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WHISTLEBLOWER CHANNEL

WEB INFORMATION SECTION INTERNAL INFORMATION SYSTEM

Welcome to our internal system for reporting irregularities.

In this channel, you can report any alleged irregularity or act contrary to current legality or internal regulations of which you may be aware. Below, we outline our strategy regarding the Internal Information System and informant protection.

Principles of the internal information system

The management of the internal information system is based on the following principles:

  • Compliance with any legal requirements related to the filed report
  • Execution of internally defined procedures for this channel
  • Implementation of best practices in handling reports
  • Taking into account the opinions and perspectives of stakeholders
  • Promoting a culture of continuous improvement for the channel
  • System Responsible

The system is managed at the group level. However, we will collaborate from Spain to assist with the investigation and provide a clearer, honest, and fair decision.

Conditions for using this channel

This channel is available to individuals with professional or employment ties to this entity, as well as those who have already concluded their professional relationship. It also extends to interns, volunteers, individuals in training, and even those participating in selection processes. It is also open to contractors, collaborators, and others.

Contact information for the channel

From this section, you can find contact details for submitting a report:

Online Form

In brief, upon receiving a report, the company will conduct an initial assessment to determine if it is suitable for management through this channel. If rejected, the informant will be informed. If accepted, the informant will be informed, and an internal investigation will commence. We will inform you about how your case has been managed and resolved within a maximum period of 90 days. During this time, both the informant and the company can exchange information about the case. All stakeholders will be notified of the final conclusions within the timeframes established by the law.

Confidentiality of Communications

All information exchange between the informant and the entity is confidential, and secure communications are guaranteed throughout the entire process.

External Reports

It is also possible to report misconduct externally to a competent (national or regional) authority that can receive and provide information. You can find contact information for each country in their competent authority, typically in the external reports section.

Anonymity

Your anonymity will be maintained when submitting a report unless you voluntarily provide personal information. It is not mandatory to provide any personal information.

Good Faith

The principle of good faith presupposes the diligent and responsible conduct of the informant, and that the report is based on truthful facts that demonstrate irregular, unlawful, criminal, or contrary behavior to the organization's internal regulations. Misuse of this tool (e.g., filing false reports) may lead to disciplinary and legal actions against the informant.

Informant Protection

In addition to anonymity and confidentiality, the organization ensures the protection of the informant's rights throughout the entire process.

Protection of the Accused

Likewise, the right to privacy, the presumption of innocence, and the defense of individuals accused will be ensured by providing them with minimal and sufficient information to understand the allegations against them.

Regulatory Framework

The entire process of reporting, management, and resolution of the filed report is governed by Law 2/2023 of February 20, regulating the protection of individuals reporting regulatory violations and combating corruption, and by Organic Law 3/2018 of December 5, on the protection of personal data and the guarantee of digital rights.