19,

20

16,

also

in

representation

of

the

GRUPO CLARÍN S.A.

-

50

-

National Government, and decided

to bring a

cor

porate liability action (Section 276

of Law

19,550, as

amended).

III.

On

June

6,

20

13,

the

Board

of

Directors

of

the

CNV

i

ssued

CNV

R

esolution

N

o.

17,102,

within

th

e

framew

ork

of

the

Administrative

Fi

le

No.

1,032/10,

w

hereby

it requi

red

that:

(i)

certain members

of

Papel

Prensa's

Supervisory Com

mittee and statutory

auditors be

imposed a fine of $

150,000 ea

ch in historical curre

ncy as of

that

d

ate;

and

(ii)

Papel

Prensa,

c

ertain

members

of

its

Board

of

Directors

,

one

member

of

its

Superv

isory

Committee

and

the

members

of

its

Ov

ersight

B

oard

(all

o

f

them

representative

s

of

Papel

Prensa's

private

shareholders)

be

imposed

a

joint

and

several

fine

of

$

8

00,000

in

h

istorical

curr

ency

as

of

that

dat

e.

Pape

l

Prensa and

its

other c

urrent an

d for

mer officers

filed

a

n appeal aga

inst the

fine

in due

time

and f

orm,

which i

s

pending to

date. On

June 28, 2013,

the fine was

paid under

prot

est in

ord

er to

c

oercive enforcement

by

the

CNV;

given

that,

under

the

new

Capital

Markets

Law

No.

26,831,

ap

peals

may

be

a

d

m

itted

without

suspension of judgment.

IV.

On

October

8,

2019,

t

he

Board

of

Directors

of

Papel

Prensa

approve

d

the

volunt

ary

delisting

of

the

Com

pany

subject

to

th

e

approval

of

the

sh

areholders

at

the

G

eneral

Extr

aordinary

Sh

areholders'

M

eeting

and

to

the

pertinent

r

egulatory

approvals

(CNV

and

BYM

A).

Ho

wever,

o

n

Nov

ember

20,

2019,

in

view

of

the

immine

nt

change of

administration

in the National

Gover

nment, the

Board of

Direct

ors decided

to stay the

delisting it had

approved, thus suspen

ding the Shar

eholde

rs’

Meeting it had d

uly called.

V.

AGEA

has

not

record

ed

any

impact

i

n

c

onnection

with

the

f

oregoing,

s

ince

its

effec

ts

shall

de

pend

on

th

e

final outcome. Such e

ffects are not expec

ted to be ma

terial to these f

inancial statements.

NOTE 9 - REGULATO

RY

FRAMEWORK

9.1. Audiovisual Comm

unication S

ervices Law

The

subsid

iaries

of

Grupo

Clarín

t

hat

re

nder

a

udiovisual

communication

services

are

holders

of

l

icenses

th

at

were

originally

awarded

under

the

r

egime

estab

lished

by

Law

No.

22

,285.

Under

Law No.

22,2

85 audi

ovisual

communication

service

compan

ies

in

Argen

tina

were

required

a

non

-ex

clusive

license

from

t

he

CO

MFER

in

order to operate.

The A

udiovisual

Commun

ication

Serv

ices

Law

(Law

No.

26,52

2, L

SCA,

for

its

Sp

anish

acronym)

was

pass

ed

and

enacted o

n October 10, 200

9, with strong criticism

about its conte

nt and enactment

procedure.

By

th

e

end

of

Dec

ember

2015, the

National E

xecutive

Branch

issued E

mer

gency

Decree

No.

267/15,

p

ublished

in

the

Official

Gazette

on

January

4,

2016,

whereby

sign

ifica

nt

ame

ndments

w

ere

introduced

to

La

ws

Nos.

26,522

and

27,078

(the

D

igital

Argentina

Law,

"LAD",

for

its

Sp

anish

acronym).

The

Emergency

Decree

was

approved on April 6, 2

016 by the

Lower House of

Con

gress. Therefore

, it has full

force and effect.

9.2.

Enforcement

Authority

The

Comité Federal de Radiodifusión

(Federal Broadc

asting Committee, “COMFE

R”, for its Spanish acronym)

was the enforcemen

t authority establish

ed by Law No. 22,2

85.

Law

No.

26,522 provided

for

the

replacem

ent

of

th

e

COMFER

by

the

A

udi

ovisual

Comm

unication

Services Law

Federal

Enforcement

Authority

(

AFSCA,

for

its

S

panish

acr

onym)

as

a

dece

ntralized

a

nd

autarchic

ag

ency

under the jurisdiction

of the Executive Bra

nch, and ves

ted the new agency w

ith authority to en

force the law.

The

Emergency

D

ecree

created

the

ENACOM

as

a

decentralized

a

nd

autarchic

agency

under

the

jur

isdiction

of the Ministry of Communi

cations and vested the new

agency with authority to e

nforce Laws Nos. 2

6,522 and

27,078,

as

a

mended

and

r

egulated.

T

he

ENACOM

h

as

all

th

e

same

powers

and

competences

that

had

been

vested in

AFSCA and th

e Information a

nd Comm

unications T

echnology Federal

Enforcement

Authority

(“AFTIC”, for its Spanish

acronym) by La

ws Nos. 26,522 an

d 27,078, respect

ively.

Upon

the

issuance

of

Decrees

Nos.

7/2019

a

nd

50/2019,

published

in

the

Official

Gazette

on

Dece

mber

11,

2019 and on December 19, 2019, respect

ively, the ENACOM is now under the juri

sdiction of the Secretariat of

Public Innovation under t

he Chief of the

Cabinet of Min

isters.

GRUPO CLARÍN S.A.

-

51

-

9.3. Multiple License

Regime

The

mu

ltiple

lice

nse

r

egime

established

und

er

Law

No.

22,285

allowed

licensees

to

hold

at

the

nationa

l

lev

el

up to twenty-four (24) sound or television broadcasting licenses. At the local level, one individual or legal entity

could

have

up

to

one

s

ound

broadcasting l

icense,

one

televis

ion

licens

e

and

one

subscription

television l

icens

e.

In this last case, FM broadc

asting services were no

t included in this limit if they wer

e broadcast from t

he same

station and location as

the AM

broadcasting serv

ices.

The

LSCA introduced

comp

rehensive

amen

dments

on the

multiple license

r

egime, against

w

hich

the Company

and

some

of

its S

ubsid

iaries

filed

an

unconstitutional

ity

cla

im.

Eventual

ly,

that

claim

w

as

dismiss

ed.

The

original

regime

approv

ed

by

th

e

LSCA

regarding

broadcast

services:

i)

restricted

to

1

0

the

number

of

audiovisual

communication

serv

ice

licenses

,

p

lus

a

sing

le

broadcas

t

s

ignal

for

r

adio,

broadcas

t

T

V

and

su

bscription

television

services

that

m

ade

use

of

the

radioelec

tric

s

pect

rum;

ii)

s

et

forth

a

further

r

estriction

on

these

services

,

which could

not

be

provided

to m

ore than

35%

of a

ll inhab

itants or

subsc

ribers nationwi

de; and

iii)

at th

e loc

al

level,

the

regime

es

tablished

the

fo

llowing

limits:

a)

one

(1)

sound

broadcasting

l

icense

for

amp

litude

modulation

(AM);

b)

one (1)

so

und

broadcas

ting

license

for frequency mo

dulation (FM)

or

up to

two

(2) licenses

w

hen there

are more

than eight (8)

l

icenses in

the primary service area;

c)

one

s

ubscription

television

license, provided th

e

applicant was

not th

e holde

r of a

broadcast

television

lic

ense; d) o

ne (1)

broadcast

television

license

provided

the

applicant

was

not

the

holder

of

a

subscription

television

license.

U

nder

no

circu

mstances

may

the

aggregat

e

number

of

t

he

l

icenses

gra

nted

in

the

s

ame

pri

mary

s

ervice

are

a

or

any

group

of

highly

over

lapping

serv

ice

areas exceed three (3) l

icenses.

Among

the

main

amendm

ents

introduced

by

the

E

mergency

Decr

ee

with

respect

to

the

LSCA,

the

most

remarkable

is the

repeal

of

Section

161,

which

s

et

forth

the

obligation

to c

onform

to th

e

provis

ions

of

th

is

law

with

res

pect

to

own

ership

conditions

an

d

th

e

number

of

licenses.

Section

45

of

L

aw

No.

26,52

2,

w

hich

establishes

th

e

multiple

license

regime,

has

been

s

ignificantly

amended.

As

a

result,

th

e

Company

and

its

subsidiaries already c

onform to the new re

gulatory framework.

As

far

as

the Com

pany

is

concerne

d,

the

Emergency

Decree:

i)

el

iminated

the

incompatibility

to

render

in

the

same location

broadcast

television serv

ices a

nd subscription

televi

sion services;

ii) increased

the lim

it to 15

of

broadcast

(telev

ision

a

nd

radio)

service

licenses

that

may be

accum

ulated

at

national

level;

iii)

e

liminated

t

he

restriction to hold cab

le television s

ignals; and iv) eli

minated the restriction

on broadcas

t s

ervices, which coul

d

not be provided to more

tha

n 35% of all i

nhabitants or subscr

ibers nationwide. At the local level, it i

ncreased to

4 the number of licenses

that cou

ld be accumulated.

9.4. Terms of the Licens

es

Law No.

22,285

provided

that

broadcast

ing

licenses

were gra

nted for

an

initial

period

of 15

years,

allowing

for

a

one-time

extension

of

10

years.

The

ex

tension

of

the

license

was

subject

to

th

e

approval

of

t

he

COMFER,

which wo

uld

determine

wh

ether or

n

ot the

licensee ha

d met

t

he terms

a

nd c

ondi

ti

ons

under

which t

he

license

had

been

granted.

Some

of

the

licenses

exploited

by

the

s

ubsidiaries

have

alr

eady

been

extended

for

th

e

above-mentioned

10-year term.

On

May

24,

2005,

Decree

No.

527/05

provided

for

a

10

-year-suspe

nsion

of the

ter

ms

then

effec

tive

of

broadcasting licenses

or their exte

nsions. Calculation

of the terms was a

utomatically resu

med upon expir

ation

of

the

suspension

term,

s

ubject

to

certai

n

c

onditions.

The

Decree

required

that

c

ompanies

seeking

to

benef

it

from

the

extens

ion

s

ubmit

to

the

CO

MFER’s

approv

al,

within

2

years

from

the date

of the

Decr

ee,

programmi

ng

proposals

that

wou

ld

contribute

to

the

pr

eservation

of

the nat

ional

culture

and

t

he

education

of

the

population

and a technology inves

tment project t

o be imple

mented during

the

suspens

ion term. COMF

ER Resolution N

o.

214/07

reg

ulated

t

he

o

bligations

established

by

Dec

ree

No.

527/05

in

order

to

benefit

fr

om

suc

h

sus

pension.

The proposals

then sub

mitted were a

pproved an

d, accordingly,

the terms

of t

he licens

es originally

awarded

to

the subsidiaries of Gr

upo Clarín were s

uspended for te

n (10) years.

Even t

hough

Law

No.

26,

522

respected

the

orig

inal

expiration

t

erms

of

the

licens

es

effective

at

the

time

of

it

s

enactment, it set a 10

-year limitatio

n to the terms of l

icenses, with a

on

e-time non

-renewable extens

ion.

With

regard

to

t

he

term

of

the

licenses

for

televis

ion

and

radio

broadcast

serv

ices,

the

Emergency

Dec

ree

establishes two imp

ortant changes:

•

It

provides

for

a

new

sys

tem

of

ex

tensions

for

au

diovisual

co

mmunication

servic

e

licenses

whereby

the

licensee

may

request

a

first

extension

for

f

ive

(5)

years,

which

will

be

auto

matic.

Upon

ex

piration

of

this

term,

licensees

may

request

subsequent

extensi

ons

of

ten

(10)

years

comply

ing

in

that

c

ase

with

the

GRUPO CLARÍN S.A.

-

52

-

provisions of t

he Law a

nd a

pplicable regulat

ions to be

eligible for e

ach extensi

on. However,

this sys

tem of

subsequent

extensions

may

be

interrupted

upon

the

expiration

of

the

las

t

extension

if

the

Ministry

of

Communications

deci

des

to

call

for

a

publ

ic

bid

for

new

licens

ees,

for

re

as

ons

of

public

i

nterest,

for

the

introduction

of

new

technologies

or

in

complianc

e

with

internat

ional

agreements.

In

t

his

case,

prior

l

icensees

shall have no acqu

ired rights regarding their

licenses.

•

Section

20

of

the

Emer

gency

Decree

provides

th

at t

he

holders

of

licenses

ef

fective

as

of

January

1,

2016

may request

a

ten (1

0) yea

r extension,

without

it b

eing

necessary

to wa

it until

the

expiration

of

the license

that is currently effective. Such extension shall be considered as a first period that entitles the holder to

the

five (5) year automat

ic extension.

Taking

into

consideration

t

he a

dvantages

prov

ided u

nder

the

new

legal framewor

k

with

regard

to

the terms

o

f

the

licenses,

the

direct

and indirect

subsidiar

ies of

the

Company

t

hat

hold

broadc

ast te

levision

licenses

m

ade

a filing

with t

he EN

ACOM r

equesting

the

extension

of

the terms

of

their

licenses

pursuant to

Sec

tion 20

of t

he

Emergency Decree.

The

ENACO

M

iss

ued

Res

olution

No.

135/2017,

whereby

it

deemed

that

ARTEAR

had

opted

to

r

equest

an

extension under

Sec

tion 20

of

Decre

e

No. 267/15

and

s

tated

that the

term

for the

fir

st

period of

T

EN

(10) years,

with the right to

an autom

atic extension for

a

term of

FIVE (5) m

ore years

, shall be calcu

lated as from

January

2, 2017.

On

March

15,

2019,

the

ENACOM

issued

Resolution

N

o.

1,176/19,

whereby

it

granted

the

extension

request

ed.

Radio

Mitre

was

deemed

t

o

have

opt

ed

to

re

quest

an

extension

for

all

of

it

s

licenses

under

Article

20

of

t

he

above-mentioned

Decree,

and

was

gra

nted

a

term

of

10

years,

with

the

ri

ght

to

an

automatic

extension

for

a

term of 5 more years.

In

addition,

the

ENACOM

has

issue

d

a

favora

ble

de

cision,

deeming

as

exercis

ed

the

opt

ions

t

o

the

r

egime

provided

under

Article

20

of

Decree

No

.

267/15

formulated

by

the

ot

her

subsidiaries.

P

ursuant

to

those

administrative

proceedings

,

the

new

expiration

date

for

the

broadcast

television

licenses

exploited

by

the

subsidiaries of the Co

mpany are:

On August

20,

2021,

Bariloche

TV

S.A. m

ade a

filing

with

the

Enforcemen

t Auth

ority, p

ursuant to

Article 41

of

Law

No.

26,522,

regardin

g

the

s

hare

tra

nsfers

in

that

company,

wh

ereby

ARTE

AR

an

d

GC

Minor

transferre

d

100%

of

their equity

inter

ests.

As a

result, they

are no

l

onger

relate

d

to

Bariloche TV

S.A., holder

of a

broa

dcast

television

s

ervice

license

a

nd

a

broadcas

t

F

M

r

adio

s

ervice

license

in

the

City

of

San

Carlos

de

Bariloche

,

province of Río Ne

gro.

Renewal of Licenses Gr

anted under

Art. 20 of Decr

ee No. 2

67/2015

LS 85 TV Canal 13 of

Buenos Aires

January 1, 2027

LU 81 TV Canal 7 of

Bahía Blanca

J

anuary 1, 2027

LV 81 TV Canal 12 of C

órdoba

January 1, 202

7

9.5. Other Resolut

ions Issued by the Enf

orcement Au

thority

Even

thoug

h

ART

EAR

has

challenged

the

va

lidity

o

r

c

onstitutionality

of

some

regulations

impose

d

by

the

Enforcement Authority,

it

c

omplies

every

year

with

the

r

equired procedures

only

i

n

t

he event

that such

requirements

may

be

c

onsidered

valid,

for

the

purp

oses

of

s

afeguarding

its

r

ights.

Those

procedures

ar

e

detailed below:

-

The procedure

provided

under AFS

CA Resol

ution No.

173/201

0, whereby

an Au

diovisual Com

munication

Services Providers In

formation System was i

mplemented.

-

The

procedure

provided

under

Decree

No.

904/2010

and

AFSCA

Resolution

No.

175/2010,

whereby

the

Registry of Signals and

Producers was i

mplemented.

-

The

procedure

provided

under

AF

SCA

Reso

lution

No.

464/2010

(currently

E

NACOM

R

esolution

N

o.

5,264/2016), wh

ich established

the ob

ligation

to

request

network authorizat

ion pu

rsuant to Art

icles 62

and

63 of Law No. 26,522.

-

The procedure prov

ided un

der AFSCA R

esolution No.

630/2010, w

hich approved

the Rules g

overning the

Public Registry

of Advert

ising Agencies

and Pr

oducers.

Such Resolution i

s aimed

at regulating t

he sale

of

advertising spaces on broa

dcasting services, encomp

assing both Advertising A

gencies with respect to the

GRUPO CLARÍN S.A.

-

53

-

services

governed

by

Law

No.

26,

522,

as

well

as

companies

acting

as

intermediaries

for

the

sale

of

advertising on such s

ervices.

-

The proc

edure

provi

ded

under

Reso

lution

No.

1/20

11

issued

jointly

by

AF

SCA

an

d th

e

Argentine

Federa

l

Revenue

Service,

w

hereby

they

implemented

a

new

procedure

for

th

e

payment

of

the

tax

applicable

to

broadcasting services.

-

The

proc

edure

provid

ed

u

nder

AFSCA

Resol

ution

N

o.

979/2013,

which

req

uires

broadcast

te

levision

licensees

to

report

in

the

form

of

an

a

ffidavit

the

list

of

national

feature

f

ilms

and

telefi

lms

for

which

they

have

acquired

broa

dcasting

rights,

ordering

t

hat

these

films

be

br

oadcast

in

con

formity

with

article

67

of

the LSCA.

-

The procedure prov

ided un

der AFSCA

Resolution No.

1,502/2014,

amended by

ENACOM Res

olution No.

1,230/2020, which requ

ires the submissi

on of an Annual

Affidavit of Audiov

isual Communicatio

n Services,

through a website creat

ed to such end by t

he enforcement aut

hority.

9.6. Award of a Digital Ch

annel

Through

Resolution

No. 1,

329/AFSCA/2014,

which a

mended

Resolut

ion N

o.

1,047/AF

SCA/2014,

the

AFSCA

approved

the

N

ational

Sta

ndard

for

Terr

estrial

and

B

roadcas

t

D

igital

Television

Audiovisual

Communicatio

n

Services,

a

nd

t

o

Dec

ree

No.

2,

456/2014,

which

ap

proves

the

Nation

al

Dig

ital

Audiovisual

Co

mmunication

Services Plan.

Through

this

lega

l

framew

ork,

which

was

subseq

uently

supplemented

by

Res

olutions

No.

2

4/AF

SCA/2015,

35/AFSCA/2015 and No. 39/A

F

SCA/2015 (among others),

the rights

of the

c

urrent broadcast television

licensees could be

infringed. Th

ese rights s

hould be p

reserved intact

as establish

ed in Law N

o. 26,522, wh

ich

has

higher

hierarchy.

The

mai

n

effect

of

these

re

gulations,

among

their

techn

ical

effects,

is

that

the

curr

ent

broadcast

t

elevision

l

icensees

that

o

btained

their

licenses

pursuant

t

o

L

aw

N

o.

22,285

will

have

to

bear

additional

charg

es

an

d

ob

ligations

inc

luding,

a

mong

o

ther

things,

mu

ltiplexin

g

and

broadcas

ting

u

nder

their

own responsibility other bro

adcast television sta

tions owned by

third parties.

Since

the changes

introd

uced

under this

reg

ulatory

framework

have an

impact on

the

responsibilit

ies

and

righ

ts

of

the

com

panies

invo

lved,

ARTE

AR

and

TELECOR

S.

A.C.I.

filed

a

claim

before

AFSCA

in

due

t

ime,

request

ing

the revocation of Resolutio

ns No. 1,329/AFSCA/2014

, 24/AFSCA/20

15, 35/AFSCA/20

15 and 39/AFSCA/20

15

to preserve their

r

ights intact as direct or

indirect broadc

ast television service lic

ensees. They also filed a

cla

im

before the Nat

ional Exec

utive

Branch requesting

the r

epeal of Decre

e No. 2,

456/2014.

As of the

date

of these

financial statem

ents, t

he cl

aim filed

before

AFSCA

was

dismissed. Th

erefore,

ARTEAR

challenge

d before

the

courts t

hat

agency’s

decisi

on to d

ismiss t

he clai

m. Th

e claim

filed

before

the Nat

ional

Executive

Branch

is still

pending resolution.

The

subs

idiaries

of

the

C

ompany

that

hold

broadcas

t

television

licenses

were

a

warded

a

digital

channel

to

render

terr

estrial

d

igital

television

services

under

th

e

legal

regime

described

a

bove.

The

following

are

the

Resolutions that determ

ined the final awar

d of each of the

digital channels:

•

Resolution N

o.

10,090/ENACO

M/2016

(as

ame

nded

by

Resolution

No.

1631

-ENACOM/201

7)

awarded

Canal 33.1 to ARTE

AR as holder of LS 85 T

V CANAL

13 DE BUENOS A

IRES

•

Resolution

No.

35/

AFSCA/2015

awarded Canal

27.1

to

T

ELECOR

S.A.C.I.

as holder

of

LV81

T

V

C

ANAL

12 DE CÓRDOBA.

•

Resolution No.

381

/AFSCA/2015

awar

ded C

anal 2

7.1

to

Bariloche TV

as holder

of

LU

93

TV

CANAL

6

DE BARILOCHE.

•

Resolution No. 236/AFSCA/2015 award

ed Canal 28.1. to Tel

edifusora Bahiense S.

A. as holder of LU81

TV CANAL 7 DE

BAHÍA BLANCA

GRUPO CLARÍN S.A.

-

54

-

9.7. Decree No. 690/2

0

–

Amend

ments to the LAD

On

August

22,

2

020,

the

National

Ex

ecutive

Br

anch

issued

Dec

ree

N

o.

690/2

020,

wh

ereby

it

amende

d

the

Digital Argentina Act.

Within

the

amendm

ents

introduced,

ICT

services

–

fi

xed

and

mobile

telephony,

subscription

television

and

Internet

–

and the

access

to

telecom

munications

n

etworks

for

and

betwe

en

license

es

are

now

deeme

d

“essential and strategic public services provided on

a competitive basis”, and their effective availability shall be

guaranteed by ENA

COM.

The

pr

ices

of

essen

tial

and

s

trategic

public

ICT

servic

es

provid

ed

on

a

competitive

basis,

the

prices

of

the

services

provided

under

the

Un

iversal

S

ervice

and

of

those

de

termined

by

ENACOM

b

ased

on

r

easons

of

public interest, shall be reg

ulated by said age

ncy.

The

Decree also

prov

ides that

E

NACOM shall

establis

h, in

t

he respective regulations, the

Mandatory Universal

Basic

Provision of

ICT

services

. It

also

provided for

the

susp

ension of

price increases

or

m

odifications

established or announce

d from July 31, 2

020 to Dece

mber 31, 2020 by ICT

licens

ees.

As

of

t

he

date

of

these

consolidated

financial

statements,

the

Decree

has

been

ratified

by

the

Argentine

Congress under t

he terms of Law No.

26,122.

On

December

2

1,

2020,

R

esolutions

Nos.

1466/20

20

and

146

7/2020

were

published

i

n

the

Off

icial

Gazette,

whereby the EN

ACOM reg

ulated Decree No. 6

90/2020.

Resolution

N

o.

1,466/2

020

provides

that

I

CT

Serv

ices

License

es

that

render

Internet

access

,

subscription

broadcasting services by physical, radio-electric or satellite link, and fi

xe

d and mobile telephony services

-in all

cases

in

their

different

and

respective

mod

alities

-

may

increase

up

to

FIVE

PERCENT

(5%)

their

r

etail

prices

as

from

January

2021.

In

order

to

es

tablish

the

perce

ntages

approved,

licensee

s

shall

take

as

r

eference

the

prices effective

as of Jul

y 31,

2020.

Said Resolution

al

so provides

that ICT Services

Licensees may request on

an exceptional bas

is price increases

exceeding 5%

in accordance with the

provisions of Articl

e 48 of the LAD

.

Said

Res

olution

also

prov

ides

that

ICT

Services

Licensees

th

at

hold

registration

for

Internet

Access

Value

Added

Service

(

SVA-INT,

fo

r

its

Spanish

acr

onym);

s

ubscription

broadcast

ing

servic

es

by

physical

an

d/or

radio

-

electric

l

ink

(SRSVFR,

for

its

Spanish

acronym)

and

aud

iovisual

communicat

ion

subscription

services

by

satellite link (DTH); shall

notify the Enforcement Authority about any and

all changes in retail prices the

y inten

d

to

make

to

their

p

lans,

pr

ices

and

commerc

ial

ter

ms

i

n

effect,

SIXTY

(60)

calendar

days

in

advance

of

the

ir

implementation.

Resolution N

o. 1467

/2020 r

egulates t

he Ma

ndatory

Universal Bas

ic Serv

ice set

forth by

Decree

No. 6

90/2020

for the

different

serv

ices provided

by

ICT

Services

Li

cens

ees,

establish

ing

the price an

d characteristics of

eac

h

plan.

Said Resolution also s

ets out the persons t

hat a

re eligible to rece

ive those service

s.

It should be

noted that subscription television service licensees are under the obli

gation to apply discounts to a

plan and programming grid that

already exist, which prevents them from

creating a specific and less expensive

grid to comply with the

Mandatory Univers

al Basic Ser

vice.

Since ARTE

AR owns

sever

al cabl

e tv s

ignals a

nd is

th

erefore a

provid

er of

conte

nts to

subscription

televisio

n

services

via

physical,

radio

-electric

or

satellite

link,

it is

currently

ev

aluating th

e

impact

that th

is regu

lation a

nd

its implementation m

ay have on its o

perations.

9.8.

New

G

eneral

Rules

Governing

Phy

sical

and/or

Radio

Ele

ctric

Link

Subscription

Broad

casting

Services

ENACOM Resolution No.

1,491/2020 issued on D

ecember 2

4, 2020 approv

ed the new Gen

eral Rules

Governing Physical R

adio-

Electric and/or S

atellite Link

Subscription Broadcasti

ng Services.

Even though the new

General Rules mai

ntain the on

erosity of all the br

oadcast television serv

ices and signa

ls

that fall with

in the scope of the “must carr

y” regime (signals and services s

ubject to mandatory retransmission)

by

the

pr

oviders

of

subscr

iption

telev

ision

services

,

they

introduce

the

co

ncept

of

“fair,

equitable

and

reaso

nable

price”

and

i

mplement

a

d

ispute

reso

lution

proced

ure

in

cas

e

of

d

isagreement

between

signal

h

olders

and

GRUPO CLARÍN S.A.

-

55

-

distributors (by phys

ical, radio

-electric or s

atellite link)

to be brought be

fore the E

NACOM, whereby th

e parties

are deemed to have vo

luntarily accep

ted to be subject

to this procedure.

In

addi

tion,

the

Genera

l

R

ules

provide

that

i

n

th

e

eve

nt

that

s

ignal

holders

and

ph

ysical,

radio

-electric

and/or

satellite

link s

ubscription

t

elevision

licensees

do

not

se

ttle

their

dispute,

distributors

shall

include

the

signal

in

the

programming

gri

d

a

t

the

pr

ice

set

by

ENACO

M’s

Board

based

on

the

information

gathered

during

the

proceeding.

It should b

e noted t

hat both

the price

and

the settl

ement proced

ure is a

pplicable t

o any s

ignal, inc

luding thos

e

which are not subject t

o mandatory retrans

mission.

In addition,

the Gener

al Rul

es also prov

ide

that the c

ommercial

ization of

one signal

may not

be con

ditional o

n

the

ac

quisition of

other signals

and, i

n the

case of

sales of

signal

packages

,

the

price mu

st include

a breakdown

of the price of each of th

e signals in

cluded in the pac

kage.

ARTEAR’s

le

gal

advisors

believe

that

the

ENACOM

is

not

emp

owered

t

o

set

t

he

price

of

a

sign

al,

regard

less

of

wheth

er

or

not

it

is

a signal

subjec

t

to mandatory

r

etransmission,

a

nd

tha

t

it

would

be arbitrary

and

unconstitutional

if

the

agency

imposed

a

price

on

the

owner

of

c

ontents

that

does

not

volun

tarily

agree

to

the

settlement proceedi

ng.

9.9. Administrative

Sanction Proceedings

Through

Reso

lution

N

o.

661/AF

SCA/2014,

the

ENA

COM

approved

the

c

urrent

Re

gime

for

the

Grading

of

Penalties, th

e

General

Rules

on

the

procedures

to

be

followe

d for

the

subst

antiation

of

summary

proceeding

s

initiated

due t

o

infringements

of

the

Audiovisu

al C

ommunication

Services

Law,

a

n

Installment

Plan

Regim

e to

be

applied

to

the

infringements

s

ubject

to

fines

committed

from

Novemb

er

21,

2002

up

to

and

including

June

23,

2010,

within

the

frame

work

of

the

effectiveness

o

f

Resolution

No.

830/COM

FER/02

and

Law

No.

22,2

85

and

an

Option

for

the

new

Regime

for

the

Gr

ading

of

Pena

lties

(

fines)

for

infringemen

t

s

comm

itted

w

hile

Resolution No. 324/

AFSCA/2010 was s

till in effect.

ARTEAR

made

a

filing

w

ith

AFSCA

to

req

uest

the

assessment

of

the

f

ines

t

hat

would

be

app

licable

to

infringements

committed

from

November

21,

2002

to

June

23,

20

10

under

the

regim

e

set

fo

rt

h

in

Reso

lution

No.

830/CO

MFER/02

in

or

der

to

dec

ide

wh

ether

to

request

authoriza

tion

t

o

ad

here

to

the

installment

plan

regime

provided

by

Resolut

ion

No.

661

/AFSCA/2014.

I

n

add

ition,

ARTEAR

made

a

f

iling

w

ith

AF

SCA

to

req

uest

the

asses

sment

of

the

f

ines

that

wo

uld

be

applicable

t

o

infringements

com

mitted

from

June

24,

2010

to

June

11,

2014,

i.e.,

the

peri

od

during

which

th

e

regime

provi

ded

under

Res

olution

No.

32

4/AFSCA/2010

was

in

effec

t,

in

order

t

o

decide

wh

ether

t

o

make

us

e

of

t

he

option

pr

ovided

by

R

esoluti

on

No.

661/AFSCA/20

14,

which

allows

broadcasters to

adhere

to the

installment p

lan reg

ime t

hat is mos

t beneficia

l in ea

ch case.

In respons

e to sa

id

filings, the Enforcement Aut

hority notified ARTEAR of the fines assessed

on the infringements committ

ed from

November 21, 2002 to June 23, 2010. ARTEAR requested authorization to adhere to the payment plan regime

payable

i

n

up

to

60

instal

lments

for

all

those

infringements

over

w

hich

the

Enforc

ement

Auth

ority

a

bandoned

all administrative

and judicial

proc

eed

ings. AFSCA

notified ARTEAR of

the applicable

fin

es i

n the period

d

uring

which

Resolution

No.

3

24/AFSCA/2010

w

as

in

ef

fect,

calculatin

g

those

fines

under

bot

h

regimes,

t

he

one

approved

throu

gh

R

esolution

No.

324

/AFSCA/2010

and

th

e

on

e

approv

ed

under

Res

o

lution

No

.

661/AFSCA/2014.

Therefor

e, ARTEAR

made

a fi

ling exerc

ising the

option

to pay

those f

ines ca

lculated un

der

the

regime

established

by

Resolution

No.

661/AFSCA/201

4,

which

allows

for

t

he

assessment

of

signi

ficantly

more

beneficial

a

mounts.

I

n

both

cases,

ARTEAR

h

ad

booked

a

provision

for

the

a

mounts

as

sessed

and

notified by AFSCA

included in the

payment plan.

The

payment

agre

ements

t

hat

had

bee

n

delivered

by

AFSCA

w

ere

deem

ed

to

enter

into

effect

as

of

Ju

ly

2,

2015.

ARTEAR

was

authorized

to

a

dhere

t

o

the

pay

ment

p

lan

relating

to

infringements

committed

betwe

en

November

21,

20

02

and

June

23,

2010,

payab

le

in

sixty

monthly

installmen

ts

s

tarting

on

August

31,

2015.

ARTEAR

was

also

a

uthorized

to

adhere

to

the

applica

ble pay

ment

pla

n f

or

infringemen

ts

c

ommitted

betwe

en

June 24, 2010 and J

une 11, 2014, payab

le in thirty mo

nthly installments s

tarting on August 31, 2

015.

ARTEAR

is

c

urrently

paying

the

installments

of

both

payment

p

lans

and

receives

and

pays

in

due

time

and

form

the

f

ines

corr

esponding

to

t

he

summ

ary

procee

dings

initiated

after

June

11,

2014

under

the

Sanct

ion

Regime in effect estab

lished by Reso

lution No. 661

-A

FSCA/14.

Through

Resolution

No.

2,882/ENACOM/201

9,

as

a

mended

by

Resolution

No.

2,984/2019,

the

ENACO

M

amended the Reg

ime for the G

rading of

Penalties approv

ed by Resolution

No. 661/AFSCA/2014. T

he

amendments

resulted

mainly

in

a

reduction of

t

he tax

rates

to

be

applied

to

the

calculation

of

the

penalties

for

infringement

of

Law

No.

26,522,

and

a

reduction

of

the

fines

imp

osed

wheneve

r

infractions

are

c

ommitted

in

GRUPO CLARÍN S.A.

-

56

-

shows

produced

by

producers

that

are

duly

registered

in

the

Registro

de

Señales

y

Productoras

(Registry

of

Signals and Producers

), which will be ch

arged with suc

h infractions.

ARTEAR

ma

de

a

filing

w

ith

the

ENACOM

requestin

g

t

he

ass

essment

of

fines

applicable

to

the

infri

ngements

committed from July 2014 up to and including Decem

ber 2018 and requested the adherenc

e to the installment

payment

plan

established

under

Resolution

No.

2,882/ENACOM/2

019,

with

respect

to

th

ose

summary

proceedings

on w

hich

infor

mation

was

requested

and

sanctions

w

ere

imposed.

The

aggreg

ate

am

ount

of

the

fines

assessed

f

or

that

per

iod

for

wh

ich

a

final

decision

has

already

been

r

endered

o

n

the

summ

ary

proceedings

LS85

TV

Canal

13

is

of

$2,343,755

.70.

ARTEAR

execute

d

an

agreement

with

the

Enforceme

nt

Authority to settle that

amount in a single

installment.

NOTE 10 - CALL OPTION

S

ARTEAR

Pursuant

to

ARTEAR’s

acquisition

of

85.2%

of

its s

ubsidiary

Te

lecor’s

c

apital

sto

ck

in

2

000,

Te

l

ecor’s

sellers

have

an

irrevocable

put

option

of

the

rem

aining

755,565

com

mon,

registered,

non

-endorsable

shares

,

representing

14.

8%

of

the

capital

stoc

k

and

votes

of

Telecor, f

or

a

16

-year

term

as

from

March

16,

2010

at

a

price

of

US$

3

m

illion

and

ARTEAR

has

a

n

irrevocable

call

option

for

such

shares

for

a

term

of

26

years

as

from

March 16,

2000 at

a price

of ap

pr

oximately US$

4.

8 mi

ll

ion,

which will

be adjusted

at a

5% nominal

ann

ual

rate

as from

April 16,

2016. Subsequently,

under an addendum

to

the ori

ginal agreements,

the beginning

of the

effectiveness

of

the

irrevocable

put

option

was

modified

on

several

occ

asions.

The

last

ad

dendum,

dated

November

27,

2019

,

set

forth

that

the

eff

ectiveness

of

the

irrev

ocable

put

o

ption

would

begin

on

March

16,

2024.

The

balances

arisin

g

from

the

put

op

tion

mentioned

a

bove

are

disclose

d

under

the

it

em

Other

Non

-Curr

ent

Liabilities

of

the

statement

of

financial

position,

with

an

offsett

ing

entry

under

Other

Reserves

and

Non

-

Controlling Interest un

der Equity.

NOTE 11

–

FINANCIAL

INSTRUM

ENTS

11.1. Financial Risks

Management (*)

(*) The amounts

included in this n

ote are stated in million

s of Argentine pesos.

Grupo

Clarí

n

is

a

party

to

tr

ansactions

involving

f

inancial

instru

ments,

w

hich

en

tail

exposure

to

market,

c

urrency

and

interest

ra

te

risk

s.

The

ma

nagement

of

these

risks

is

based

on

the

p

articular

ana

lysis

of

e

ach

situat

ion,

taking into account its own estimates and

those mad

e by third pa

rt

ies of the evolution of

the respective factors.

11.1.1 Capital Risk M

anagement

Grupo

Clarín manages

its

capital

structur

e

seeki

ng

to

ensure i

ts

ability to

con

tinue

as

an

ongo

ing

concern,

while

maximizing the return to

its shareholders thr

ough the optim

ization of financial d

ebt and equity balanc

es.

As

part

of

this

process,

G

rupo

Cl

arín

monit

ors

its

c

apital

struct

ure

throu

gh

the

financial

deb

t

-

to

-equity

ratio,

which is equal to the

quotient of its n

et financial debt

(Financial Debt

less Cash and Cash

Equivalents)

divided

by its adjusted EBITD

A.

The financial debt-

to

-equity ratio for th

e reporting year

s is as follows:

December 31,

2021

December 31,

2020

Financial Debt (i)

1,691

2,586

Less: Cash and Cash Equivalents

Cash and Banks

(2,213)

(1,953)

Other Current Investments

(2,071)

(2,254)

Net Financial Debt

(ii)

(2,593)

(1,621)

Adjusted EBITDA

6,240

4,899

Debt-

to

-Equity Ratio

(ii)

(0.42)

(0.33)

(i)

Long

-term and short-term

loans, including deri

vatives and financial g

uarantee agreemen

ts.

GRUPO CLARÍN S.A.

-

57

-

(ii)

As of December 31, 2021 and

2020, the cash and ca

sh equivalents balan

ce exceeds the amount

of loans.

The financial debt-

to

-equity ratio is

reasonable compared to other industry players an

d considering the

particular situation of

Argentina and of

the companies

that make up Gr

upo Clarín.

11.1.2 Categories of

Financial Inst

ruments

December

31, 2021

December

31, 2020

Financial Assets

At amortized cost

Cash and Banks

2,213

1,953

Other Investments

28

91

Receivables

(1) (2)

14,150

15,508

At fair value with an impact on net income

Other Investments

2,064

2,864

Total Financial Assets

18,455

20,416

Financial Liabilities

At amortized cost

Financial Debt

(3)

1,691

2,586

Accounts Payable and Other Liabilities

(4)

9,279

10,663

Total Financial Liabilities

10,970

13,249

(1)

Does not inc

lude the allowance

for doubtful account

s of approximately $ 573

million and $ 774

million, respectivel

y.

(2)

Includes re

ceivables with rela

ted parties of appr

oximately $ 824 a

nd $ 1,070 million, re

spectively.

(3)

Includes loan

s with related par

ties in the amount of appro

ximately $ 26 million a

s of December 31, 2

020.

(4)

Includes debt

s with related parti

es of approximately $

311 million an

d $ 311 million, respe

ctively.

11.1.3 Objectives of

Financial Risk

Management

Grupo Clarín monitors and manages the financi

al risks related to its operations; these risks include market risk

(including exchange r

isk, interest rate r

isk and equity pr

ice risk), credit risk and

liquidity risk.

Grupo Clarín does not e

nter into financial

instruments for specul

ative purposes

as common pract

ice.

11.1.4 Exchange Ris

k Management

Grupo

Clarín

enters

into

certain

for

eign

curr

ency

transac

tions;

therefore,

it

is

exposed

to

exchange

r

ate

fluctuations.

The

fo

llowing

table

shows

the

monet

ary

assets

and

liabilities

denomi

nated

in

U

S

dollars

,

the

main

foreign

currency

involved

in

G

rupo

Clarí

n’s

trans

actions,

at

t

he

closing

of

the

y

ears

e

nded

Dec

ember

31,

2021

and

2020:

(in millions

of Argentine

pesos)

of Argentine

pesos)

December 31,

2021

December 31,

2020

ASSETS

Other Receivables

57

54

Trade Receivables

564

806

Other Investments

565

1,106

Cash and Banks

1,077

1,114

Total assets

2,263

3,080

LIABILITIES

Financial Debt

1,271

2,148

Other Liabilities

195

91

Trade and Other Payables

899

1,885

Total Liabilities

2,365

4,124

Bid/offered

exc

hange

rates

(Banco

de

la

Nac

ión

Argenti

na)

as

of

Dece

mber

31,

2021

a

nd

2020

were

of

$102.52

and $ 102.72 and $

83.95 and $ 84.

15; respective

ly.

GRUPO CLARÍN S.A.

-

58

-

11.1.4.1 Foreign

Exchange Sensitivity

Analysis

Grupo Clarín is expose

d to exchange risk, ma

inly with res

pect to the US dollar.

Taking

into

consideration

t

he

b

alances

disclosed

ab

ove,

Grupo

Clarí

n

estimates

that

the

im

pact

of

a

20%

favorable/unfavora

ble

f

luctuation

of

the

U

S

dollar

exchange

rat

e

wou

ld

generate

an

inco

me/loss

b

efore

tax

es

of approximately $ 20 m

illion and $

209 million as of D

ecember 31, 202

1 and 2020, respective

ly.

The

sensitivity

analysis

presented

above

is

hypothetical

since

the

quantif

ied

impact

is

not

necessarily

an

indicator of the actual

impact, because ex

posure level

s may vary over tim

e.

Additionally, ev

en though

Grupo Cl

arín con

ducts its op

erations in

Argentine

pesos,

an eventual

devaluation of

that curr

ency

may

hav

e

an

ind

irect

imp

act o

n

its

opera

tions,

depending

on

the

ability

of

the

r

elevant

suppliers

to reflect that effect on th

eir prices.

11.1.5. Interest Rate Ri

sk Management

As of

December

31,

20

21

and

20

20, Gr

upo

Clarín

w

as

exposed

to

in

terest

rate

ri

sk

mainly

thro

ugh

ARTEAR,

AGEA

(a

nd

its

su

bsidiaries

LVI

and

DLA),

IE

SA,

R

adio

M

itre,

and

GCG

C.

This

is

due

to

the

fact

that

th

ose

companies

have

taken

lo

ans

at

fixed

and

var

iable

interest

rates

and

have

not ente

red

into

hedge

agree

ments

to

m

itigate

these

risk

s.

If

interes

t

rates

had

eventually

been

100

basis

points

h

igher

and

all

the

varia

bles

had

remained

const

ant,

th

e

add

itional

esti

mated

loss

before

tax

es

wo

uld

have

been

of

approximate

ly

$

18

m

illion

and $ 20 million as o

f December 31, 2021

and 2020, res

pectively.

11.1.6. Equity Price Ri

sk Management

Grupo

Clarín is

exposed

to

equity

price

r

isk

in

con

nection

w

ith

its

hold

ings

of

mutu

al

funds,

securi

ties

and

bonds

and foreign exchang

e agreements

.

Its sensitivity to the vari

ation in the price

of these instruments is

detailed below:

December 31,

2021

December 31,

2020

Investments valued at quoted prices at closing (Level 1)

1,541

1,843

The estimated

impact

of a

n ev

entual 10%

favora

ble/unfavorable f

luctuation

of the

quoted

price o

f inves

tments

valued at

closing, assuming that all the

other variables remain constant, would generate an

income/loss

before

taxes of approximately $

154 million

and $ 18

4 million as of Dece

mber 31, 2021 a

nd 2020, respectively.

A

potential

10%

favorable/unfavorabl

e

fluctuati

on

of

the

quoted

price

of

investm

ents

value

d

as

Level

2

would

generate an

income/

loss before

taxes

of

approximately $ 52

million and $

103 m

illion as of

D

ecember 31, 2021

and 2020, respectively.

11.1.7 Credit Risk M

anagement

Credit

risk

is

defined

as

t

he

risk

that

one

of

the

parties

may

breach

its

contractu

al

obligations,

generating

an

eventual financial loss

for Grupo Clarín.

Credits of the Print and

Digital Publicati

ons Segment

The

companies

that

o

perate

in

this

segment

c

onduct

a

n

analysis

of

the

clients’

finan

cial

position

at

the

be

ginning

of

the

busi

ness

rel

ationship,

through

a

cred

it

risk

rep

ort

req

uested

fr

om

s

everal

credit

rating

agenci

es.

Th

e

credit amount grant

ed to eac

h client is monitored

on a daily bas

is, with re

p

orts being sub

mitted to the financ

ial

management.

The

credit

r

isk

aff

ects

c

ash

an

d

cash

equivalents,

d

eposits

h

eld

at

banks

and

financial

institut

ions,

as

well

a

s

credit granted to clients.

The

maximum theoretical

credit risk

ex

posure of

the companies

op

er

ating i

n this

s

egment i

s represented

by the

book value of net fina

ncial assets, disclose

d in the cons

olidated statement of fi

nancial position.

GRUPO CLARÍN S.A.

-

59

-

For

the

purposes

of

con

ducting

an

analysis

of

the

suitability

of

the

allowa

nce

for

bad

debts,

these

compan

ie

s

consider

each

c

lient on

a

c

ase

by

cas

e

basis,

verifying, among

ot

her

fac

tors, i

f

there is

any record

of

delinquency, risk of

bankruptcy, insolve

ncy proceed

ing or other j

udicial proceed

ing.

In addition, and i

n

accordance

with

IFR

S

9,

for

the

ca

lculation

of

the

a

llowance

for

bad

debts on

tra

de

receivables

t

he

Company

considers

th

e

exp

ected

credit

losses

over

their

total

useful

life.

Trade

receivables

comprise

a

sign

ificant

n

umber

of

clients and

are internally classified

among the

following categories: Advertising, Official, Di

stri

bution, Internet

and Subscriptions, a

mong others.

The compa

nies tha

t operat

e in t

his se

gment

have rec

orded an

allowance

for

dou

btful accou

nts accou

nting f

or

10% of accounts rec

eivable as of Decemb

er 31, 2021 and

2020, respectiv

ely.

The

companies

that

o

perate

in

this

s

egment

did

not

set

up

an

allow

ance

for

bad

debts

for

those

amounts

in

which no significant cha

nge was recorded

in the credit

rating, considering such

amounts as recovera

ble.

The

co

mpanies

that

operate

in

this

segment

have

a

w

ide

r

ange

of

c

lients,

including

individuals,

businesses

-

medium-

and

-large-

sized

companies

-

and

governm

ental

a

gencies.

T

herefore,

t

hese

companies’

receivables

are not subject to cre

dit risk concentratio

n.

Credits from the Broadcas

tin

g and Programm

ing Segment

Credit risk represents for the companies that operate in this segment the risk of incurring in losses arising from

possible

breaches of

the contractual

obligations assumed

by

business or

financi

al

counterparties. This

risk

may

be

due

to

economic or

financ

ial

factors

,

or

to

particular circumstances

of

the

count

erparty,

or

to

other economic,

commercial or admin

istrative factors.

Credit risk affects cash and

cash equivalents, deposits

held at banks and financi

al institutions in a wi

de sense,

and

every

f

orm

of

c

redit

granted

to

the

com

panies

that

operate

in

th

is

se

gment.

The

maximum

exposure

to

credit risk

is repres

ented b

y the

value

of fi

nancial ass

ets considered

as

a who

le,

recorded

in the

Consol

idated

Statement

of

Financial

Positio

n

under

Cash

and

Ba

nks,

O

ther

Investments,

T

rade

R

eceivables

and

Ot

her

Receivables.

Financial

instruments

are

ex

ecuted

with

creditworthy

bank

s

and

financial

institutions

renowned

in

the

mark

et

and

for

terms

not

longer th

an t

hree

months.

In this

sense,

the

co

mpanies

that

op

erate

in

this

seg

ment

have

a

policy

of

diversifyi

ng

their

investments

amon

g

differe

nt

banks

and

f

inancial

institutio

ns,

thus

reducing

the

concentration risk in on

ly one counterp

arty.

As

to

the

credit

risk

financ

ial

c

redit,

the

companies

that

op

erate

in

this

segment

evaluate

th

e

c

redit

standing of

the different counterparties to de

fine their investment levels, ba

sed on their

equity and credit

rating.

As to Tra

de Rec

eivables,

such

companies

have a

wid

e range

of c

lients,

categoriz

ed depending

on t

he ty

pe of

business. These categories are: Advertising, Signals, Programming and o

ther. Within this classification, clients

can

also

be

classif

ied

as

adv

ertising

agenc

ies,

direct

advertisers

,

distributors

of

cab

le

TV,

bro

adcast

T

V

stations

and other, each of them of

a different magnitud

e. Due to this diversity of c

lients, there is not a sig

nificant credit

risk concentration in this re

spect.

The allowance for bad

debt

s is set

up upon conducting an analysis

of the debtor portfolio,

which is recorded as

follows:

−

In the

case

of individual ri

sks

i

dentified (risks of

bankru

ptcy, insolvency

proceeding

s or

j

udicial

proceed

ings

pending with the co

mpany), for its total val

ue.

−

The

rest

of

the

cases

is

decided

based

on

the

aging

of

the

past

due

de

bt,

the

pr

ogress

of

the

c

ollection

procedures, the solvenc

y conditions and th

e variations

observed in the clie

nts’ settlement periods.

−

In

addition,

and

in

accorda

nce

w

ith

IFR

S

9,

for

the

calculati

on

of

th

e

allowance

for

bad

debts

on

trade

receivables the Co

mpany considers

the expected credit loss

es over their tota

l useful life.

11.1.8. Liquidity Risk

Management

Liquidity

risk

is

the

r

isk

that

Gr

upo

Clarín

may

n

ot

be

able

to

fu

lfill

its

financial

obligations

at

m

aturity.

Grupo

Clarín

manages

liquidity

ri

sk

through

the

m

anagement

of

its

capital

s

tructure

and,

if

poss

ible,

the

acc

ess

to

different capital markets. It

also manages liquidity risk through a

constant review of the estimated cash flows

to

ensure that it will hav

e enough liquidity t

o fulf

ill its obligations.

GRUPO CLARÍN S.A.

-

60

-

11.1.8.1 Interest Rate

Risk and Liquidity R

isk Tabl

e

The

following

table

shows

the

break

down

of

financial

liabilities

by

relevant

groups

of

maturities

based

on

the

remaining

perio

d

as

fro

m

the

d

ate

of

the

statement

of

financial

pos

ition

throu

gh

the

contract

ual

ma

turity

dat

e.

The amounts disclosed

in this table represent un

discounted cash f

lows (principal plus con

tractual interest).

Information as of D

ecember 31, 2021:

Maturities

Financial

Debt

Other

debt

Matured

-

2,545

Without any established term

3

847

First Quarter 2022

544

5,632

Second Quarter 2022

368

436

Third Quarter 2022

456

18

Fourth Quarter 2022

284

14

More than 1 year

492

327

2,147

9,819

Information as of D

ecember 31, 2

020:

Maturities

Financial

Debt

Other

debt

Matured

-

2791

Without any established term

5

894

First Quarter 2021

406

5020

Second Quarter 2021

89

1158

Third Quarter 2021

57

48

Fourth Quarter 2021

86

24

More than 1 year

2,453

510

3,096

10,445

11.1.9. Financial Instrume

nts at Fair Value

The following table shows Grupo Clarín’s financial assets and liabilities meas

ured at fair value at the

c

losing of

the reporting year:

December 31,

2021

Quoted Prices

(Level 1)

Other Significant

Observable Items

(Level 2)

Assets

Current Investments

2,064

1,675

389

December 31,

2020

Quoted Prices

(Level 1)

Other Significant

Observable Items

(Level 2)

Assets

Current Investments

2,864

2,029

835

Financial

assets

and

liabiliti

es

are

val

ued

using

quoted

prices

for

ide

ntical

assets

and

liabilities

(Level

1),

and

the

prices

of

similar

instruments

arising

from

sources

of

information

available

in

the

market

(Level

2).

At

t

he

closing of

the

reporting y

ears,

Grupo Clarín

did

not h

ave any

financia

l asset

or l

iability for

which

a c

omparison

had not been conducted

against observ

able market da

ta to determine t

heir fair value (Leve

l 3).

11.1.10. Fair Value of

Finan

cial Instruments

The book value of

cash,

accounts receivable and current liabilities is similar to

the

ir fair value, due to

the short

-

term maturities of thes

e instruments.

The

book value

of receivables with

estimated collection

periods that

extend throug

h

t

ime, is

measured

considering the estimated collectio

n period, the time value of money

and the specific risks of the transaction at

the time of measur

ement and, therefor

e, such book va

lue approximates th

eir fair value.

GRUPO CLARÍN S.A.

-

61

-

The fa

ir v

alue

of

non-c

urrent

fina

ncial

liabilities

(L

evel

2)

is

measured

base

d o

n t

he

future

cash

flows of

thos

e

liabilities,

d

iscounted

at

a

representative

market

rate

available

to

Grupo

Clarín

for

liabilities

with

s

imilar

terms

(currency and remain

ing term) prevaili

ng at the time of

meas

urement.

The following table sho

ws the estimat

ed fair value of n

on

-current f

inancial liabilities

:

December 31, 2021

December 31, 2020

Book Value

Fair Value

Book Value

Fair Value

Non-Current Financial Debt

87

76

2,173

1,802

NOTE 12 - INTERE

STS IN SUB

SIDIARIES AND

AFFILIATES

1-

AGEA and sub

sidiaries

a)

On

January

13,

2021,

AGEA

acquired

13,429,

076

common,

registere

d,

non

-

endorsable

shares,

with

nominal

value

of

$

1

each

and

e

ntitled

to

one

(1)

vote

p

er

share,

of

the

capital

stock

and

votes

of

Urbano

Express

Argentina

S

.A.

(“

Urbano”),

a

co

mpany

mainly

eng

aged

in

renderin

g

postal

services

,

in

the

amount

of

US$

1,310,000

payable

thro

ugh

the

de

livery

of

advertising

spaces

and/or

s

econds

(

as

th

e

case

may

be)

in

AGEA

an

d/or

through

AGEA,

in

cer

tain

mpanies,

as

established

in

the

purchase agreement

.

On

the

sam

e

date,

AGEA

sold

to

Urbano

36,900,000

s

hares

repres

enting

100%

of

the

capital

s

tock

and

votes

of

UNIR

for

$

90

milli

on,

which

originated

a

credi

t

in

favor

of

AGEA.

At

the

S

hareholders’

Meeting

held

on

January

13,

2021,

the

s

hareholders

of

Urban

o

decided

to

appr

ove

the

cap

italization

of

s

uch

credit

of

AGE

A

and

an

increase

in

t

he

capita

l

s

tock

of

$

15,662,

647

with

paid

-in

capital

of

$74,337,353. Through

this capitalization, A

GEA became

th

e

holder of

15,662,6

47

common, registered,

non

-endorsable

sh

ares,

with

nominal

value

of

$

1

each

and

entitled

to

one

(1) vote

per

share

of

Urbano.

As

a

r

esult

of

those

transactions,

AGEA

became

the

holder

of

29,091,723

com

mon,

registered,

non

-

endorsable shares, with n

ominal value of $ 1 each

and entitled to one (1

) v

ote per share, represe

nting

30%

of

the

cap

ital

stock

and

votes

of

Urban

o.

As

from

J

anuary

13,

2020,

AGEA

has

significant

influence

over Urbano and

has complete

d the necessary

analyses for record

ing the acq

uisition of this ass

ociate

in conformity with I

AS 28.

During

O

ctober

2021,

AGEA

acq

uired

3

59

C

lass

C

bo

ok

-entry

comm

on

s

hares

of

Pa

pel

Pre

nsa

with

nominal

val

ue

of

$

1

each and

entitled

t

o

on

e

(1)

vote

per

share

for

$

5,000

($5,323

in

constant

currency

as of December 31,

2021).

b)

On

October

13,

2020,

AG

EA

and

Botón

de

Pago

S.A.

incorpor

ated

a

company

under

the

corp

orate

name

Billetera

Móvil

S

.A.

(“

BIMO”)

mainly

engaged

in

the

prov

ision

of

electronic

payment

s

ervices.

BIMO

has a

capital

stock of

$ 1,000,000,

re

presented

by

1,000,000

common shares

with

nom

ina

l

value

of $

1 each, entitled to

one vote per

share. AGEA holds a 50%

interest in the

ca

pital stock and

votes of

BIMO. On January

18, 2021, BIMO was re

gistered wit

h the IGJ.

During

th

is

year,

AGE

A

m

ade

co

ntributions

in

BIMO

for

a

t

otal

of

$

183,00

0,000

($

212,322,367

in

constant currency as o

f December 31, 2021).

At t

he

Shareholders’

Meetings

of

BIMO

held

on

May

12,

2021

and S

eptember

30,

2021,

the

shareholders

approved

the

capitalization

of

the

contributions

for

$

37,054,969

a

nd

$

1

07,792,792.

In

addi

tion,

at

the

Shareholder

s’

Meeti

ng

he

ld

on

September

30,

2021,

the

shareh

olders

approved

the

capitalization of

a credit

t

hat

BIMO held

w

ith B

IMO for

$ 53

,033,3

86

($

58,4

48,201 in

constant currency

as of December 31,

2021). AGEA sti

ll holds a 50% inte

rest i

n BIMO.

2-

ARTEAR and G

C Minor

a)

On July 22, 2021, ARTEAR and GC Minor

received

and accepted an offer

for the acquisition of shares

submitted

by

Tel

evisión

L

itoral

S

.A.

and

Marg

arita

Scaglione

(“the

purchasers

”),

whereby

ARTEAR

and

GC

Min

or

shall

sell

9,990

and

10

shares,

respectively,

of

Bar

iloche

TV

S.A.

representing

,

aggregate,

100%

of

the

capital

s

tock

and

votes

of

that

co

mpany,

f

or

a

lump

-sum

of

US$

600,000,

to

be

paid

pro

rata.

The

paymen

t

will

b

e

made

by

the

purchasers

i

n

two

instal

lments

of

US$

300,000

each. Th

e

first

installment was settled

in July 2021 and the sec

ond one is

due

on

D

ecember 1, 2022.

GRUPO CLARÍN S.A.

-

62

-

NOTE 13 - CAPITAL

STOCK, RE

SERVES, ACC

UMULATED IN

COME AND DI

VIDENDS

13

.1

–

Capital stoc

k

Upon

the

Company’s

public off

ering during

2

007,

the capital

s

tock

amounted to

$

287,418,584, represented by:

-

75,980,304

Class

A

c

ommon,

r

egistered,

non

-

endorsable

sh

ares,

with

n

ominal

value

of $

1

each an

d

entitled to five votes per sh

are.

-

186,281,411

Class

B

boo

k-entry

common

shares,

with

nom

inal

value

of

$

1

each

and

entitled

to

on

e

vote per share.

-

25,156,869

Class

C

comm

on, re

gistered,

non

-e

ndorsable

shares,

with nom

inal

value

of

$

1

e

ach a

nd

entitled to one vote per s

hare.

On

October

5

an

d

11,

2007,

th

e

CN

V

and

BCBA,

r

espectively,

gr

anted

auth

orization

for

the

Company’

s

admission to

the init

ial publi

c offering

of its

capital s

tock, author

izing the

Company

to (i)

offer public

ly its Cl

ass

B

book-e

ntry

c

ommon

s

hares;

(ii)

list

its

Class

B

book

-entry

common

share

s;

an

d

(iii)

list

its

registere

d

non

-

endorsable Class C

common sh

ares, trading

of which

was suspende

d due to res

trictions on

transfers s

et forth

in

the

Company’s

Bylaws.

Also

in

the

last

quarter

of

2007,

the

Compa

ny

was

granted

auth

orization

to

list

its

GD

Ss in the LSE. Each GD

S represents two of t

he Company

’s Class B common

shares.

On Apri

l 2

7, 2

017,

the

IGJ

registered

the

Corp

orate

Reorga

nization

Transaction

which

co

nsisted

in t

he

partial

spin-off

of

t

he

Comp

any

for

the

creat

ion

of

a n

ew

company

called

C

a

blevisión

Ho

lding

S.

A.

As

a

result

of

the

Spin-

off

of

Grupo

Clarín,

its

equity

was

red

uced

pro

rata

and

the

C

ompany’s

C

lass

A,

Class

B

and

Class

C

shares were canceled in

exchange for a set of shares

of the same class and w

ith substantially the same r

ight

s

distributed by Cablev

isión Holding.

Consequently,

the

C

ompa

ny’s

equity

was

reduce

d,

e

ffective

as

of

the

Effective

Date

of

the

Spin

-off

(

May

1,

2017), to $ 106,776,0

04, represented by:

-

28,226,683

Class

A

c

ommon,

r

egistered,

non

-

endorsable

sh

ares,

with

n

om

inal v

alue

of

$

1 each

and

entitled to five votes per sh

are.

-

69,203,544

Class

B

b

ook-

entry

c

ommon

sh

ares,

with

nominal

v

alue

of

$

1

e

ach

and

ent

itled

to

one

vote per share.

-

9,345,777

Class

C

co

mmon,

registered,

non-end

orsable

shares,

with

nominal

value

of

$

1

each

and

entitled to one vote per s

hare.

Having

obt

ained

a

ll

of

the

required

regulatory

authoriz

ations,

o

n

August

30,

2017,

Grupo

Clarín

and

Cablevisión

Holding

exchanged their

s

hares pursuant

to the

excha

nge

ratio approved

by

Grupo Clarín's shareholders

at

the

time

of approval

of

the

sp

in-

off

process

.

As a

result of

th

e

exchange

of shares

and

payment of

fr

actions in

cash,

the Company held 1,485 treasury shares. During 2020

, the Company sold all those shares, and does not have

any treasury shares as

of the date of th

ese financial st

atements.

13

.2

–

Reserve

s, accumulated inco

me and

dividends

December 31,

2021

December 31,

2020

Balances at the beginning of the year:

Retained Earnings

(416,089,457)

(3,097,437,255)

Other Reserves

(259,342,725)

(243,726,244)

Voluntary Reserves

2,254,278,015

Total

1,578,845,833

(1,086,885,484)

Changes in minority interest in a subsidiary

-

(17,674,726)

Sale of Treasury Stock

-

79,686

Absorption of Retained Earnings with Paid-in Capital

416,089,457

3,097,437,255

Net Income (Loss) for the Year

1,039,043,355

(414,110,898)

Balance at the end of the year

3,033,978,645

1,578,845,833

GRUPO CLARÍN S.A.

-

63

-

a. Grupo Clarín

On

April

30,

2020,

at

t

he

Annual

Ordinary

Shareholders'

Meeting

of

Grupo

Clarín

S.A.,

the

shareholders

decided,

among

ot

her

things,

to

absorb

the

negative

balanc

e

of

reta

ined

earnings

as

of

December

3

1,

20

19

through the partial revers

al of the P

aid-

in capital.

On

Apr

il

30,

20

21,

at

the

Annual

Ordinary

and

Extraordi

nary

S

hareholders'

Meeting

of

the

Company,

the

shareholders

dec

ided,

among

other

things,

to

absorb

t

he

negative

balance

o

f

reta

ined

earn

ings

as

of

Decembe

r

31, 2020 through the

partial reversal

of the Paid-i

n capital.

b. ARTEAR

At

the

Ge

neral

Ord

inary

an

d

Extraordi

nary

Shareh

olders’

Mee

ting

hel

d

on

M

ay

28

,

2020,

the

sharehol

ders

of

ARTEAR

decided,

amo

ng

other

things,

to

appropriate

the

accumul

ated

retained

earni

ngs

for

the

year

ended

December

31,

2020

which

amounted to

$

3

40,754,471

in

historical

curre

ncy

as

of

that

date

($

700,

225,993

in

constant currency as of December 31, 2021) as follows: (i) $ 1

56,54

6,983 ($ 321,692,822 in constant currency

as

of

December

31,

2

021)

to

increase

the

Legal

Reserve

and

(ii)

$

18

4,207,488

($

378,533,171

in

cons

tant

currency as of

December 3

1, 2021) to

increase the

voluntary reserve.

In additio

n, the shareh

olders decide

d to

delegate to the

Board of Dir

ectors the po

wer to partial

ly reverse the

Voluntary R

eserve up to

$ 250,000,0

00 to

pay dividends.

At the General E

xtra

ordinary

Shareholders’ Meeting held on September 9, 2020, the shareholders of ARTEAR

approved

the p

artial

reversal

of

the

Voluntary

Reserve

for

$ 448,230,

000 ($

753,

200,614

in

constant

curre

ncy

as of December 31,

2021), to be used

for the distributi

on of dividends.

At

t

he

G

eneral

Ordinary

a

nd

Extraordinary

Share

holders’

Meeting

of

ARTEAR

held

on

April

22,

202

1,

t

he

shareholders

of

the

C

ompany

deci

ded,

among

oth

er

things,

to

fully

absorb

the

net

loss

for

the

ye

ar

ende

d

December

31,

2020

which

amounted

to

$

261

,032,37

1

in

historical

currency

as

of

that

date

($

394

m

illion

in

constant currency as of D

ecember 31, 2021) thro

ugh the partial revers

al of the Voluntary

Reserve. In addition

,

the

shar

eholders

d

ecided

t

o

de

legate

to

the

Board

of

Directors

the

power

to

p

artially

reverse

the

Voluntary

Reserve

u

p

to

$

500,00

0,000

to

pay

div

idends.

Said

power

may

be

exercised

by

the

Board

of

Directors

at

its

discretion in one or more t

imes until the

next Ann

ual S

hareholders Meeting of

that compa

ny is held.

At

the

meeting

hel

d

on

May

13,

2021,

the

Board

of

Directors

of

ARTEAR

approved

the

partial

rev

ersal

of

the

Voluntary Reserve for $

150 million ($ 186.4 mil

lion in constant currency as of

December 31,

2021), to be

us

ed

for the

distribution of

dividends

.

As of

the date of

th

ese consolidated

fin

ancial statements,

the full amount

of the

distributed dividends was c

ollected.

At

the

meeting

held

on

Jul

y

22,

2021,

the

Bo

ard

of

Directors

of

ARTEAR

approved

the

partial

reversal

of

th

e

Voluntary Reserve for $

150 million ($ 175.4 mil

lion in constant currency as of

December 31, 2021), to be

used

for the

distribution of

dividends

.

As of

the date of

th

ese consolidated

fin

ancial statements,

the full amount

of the

distributed dividends was

collected.

c. Other Companies

In April 2021,

the sharehold

ers of TRIS

A decided, a

mong other

things, to ap

prove the distri

bution of d

ividends

in the amo

unt of $ 2

00 million

($ 267.26 m

illion in cons

tant currency

as

of December

31, 2

021) of which

$ 100

million correspo

nds to t

he Comp

any on

account of

its

indirect hold

ing in t

hat com

pany. As o

f the

date of

these

financial statements, th

e full amount of

the distributed divid

ends was collecte

d.

In August 2021, t

he shareh

olders of Canal

Rura

l S.A. decid

ed, among ot

her things, to

approve the

distribution

of dividends in

the amount of $ 60

million of which $

23

.9 million corresponds to

the Company on account of i

ts

indirect holding in that com

pany.

In April 2020,

the sharehold

ers of TRIS

A

decided, amo

ng other th

ings, to approv

e the distribut

ion of dividends

in

the

amount

of

$

170

m

illion

($

22

7.17

million

in con

stant

currency

as

of

December

31,

20

21)

of

wh

ich

$

85

million

($

113.59

million

in

constant

currency

as

of

December

31,

2021)

corr

e

sponds

to

the

Compa

ny

on

account

of

its

indirect

holding

in

t

hat

company.

As

of

Dec

ember

31,

2020,

TRISA

paid

all

of

th

e

distribut

ed

dividends.

GRUPO CLARÍN S.A.

-

64

-

NOTE 14 -

NON-

CONTRO

LLING INTEREST

December 31,

202

1

December 31,

2020

Balances as of January 1

144,877,810

424,410,392

Changes in Other Reserves

-

17,674,726

Equity in the Earnings from Associates for the year

25,635,207

(287,844,000)

Dividends and Other Movements of Non-Controlling Interest

(24,925,722)

(9,383,202)

Variation in Translation Differences of Foreign Operations

(132,020)

19,894

Balance at the end of the year

145,455,275

144,877,810

As of

December

31

,

2021

and

20

20,

the

non

-contro

lling

interests

are

not

sign

ificant

on

an

ind

ividual

or

a

joi

nt

basis.

NOTE 15

–

BALANCE

S AND TRAN

SACTIONS WITH RELAT

ED PARTI

ES

The following table con

tains the outstan

ding balances

with related parties:

December 31,

2021

December 31,

2020

Other Receivables

Non-Current

Other Related Parties

569,481

6,340

569,481

6,340

Current

Under Joint Control

140,219,724

78,183,827

Other Related Parties

18,463,813

44,352,061

158,683,537

122,535,888

Trade Receivables

Current

Under Joint Control

179,957,639

704,922,169

Other Related Parties

484,309,984

242,611,582

664,267,623

947,533,751

Trade and Other Payables

Current

Under Joint Control

15,809,848

16,279,668

Other Related Parties

284,531,483

286,144,826

300,341,331

302,424,494

Financial Debt

Current

Under Joint Control

-

25,791,278

-

25,791,278

Other Liabilities

Current

Other Related Parties

11,191,879

8,816,095

11,191,879

8,816,095

GRUPO CLARÍN S.A.

-

65

-

The following table sho

ws the operat

ions with related

parties for the years

ended

December 31,

2021 and

2020:

Item

December

31, 2021

December

31, 2020

Under Joint Control

Advertising Sales

38,820,005

41,654,031

Printing Services Sales

104,136,760

6,281,201

Other Sales

524,339,546

594,483,954

Printing and Distribution Costs

(42,908,016)

(53,322,583)

Interest Income

2,814,562

34,465,354

Interest on Financial Debt

(21,590,113)

(13,873,035)

Other Purchases

-

(398,004)

Other Revenues

95,934,398

102,545,705

Advertising and Promotion Expenses

(18,852,836)

(12,976,731)

Other Related Parties

Advertising Sales

577,300,154

698,413,023

Printing Services Sales

8,588,424

32,814,252

Circulation Sales

6,552,076

6,298,794

Television Signals Sales

1,901,661,719

2,136,524,102

Other Sales

428,759,673

1,239,273,054

Fees for Services

56,693,606

(53,014,182)

Services and Satellites Expenses

(67,332,975)

(47,205,956)

Communication Expenses

(67,759,749)

(87,903,296)

Other Purchases

(649,789,698)

(626,772,116)

Other Expenses

(10,762,885)

(13,708,558)

The

f

ees

paid

to

the

Board

of

D

irectors

and

the

U

pper

Manage

ment

of

Grupo

Clarín

for

the

years

ended

December 31, 2021 a

nd 2020 amou

nted to approxima

tely $ 1,077 m

illion and $ 1,030 mi

llion, respectively.

NOTE 16

–

EARNING

S PER SHAR

E

The

fo

llowing

table

s

hows

t

he

n

et

income

(l

oss)

and

t

he

w

eighted

average

of

t

he

number

of

common

shares

used in the calculat

ion of basic earn

ings per share:

December 31,

2021

December 31,

2020

Net Income used in the Calculation of Basic Earnings per Share:

1,039,043,355

(414,110,898)

Weighted Average of the Number of Common Shares used in the Calculation

of Basic Earnings per Share

106,776,004

106,774,807

Earnings Per Share

9.73

(3.88)

The

weighted

averag

e

of

o

utstanding

shares

for

the

y

ear

ended

Dece

mber

31,

2021 was

106,776,0

04.

Since

no

debt

securities

conv

ertible

into

s

hares

were

recorded,

t

he

s

ame

weighted

average

should

b

e

us

ed

for

th

e

calculation of diluted

earnings per share.

NOTE 17 - COV

ENANTS, SUR

ETIES AND GUARAN

TEES PROVID

ED

As of December 31

, 2021, the followi

ng covenants, s

ureties and guarante

es were in effect:

a.

IESA

is subject to contractual restrictions on

the transfe

r of

its equity interest in TRISA

and Tele Net

Image

Corp.

b.

AGEA holds a joint and sev

eral guarantee for t

he loan grante

d by ICBC to AG

L.

c.

The

C

ompany became gua

rantor of certain financial obligations

of AGEA and some of its subsidiaries with

Banco Itaú Argentina S.

A.

d.

The

C

ompany

became

g

uarantor

of

c

ertain

o

bligatio

ns

relating

t

o

the

purchas

e

of

s

upplies

by

AGEA,

CIMECO,

Tinta

Fresc

a a

nd

OSA

for

u

p t

o

EUR

12

m

illion,

until

Dec

ember

2020.

It was

not ren

ewed

after

the closing of the year.

GRUPO CLARÍN S.A.

-

66

-

NOTE 18 - LONG

-TERM SAVING

S PLAN FOR E

MPLOYEES

During

th

e

last

quarter

of

2007,

the

Compa

ny,

together

with

its

subsidiaries,

began

to

im

plement

a

long

-t

erm

savings plan

for certain executives (directors and

managers

comprising

the “executive payroll”), which became

effective

in

January

2008.

Exec

utives

who

adhere

to

s

uch

plan

undertake

to

contribute

re

gularly

a

portion

of

their

salary

(v

ariable

within

a

certain

range,

at

the

employee’s option)

to

a

fu

nd

that

will

allow

them

t

o

s

trengthe

n

their savings

capac

ity. Each

company

of

the Group where

those exec

utives

render services

will match the

sum

contributed by

such

executives

. This match

ing contr

ibution wi

ll be a

dded to

the fun

d raised

by th

e employees.

Under

certai

n

cond

itions,

t

he

emp

loyees

m

ay

acces

s

such

funds

upon

terminatio

n

of

t

heir

p

articipation

in

th

e

long-term savings p

lan.

In

addition,

suc

h

plan

provides

for

c

ertain

s

pecial

con

ditions

for

th

ose

mana

gers

who

were

in

the

“execut

ive

payroll” before

J

anuary 1,

2007. Such

co

nditions consist of

sup

plementary contributions made

by each

company to

the p

lan related to

the executive’s years

of service with

the

Group.

As of

D

ecember 31, 2021,

s

uch

supplementary

contributi

ons

made

by

th

e

C

ompany

on

a

consolidate

d

basis

amount

to

approximate

ly

$

54

million, and the charg

e to income is deferre

d until the r

etir

ement of each execu

tive.

During

2

013,

c

ertain

c

hanges

were

made

to

the

savin

gs

sy

stem,

a

lthough

i

ts

op

eration

mechanism

and

th

e

main characteristics wit

h regard to the ob

ligations undertak

en by the company

were essentially ma

intained.

Pursuant

t

o

I

AS

No

.

19,

the

above-

mentioned

saving

s

plan

qua

lifies

as

a

Defin

ed

Contr

ibution

Plan,

which

means

that

the

companies

’

c

ontributions

sh

all

be

c

harged

to

income

on

a

month

ly

basis

as

from

t

he

date

the

plan becomes effective

.

NOTE 19

–

OPERATI

NG LEAS

ES

19.1 The Compan

y as Lessee

As

of

December

31,

20

21

and

2020,

th

e

Company

is

a

party

to

non

-

cancellable

operating

leases,

wh

ich

are

currently

effective

and

have

different

terms

and

renew

al rig

hts. T

he to

tal

amount

of

minimum

future

payme

nts

for non-cancellable

operating leases is t

he following (i

n millions of $):

December

31, 2021

December

31, 2020

1 year

60

113

Between 1 and 5

27

59

87

172

19.2 The Compan

y as Lessor

The

total

amount

of

min

imum

future

collections

for

n

on

-cancellable

operating

le

ases

of

c

ertain

pro

perty

is

th

e

following (in millions

of $):

December

31, 2021

December

31, 2020

1 year

76

21

Between 1 and 5

201

44

277

65

NOTE 20

–

TAX R

EFORM IN ARGENT

INA

Income Tax

On

December

29,

2017,

the

National

Executive

Branch

enacted

Law

N

o.

27,430

-

Income

Tax.

This

la

w

introduced several ch

anges in the treatm

ent of income

tax, among which th

e following are t

he most importan

t:

(i) Income

t

ax rate:

Income

tax

rates for Argentine

com

panies were

reduced

from 35

%

to 30% for

fiscal

perio

ds

beginning

as

from January

1,

2018 until

December 31, 20

19, and

to

25% for

fiscal periods

b

eginning on

or after

January 1, 2020.

GRUPO CLARÍN S.A.

-

67

-

On December

23, 2019

, Law

No. 27541 (th

e Socia

l Solidarity an

d Producti

on Rea

ctivation Law) w

as enacte

d,

regulated

under

Dec

ree

No.

99/2019,

w

hereby

the

tax

rate

reducti

on

from

30%

t

o

25%

was

suspen

ded

until

fiscal years beginning on

or after Jan

uary 1, 20

21.

In

June

2021,

Law

N

o.

2

7,630

was

enacted

which

pr

ovides

f

or

a

new

tiered

tax

s

tructure

for

income

tax

with

three

brackets

based

on

the

level

of

acc

umulated

net

ta

xable

income.

The

amounts

established

for

each

bracke

t

will b

e a

djusted

once

a

yea

r

as f

r

om 2

022

based

on

the

CPI

corr

esponding

to

October

of

the

year

pr

ior

to

the

year i

n which the

adjustm

ent is

made compared to

the same month of

t

he previous

year. The

new tax rates are

detailed below:

- 25% for accumu

lated net taxable inc

ome of up to $5M;

- 30% for the second

bracket compr

ising taxable inco

me of up to $50

M;

- 35% for taxable incom

e exceeding $ 50

M.

Such amendment sh

all be applicable

to fiscal years beginni

ng on or after Ja

nuary 1, 2021.

The

Co

mpany

has

r

ecorded

in

thes

e

cons

olidated

fina

ncial

statements

the

impacts

of

this

change

on

curr

ent

tax an

d on

the balances

of deferred

tax assets and

liabilities, net,

t

aking into

consideration the

effective tax rate

deemed

applica

ble

as

of

the

date

o

n

which

it

is

probable

t

hat

those

d

eferred

assets

and

liabilities

will

b

e

reversed.

(ii)

Tax

on

Dividends:

The

new

law

introduces

a

tax

on

divid

ends

or

profits

di

stributed,

am

ong

ot

hers,

b

y

Argentine

companies

or

permanent

establishme

nts

to:

Individuals,

undivided

estates

or

foreign

beneficiaries,

with

the

following

consider

ations:

(a)

dividends

derive

d

from

profits

generated

during

fiscal

years

on

or

after

January

1,

2018

and

until

December

31,

2019

will

be

subject

to

a

7%

withholdin

g;

and

(b)

dividends

derived

from

prof

its

generated

during

fisca

l

y

ears

beginning

on

or

after

January

1,

2

020,

will

be

s

ubject

to

a

13%

withholding.

Dividends derived from profits ge

nerated up to and including the

fiscal year preceding the fiscal year

beginning

on

or

after

January

1,

2018

continued

to

be

subject,

for

all

th

e

beneficiaries

of

those

dividends,

to

a

35%

withholding

on

t

he

dividends

distributed

in

excess

of

the

ac

cumulated

taxab

le

income

(transition p

eriod

of

th

e

equalization tax.)

Law

No.

27541 mentioned ab

ove maintained

the

7% withholding

u

ntil

fiscal years

b

eginning on

or after

Janua

ry

1, 2021.

(iii)

Optional Revaluation for

Tax Purposes:

The law

pro

vides that

c

ompanies may op

t to

m

ake a

rev

aluation for

tax pu

rpos

es of

ass

ets located in

Argentina that

genera

te

taxa

ble i

ncome.

The

sp

ecial tax

on the amount

o

f

the

revaluation

depends

on

the

asset:

8%

for

real

estate

t

hat

d

oes

not

qualify

as

inventories,

15

%

for

real

estate

that

quali

fies

as

inventor

ies,

and

10

%

for

chattel

and

other

ass

ets.

Th

e

taxpa

yer

that

opts

for

th

e

speci

al

revaluation

regime

must

do

so

for all

the

assets

that b

elong

to th

e s

ame cat

egory.

The

special

revaluat

ion t

ax

may

not

be

de

ducted

fro

m

income

tax

,

an

d

the

taxable

income

ge

nerated

by

the

r

evaluation

is

not

subj

ect

t

o

income tax. The Comp

any did not opt

for that regime.

(iv)

Inflation

Adjustment

of

Deductions:

Acqu

isitions

or

investments

made

in

fisc

al

years

beginning

on

or

after

January

1,

2

018

are

restated

for

inflation

based

on the

percentage

variat

ions

of

the

Consumer

Price

Index

(IPC

,

for

its

Span

ish

ac

ronym)

p

ublished

by

the

Nati

onal

In

stitute

of

Stat

istics

and

C

ensus.

Suc

h

adjustment

w

ill

increase deductible amort

ization and tax c

ost in the event of a sa

le.

(v) Inflation

Adjustment: N

otwithstand

ing the

above

-me

ntioned regime,

Law N

o. 27,430

and

its amendin

g Law

No.

2

7,468

provide

that,

effective

as

from

fiscal

year

s

beginning

on

or

after

Ja

nuary

1,

2018,

the

inflatio

n

adjustment

procedure

set

out

in

Title

VI

of

th

e

income

tax

law

sh

all

be

applicable

in

fiscal

years

in

w

hich

the

variation of IPC is hig

her than 55%, 3

0% and 15% f

or f

iscal years 2018,

2019, 2020, respective

ly.

As

of

D

ecember

3

1,

2021,

the

C

ompany

has

calculat

ed

the

income

t

ax

charge

taking

i

nto

considerat

ion

th

e

inflation adjustment for tax

purposes.

In ad

dition,

said l

aw pr

ovided

that

the p

ositive

or

negative

in

flation

adjustment,

as t

he c

ase

may

be,

corresponding

to

the

first,

second

and

t

hird

fisc

al

years

beginning

on

or

after

January

1,

201

8,

that

must

be

calculated

if

the

triggers

s

et

forth

in

the

bill

occur,

shall

be

allocated

as

follows:

one

third

in

that

f

iscal

period,

and the other two thirds,

equally, in the i

mmediately fo

llowing two fiscal per

iods.

GRUPO CLARÍN S.A.

-

68

-

Law

No.

27541

mentione

d

above

provi

ded

th

at

the

appl

ication

of

the

inflation

a

djustment

for

t

ax

pur

poses

corresponding

to

the

f

irst

and

second

f

iscal

years

beg

inning

on

or

after

January

1,

201

9

must

be

alloca

ted,

equally, during six fisc

al years.

Tax on assets

Law No. 27,260 rep

ealed the tax

on assets for fiscal y

ears beginning on or a

fter January 1,

2019.

Value Added Tax

Through Decree

No.

1,094/1

8, t

he Execut

ive

Branch e

nacted Law

No.

27,467,

which

introduces

amendme

nts

regarding value added

tax (“VAT”):

(i)

Allocation

of

Social

S

ecurity

Contributions:

Ent

ities

may

a

llocate

employer’s

contributions

on

the

payroll

as

a tax

credit a

gainst

VAT. T

hes

e co

ntributions

must

have

been ac

crued i

n the

fisc

al period

and

effectively

pai

d

at

the

moment

of

submitti

ng

the

VAT

r

eturn.

Qu

alifying

ent

ities

are

those

engaged

i

n

the

fo

llowing

activitie

s:

broadcast

telev

ision

or

physical

link

and/or

radio

electric

link

subscr

iption

television

services,

audio

broadcasting, cable television signals, newspaper, magazine or periodical publishing companies or companies

engaged

in

d

igital

journalis

m,

and

the

distributors

of

th

ose

publishing

companies.

In

cas

e

the

paymen

t

of

t

hat

amount

is

ma

de

after

the

time prov

ided,

entities

may

allocate

emp

loyer’s

contrib

utions

on

the

p

ayroll

as

a tax

credit

against

VAT

in

the

t

ax

return

for

the

fiscal

peri

od

in

which

social

c

ontribut

ions

were

paid.

As

provide

d

above,

when

the

salaries

that

g

ive

rise

to

t

he

e

mployer’s

contributions

that

may

be

al

located

as

a

tax

credit

against

VAT

are

also

r

elated

to

other activities

outs

ide

the

scope

of

this

be

nefit,

th

e

amo

unts

of

thos

e

contributions

will

be

allocated

pro

r

ata

for

the

s

ole

purpose

of

calcu

lating

the

ratable

portion

that

qualifies

for

the

benefit.

The

am

ounts

of

such

employer’s

contributi

ons s

hall

be

counte

d

as

a

VAT credit

u

p t

o

the

amou

nt

of

the

output

tax

for

the

relevant

period,

b

efore

al

locating

th

e

other

tax

c

redits.

It

shall

apply

to

qualifying

amounts as from Jan

uary 1, 2019.

(ii)

V

AT

Exem

ption:

As

fro

m

January

1,

2019,

the

sales,

leases

o

the

developme

nt,

constructio

n

or

manufacturing of

chattel at

the request of

a third pa

rty, imports and

leases and

s

ervices relating to

t

he foll

owi

ng

items,

are

ex

empted

fro

m

VAT:

books,

brochures

and

similar

pri

nted

pro

ducts,

including

book

series

or lo

ose

leaves

that

make

up

th

e

whole

w

ork

or

part

of

it,

and

newspa

pers,

magaz

ines

and

similar

perio

dic

printe

d

publications,

as

we

ll

as

su

bsc

riptions

to

digital

perio

dic

editions

of

online

infor

mation,

throug

hout

the

entir

e

marketing and distribution c

hain, in all cases irrespec

tive of the support or me

ans used for their diss

emination.

The

distribution,

classif

ication,

delivery

and/or

r

eturn

of

newsp

apers,

magazines

,

and

perio

dical

publications

provided to entities en

gaged in editor

ial production d

o not qualify for V

AT exempti

on.

(iii)

Sp

ecial

T

reatment.

Tax

Credit

relate

d

to

ne

wspapers,

magazines,

digital

editions

and

books:

The

entities

engaged

in

editorial

pri

nting

and/or

production

of

b

ooks,

brochures

and

simi

lar

printed

publ

ications,

or

of

newspapers, magazines

and periodical publications, as well as digital journalistic editions of online information

and

the

ir

distribut

ors, to

the extent all

of them qualify

for the

tax exemption under the

V

AT Law

as from

January

1, 2019,

may a

llocate the

tax

credit g

enerated

by trans

actions that q

ualify f

or the

above

-mention

ed exempt

ion

against

the

output

tax

generated

by

other

tra

nsactions

su

bj

ect

to

VAT.

Any

unu

sed

balanc

e

can

be

credited

against other taxes controll

ed by AFIP, or be returned or transferred to respo

nsible third parties in the manne

r,

terms and conditions est

ablished by

the AFIP to such e

nd.

Tax on Personal As

sets (substitute

taxpayer):

Law No. 27,541 (the Social Solidarity and Product

ion Reactivation Law), regulated under Decree No. 99/201

9,

increased to 0.5%, for

fiscal year 2019

onwards, the rate to be

applied by Argentine issuers in their

capacity as

substitute taxpayers

for shareholder i

ndividuals res

iding in Argentina or abro

ad, on the

value of the shares.

NOTE 21 - LAW No

. 26,831 CAPITAL MA

RKETS

Capital Markets Law

–

Law No. 26,

831, as amende

d

On

Dece

mber

28,

20

12,

Capital

M

arkets

Law

N

o.

26,831

was

p

ublished

in

t

he

O

fficial

Gazette.

This

law

eliminated

the

self-

regulation

of

the

c

apital

m

arket,

gr

anted

n

ew

powers

to

the

CNV,

and

repealed

L

aw

No.

17,811

and

Dec

ree

No.

677/01,

among

other

regulations.

Law

No.

26,831

beca

me

e

ffective

on

J

anuary

28,

2013. As from its effec

tive date, the

Public Tender Off

er regime applies

to all listed comp

anies.

GRUPO CLARÍN S.A.

-

69

-

Productive Financing

Law

On

May

11,

2018

,

Productive

Fi

nancing

Law

No.

27,440

was

published

i

n

the

Officia

l

Gazette.

This

l

aw

introduced

sever

al

amendm

ents

to Law

No.

26,831

reg

arding

the extent

of

the

pow

ers of

the

CNV; the

exercise

of preemptive rights on shares offered through pu

blic offering in the case of capital increases; priva

te

placements;

public

tender

offers;

the

jurisdicti

on

o

f

the

federal

commercial

co

urts

of

app

eals

t

o

review

the

resolutions issued or s

anctions imposed by th

e CNV, among oth

er amendments

.

With

respect

to

pub

lic

te

nder

offers,

un

der

the

previo

us

regime,

the

offer

or

was

obliged

to

for

mulate

a

“fair

”

price to be set by weighing

the results of

different company val

uation methods, wi

th a minimum floor re

lated to

the average

market

price f

or

the six

-month

period

immediate

ly preced

ing the

date

of the

agreement.

Pursuan

t

to

the

amendme

nts

introdu

ced

by

Law

No. 27

,440

to

Law

No.

26,831,

the

obl

igatio

n

is

objective

and

consists

in

offering

t

he

higher

of

two

existing

prices:

t

he

pri

ce

paid

or

agreed

by

th

e

offeror

d

uring

th

e

12

mo

nths

immediately

preced

ing

th

e

first

d

ay

of

th

e

public

tender

offer

perio

d,

and

t

he

average

price

of

t

he

s

ecurities

subject

to the

offer

during the

semest

er

imme

diately

pre

ceding

the date

of the

announcement of

t

he transaction

under which the chan

ge of control is agre

ed upon.

On

Dece

mber

28,

20

18,

G

eneral

Reso

lution

N

o.

7

79/2018,

wh

ereby

t

he

CNV

es

tablished

the

r

egulatory

framework applica

ble to public tender off

ers, was publ

ished in the Off

icial Gazette.

On

August

20

,

2013,

at th

e

r

equest

of

Mr.

Rubén

Mari

o

Szwarc,

a

minority

shar

eholder

of

the

Company,

and

by

mea

ns

of

public

deed

number

two

hundred

forty-

five,

th

e

C

ompany

was

s

erved

notice

of

the

decision

rendered

by

Chamber

A

of

the

National

Court

of

App

eals

on

Commerc

ial

Matters

on

August

1

2,

2013,

in

r

e

“SZWARC,

Rubén

Mar

io

v.

Nat

ional

Governm

ent

and

Others

on injunction”

File

No

.

0114

19/2013.

T

hat

Chamber

decided,

among

other

things,

(i)

to

declare

the

unconstitutionality

of

Sections

2

,

4,

5,

9,

10,

11

,

1

3,

15 and 16

of L

aw No.

26,854,

and (ii)

to order

the

provisional,

injunctive

suspension

of Sec

tion 20,

subsection

a), second part, p

aragraphs

I and II (or

1 and 2) o

f Law

No.

26,831 and

of all laws

, rules or adm

inistrative acts

issued

or

that

may

be

issu

ed

pursuant

to

such

legal

prov

isions,

with

resp

ect

to

G

rupo

Clarín,

until

th

e

judge

that

is

finally

declared

com

petent

t

o

r

ender

a

decision

on

th

e

merits

assumes

fu

ll

jurisd

iction

of

t

he

case

and

renders a final decision re

lating to the injunct

ion.

NOTE 22 - IMPACT O

F CORONAVIRU

S

Given the magnitude of the spread of the virus

called “Coronavirus” (CO

VID

-19) at a global level, in Argentina

,

the

National

Gov

ernment

implement

ed

a

s

eries

of

measures

aimed

at

reducing

the

movem

ent

of

t

he

populati

on,

ordering

t

he

Mandatory

and

Preventive Social

Isolation (MP

SI)

as

from

March 20

,

2020, allowing

the

movemen

t

of on

ly those

peop

le i

nvolved

in t

he prov

ision/prod

uction

of ess

ential

o

r

exempte

d s

ervices

and

products.

The

Government

made

changes

to

and

exte

nded

such

isolation

measures

in

d

ifferent

stages

by

geographical

regions according to th

e epidemiological sit

uation of each city.

On Nov

ember

9,

2020,

th

e

National

Governmen

t

order

ed

the

Man

datory

and

Social

Distanci

ng f

or

all

persons

who

res

ide

or

transit

in

urb

an

c

enters

and

in

d

istricts

a

nd

departme

nts

of

the

Ar

gentine

provinces

that

do

not

have

a

sus

tained

c

ommunity

transmission

of

the

virus

and

they

posi

tively

v

erify

certain

epidemiological

and

sa

nitary

parameters.

Th

e

locations

where

these

parameters

were

not

met

c

ontinued

with

the Mandatory and

Preventive Social Iso

lation.

By the

end

of 2020,

Argentina rolled

out the

national vaccination

campai

gn

under the di

rect

management of the

national and provincial

governments an

d of the govern

ment of the Autono

mous City of B

uenos Aires.

The

v

accination

ca

mpaign

is

being

completed

with

th

e

application

of

a

booster

dose,

which

favors

a

lower

severity in COVID-19 infections in Argenti

na with the new strains that are spreading worldwide. Like the rest of

the

world,

Argentina

does

not

escape

the

exponential

rise

in

infections

that

s

ince

t

he

end

of

202

1

and

e

arly

2022 has been strong

ly affecting all age groups

.

During the effect

iveness of the

Mandatory and Pr

eventive Social Distanc

ing, and even

under the new

restrictions,

several

service

s

and

act

ivities

are

s

till

de

emed

“essentia

l”

as

th

ey

had

been

define

d

during

the

effectiveness of the Man

datory and Prevent

ive Social Isolation.

Since

the

be

ginning

of

the

pande

mic,

the

C

ompany

has

carried

out

its

activit

ies

under

challenging

circumstances

derived

from

the

health

s

ituation.

Even

though

th

e

print

media,

radio

and

audiovisu

al

GRUPO CLARÍN S.A.

-

70

-

communication

s

ervices,

which

are

the

Group's

main

busines

ses

,

have

been

exempt

ed

from

the

M

PSI,

th

e

Company has experi

enced or is expecte

d to experienc

e the following imp

acts:

-

A

decl

ine

in

the

sale

of

advertising

in

all

the

med

ia

o

f

Grupo

C

larín,

mainly

due

to

th

e

cuts

in

the

customers’

advertising

b

udgets.

H

o

wev

er,

ARTEAR is

showing a

gradual

and

continued recovery

since

September 2020 to d

ate;

-

A drop in circulation, w

ith an impact on subsc

riptions as

from the second qu

arter of 2020;

-

An increase in the overdue

collection of rec

eivables;

-

Television

audience

levels

were

affected

by

the

lack

of

production

of

certain

contents

for

prime

time,

which

were

suspended

due

to

the

pandemic.

As

from

May

2021,

the

company

resumed

the

airing

of

contents that general

ly lead to an increase i

n audience levels;

-

Several difficulties th

at hindered o

ur operations, such

as:

o

Those

re

lated

to

the

logistics

regard

ing

t

he

c

ommute

of employees,

perf

ormers

and

journalists;

o

The reconfiguration of som

e programs due to

social dis

tancing measures;

o

The implementation o

f home office

mainly for

our back office staff;

o

Strict sanitation, disinfecti

on and preve

ntion protocols at our

offices;

o

The

incor

poration

of

technolo

gies

re

quired

to

ensure

the

virtual

presence

of

talents

in

the

production of contents.

In

order to

help companies mitigate the

eco

nomic impacts of

the pandemic, the

National Government launched

a

series of financial

aid measures. Among

the companies that qualify

for such

fina

ncial aid,

certa

in subsidiaries

of

the

C

ompany

h

ave

benefited

from

the

Emergency

Assistance

Progr

am

for

Work

and

Prod

uction

fr

om

April

to

Septemb

er

2020

and,

subsequently,

to

a

lesser extent,

t

he

Progra

m

for Productive

R

ecovery

II

from

November

2020

to

June

2021,

whereby

the

Nation

al G

overnment

has

assum

ed th

e burde

n of

a

porti

on of

the

wage

c

osts

and

has

a

llowed

for

reductions/deferm

ent

of

the

payment

of

certai

n

em

ployers’

social

securit

y

contributions.

In

additio

n,

other

activities which

have

a

s

maller

weigh

t

in

the

Group’s operations

t

aken

as a

w

hole

were he

av

ily

affected

since t

he

MPSI

entered

int

o

effect,

such

as

th

e opera

tions

of

Autosports,

Pol-k

a

and

Cúspide.

These

companies

were

f

orced

to

reduce

or

s

uspend

most

of

their

operations

and

the

commercialization

of

t

heir

products

during

mos

t

of

fisc

al

y

ear

2020.

In

the

case

of

P

ol

-ka,

the

economic

impacts

were

very

significant

because, during

2020,

it

w

as unable to

produce contents for

the subsequent commercialization. Consequently,

it

ha

d

s

erious

difficulties

in

meeting

its

financial,

busi

ness

and

l

abor

c

ommitments,

being

in

a

very

difficult

position to

have

access

to

new

financing

sources.

As f

rom t

he begin

ning of

2021,

Pol

-k

a s

tarted t

o resu

me its

activities.

Pursuant

to

the

gu

idelines

of

IA

S

36,

t

aking

into

cons

ideration

that

the

d

ecline

i

n

activities

during

202

0

and

2021

in

the

industries

in

which

certa

in

subsidiaries

of

the

Grou

p

operate,

mainly

the

pri

nt

a

nd

audiovisual

production ind

ustries, was

an indication

of impairm

ent, the Com

pany’s Man

agement h

as ass

essed the

recoverable value of its f

ixed assets.

The

recoverable

a

mount

of

each

CGU

has

be

en

determin

ed

as

per

its

v

alue

i

n

use,

calc

ulated

based

on

operating

cash

fl

ows

estimated

in

the

financia

l

budgets

,

which

comprise

a

period

rang

ing

from

one

t

o

thre

e

years.

Cas

h

flows

not

included in

those

periods are

projected

using

a

growth

rate, a

ssessed

based

on

statistical

data

a

nd

historical

indicators

of

Argentina,

wh

ich

does

not

exc

eed

the

lo

ng

-ter

m

average

gr

owth

of

each

business.

The gros

s

margin us

ed

in e

ach

case

for

the calcu

lation

of

the

value

in

use

allocated

to

each

CGU

arises

from

bud

gets prepared by

each business for

the period

und

er consideration, which

are

in l

ine with the

historical data

and the expectations re

garding market

development and evo

lution of the resp

ective businesses

.

The

discount

rate

used

i

n

each

case

for

the

calcul

a

tion

of

th

e

value

in

use

a

llocated

to

each

CGU

takes

into

account

t

he

r

isk

-free

rate

,

t

he

c

ountry

risk

premium

and

the

premium

for

risks

s

pecific

to

e

ach

business,

and

the indebtedness structure

of each CGU.

As

of

Dec

ember

31,

2020

,

as

a

result

of

the

rec

overability

assessment

des

cribed

ab

ove,

the

Company

recognized

impairment

l

osses

of

100%

in

the

goodw

ill

held

by

ARTEAR

in

Teleco

r,

Telba,

Bariloche

TV,

and

Pol-Ka,

and

a

portion

of

the

goodwill

of

Patagonik,

for

an ag

gregate

a

mount

of

approximately

$

1,95

6

million,

in

c

onstant

currency

as

of

December

31, 2021.

As

of

December 31,

2021, the

Company

recognized impairment

losses for a portion of

Patagonik's goodwi

ll of approximately $6

1 million in constant curr

ency of that dat

e.

-

71

-

The

ultimat

e

effects

of

COVID

-19

and

its

imp

act

on

the

global

a

nd

local

econo

my

are

unknown

and

impossible

to

be

reasonably

predicte

d.

How

ever,

ev

en

thoug

h

the

Company

has

suffered

and

is

expect

ed

to

suffer

s

hort

term

effects,

it

does

n

ot

expect

that

they will

affect

the

co

ntinuity

of

the

Group’s

business

es.

The

Board

of

Directors

is

c

losely

monit

oring

the

evolution

of

the

s

ituation

and

taking

the

necessary

measures available t

o preserve the saf

ety and healt

h of the em

ployees and the C

ompany’s activities

.

NOTE 23

–

SUB

SEQUENT EVENT

S

On

February

9,

2022,

IE

SA

accepted

a

binding

offer

under

a

Memorandum

of

Understandi

ng

(“MOU”)

from Ta

ngo

Sports

Team

S.R.L. for

th

e

latter's

acquis

ition

of

all

the

sh

ares

held

by

IESA

in Auto

Sports

S.A.

for approximately

US

$

0.96

million.

Subject

to

com

pliance

with

th

e

t

erms

and

c

onditions

of

the

MOU,

the closing date for

the sale of the shares w

as set at Marc

h 31, 2022.

NOTE 24 - APPROV

AL OF FINANCIAL

STATEMENT

S

Grupo

Clarín’s

Board

o

f

Direc

tors

has

approved

the

consolidated

financial

stat

ements

an

d

authorized

their issue for March 1

0, 2022.

These consolidated financial statements for the year ended December, 31 2021

, and for the pu

rpos

es of

their filing with th

e

LSE, hav

e been approved by G

rupo Clarín’s Boar

d of Director

s on

April

22

,

2022.

Price Waterhouse & Co. S.R.L., Bouchard 557, piso 8°, C1106ABG - Ciudad de Buenos Aires

T: +(54.11) 4850.0000, F: +(54.11) 4850.1800, www.pwc.com/ar

Independent audi

tor’s report

To the Shareholders, President and Directors of

Grupo Clarín S.A.

Opinion

We have audited the consolidated financial statements of Grupo Clarín S.A.

(“the Company”)

and its subsidiaries (

“

the

Group

”

)

which comprise the consolidated statement of financial position as at December 31, 2021

,

and the

consolidated statement of comprehensive income, consolidated statement of changes in equity, and consolidated

statement of cash flows for the year then ended, and the notes to the consolidated financial statements, inclu

ding a

summary of significant accounting policies and other explanatory information.

In our opinion, the accompanying consolidated financial statements

present fairly, in all material respects, the

consolidated financial position of the Group as at December 31, 2021, and its consolidated financial performance and

its consolidated cash flows for the year then ended in accord

ance

wit

h International Financial Reporting Standards

(IFRS).

Basis

fo

r opinion

We conducted our audit in accordance with International Standards on Auditing (ISAs). O

ur responsibilities under

those standards are further described in the Auditor’s responsibilities for the audit of t

he consolidated financial

statements section of our report.

We believe that the audit evidence we have obtained is sufficient and appropriate to provid

e a basis for our opinion.

Independence

We are independent of the Group in accordance with the International Code of Ethics for P

rofessional Accountants

(including International Independence Standards) issued by the Internation

al Ethics Standards Board for Accountants

(IESBA Code) and the ethical requirements that are relevant to our audit of the consolidated financial statements in

Argentina. We have fulfilled our other ethical responsibilities in accordance with the IESBA

Code.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the

consolidated financial statements of the current period. These matters were addressed in the context of our

audit of

the consolidated financial statements as a whole, and in forming our opinion thereon, and we do not provide a

separate opinion on these matters.

2

Key audit matter

How our audit address

ed the key aud

it matter

Recognition of adve

rtising revenue

The Group has different sources of sales revenue as

detailed in Note 6.1. Advertising sales revenue is

recognized by applying the accounting policies

described in Note 2.9.

We considered the accuracy of advertising sales

revenue recognized as a key audit matter. The reason

for the foregoing is the different systems required for

the provision and pricing of these services, given their

nature, and the inclusion of manual activities into the

business process of this source of revenue, which

represents an inherent risk.

The audit procedures performed included the following,

among others:

•

Understanding the procedure performed by

Management

to

determine and recognize revenue

from advertising in each of the subsidiaries.

•

Evaluating the relevant information system and

the design and operational effectiveness of the

control over the capture and recording of revenue

transactions. To this end, our Information

Technology specialists have assisted us in the

audit of automated controls, including controls

over the interface between the various system

applications. We also performed tests on acces

s

controls and change management controls for the

Group's billing systems.

•

Evaluating current manual controls in place over

the authorization of changes to rates, the

introduction of discounts, the effective provision of

the service, and the entry of that information into

the billing systems.

•

Performing tests, based on a sample of customer

invoices, on the accuracy of rates and discounts.

•

Performing tests on key reconciliations used by

Management to assess the completeness and

accuracy of revenue.

•

Performing tests on the documentation supporting

manual journal entries to revenue accounts to

identify unusual items.

•

Requesting confirmations based on a sample of

account receivables transactions.

Other information

The other information comprises the Annual Report

.

Board of Directors is responsible for the other information.

Our opinion on the consolidated financial statements does no

t cover the other information and we do not and will not

express any form of assurance conclusion thereon.

3

In connection with our audit of the consolidated financial stat

ements, our

responsibility i

s to read the other information

identified above and, in doing so, consider whether the other information is materially in

consis

tent with the

consolidated financial statements or our knowledge obtained in the audit, or otherwise app

ears

to

be materially

misstated. If, based on the work we have performed on the other information, we concl

ude that there is a material

misstatement of this other information, we are required to report that fact. We have nothing to report in this regard

.

Responsibilities of Bo

ard of

Directors and

Audit C

ommittee for the con

solid

ated financial

statements

Board of Directors is responsible for the preparation and fair presentation of the consolidated financial state

men

ts in

accordance with IFRS, and for such internal control as Board of Directors determines is necessary to enable the

preparation of consolidated financial statements that are free from material misstatement, w

hether due to fraud or

error.

In preparing the consolidated financial statements, Board of Directors is responsible for assessi

ng the

Group’s ability

to continue as a going concern, disclosing, as applicable, matters related to going

concern and using the going

concern basis of accounting unless management either intends to liquidate the Group or to cease operations, or has

no

realistic alternative but to d

o so

.

Audit Committee is

responsible for overseeing the Group’s financial reporting process.

Auditor’s responsibilities

for the audit of

the consol

idated f

inancial statement

s

Our objectives are to obtain reasonable assurance about whether

the consolidated financial statements as a whole

are free from material misstatement, whether due to fraud or error, and to issue an auditor’s

report that includes our

opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in

accordance with ISAs will always detect a material misstatement when it exists. Misstateme

nts can arise from fraud or

error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence

the economic decisions of users taken on the basis of these consolidated

financial statements.

As part of an audit in accordance with ISAs, we exercise prof

essional judgment and maintain pro

fessional scepti

cism

throughout the audit. We also:

•

Iden

tify and assess the risks of material misstatement of the consolidated financial statements, whether due to

fraud or error, design and perform audit procedures responsi

ve t

o those risks, and obtain audit evidence that is

sufficient and appropriate to provide a basis for our opinion. The risk of not detec

ting a material misst

atement

resulting from fraud is higher than for one resulting from error, as fraud ma

y involve collusion, forgery, intentional

omissions, misrepresentations, or the override of internal control.

•

Obtain an u

nderstanding of internal control relevant to the

a

udit in order to design audit procedures that are

appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the

Group’s

internal control.

•

Eval

uate the appropriateness of accounting policies used and the reasonableness of accounting estimates and

related disclosures made by Board of Directors.

•

Conc

lude on the appropriateness of Board of Directors use of the going concern basis of accounting and, based

on the audit evidence obtained, whether a material uncertainty exis

ts related to events or conditions that may

cast

significant doubt on the

Group’s

ability to continue as a going concern. If we conclude that a material uncertainty

exists, we are required to draw attention in our auditor’s repor

t to the related d

isclosures in t

he consolidated

4

financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on

the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cau

se

the Group to cease to continue as a going concern.

•

Eval

uate the overall presentation, structure and

content of

the c

onsolidated financial statements, including the

disclosures, and whether the consolidated financial statements represent the underlying t

ransactions and events

in a manner that achieves fair presentation.

•

Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities

within the Group to express an opinion on the consolidated fi

nancial statements. We are responsible for the

direction, supervision and performance of the Group audit. We remain solely responsible for our audit opinion.

We communicate with

the Company’s

Audit Committee regarding, among other matters, the planned scope and

timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify

during our audit.

We also provide to the Audit Committee with a statement that we have complied with relevant ethical requirements

regarding independence, and to communicate with them all relationships and other matters that ma

y reasonably be

thought to bear on our independence, and where applicable,

ac

tions taken to eliminate threats or safeguards applied.

From the matters communicated with the Audit Committee, we determine those matters that were of most significance

in the audit of the consolidated financial statements of the cur

rent period and are therefore

the key audit matters. We

describe these matters in our auditor’s report unless law or regulation precludes public disclosure about the

matter or

when, in extremely rare circumstances, we determine that a matter should not be communi

cated in

our report

bec

ause the adverse consequences of doing so would reaso

nably be expected to outweigh the public interest

benefits of such communication.

Autonomous City of Buenos Aires, April

22

nd

, 2022.

PRICE WATERHOUSE & CO. S.R.L.

Alejandro Javier Rosa

Partner