Ethical Channel is a tool that allows you to communicate, in a confidential manner, the alleged commission of conduct within its scope of application: complaints or irregularities relating to actions or omissions that may constitute violations in accordance with the provisions of Directive (EU) 2019/1937 on the protection of whistleblowers and Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption.

It serves to report regulatory breaches and correct those detected. It is not a mailbox for requests, complaints, suggestions, etc., regardless of regulatory compliance.

The subjects susceptible to reporting are those defined in Directive (EU) 2019/1937 on the protection of whistleblowers and Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption.

Therefore, actions or omissions that may constitute: a) Violations of European Union Law are subject to reporting on this channel

, provided that:

•They are included in the scope of application of the acts listed in the annex to Directive (EU) 2019/1937. (D.O.U.E. 26/11/2019).

•Affect the financial interests of the European Union, according to Art. 325 of the Treaty on the Functioning of the European Union (TFEU).

•They affect the internal market, according to Art. 26, paragraph 2 of the TFEU, including infringements relating to competition and aid granted by States, corporate tax rules, or practices whose purpose is to obtain a tax advantage that distorts the object or purpose of the legislation applicable to corporate tax.

b) Actions or omissions that may constitute a serious or very serious criminal or administrative offence, including those involving economic disruption to the Public Treasury and Social Security.

c) Violations of the Law on Safety and Health at work.

It does not cover complaints, complaints or suggestions that would be referred, if appropriate, to the mailboxes or channels enabled for this purpose.

The Ethical Channel is not a mailbox for requests, complaints or suggestions “for use”. Therefore, complaints, complaints or suggestions will not be processed through the Ethical Channel, which must be channeled through customer service, or through the mailboxes or channels enabled for this purpose in each

Keep in mind, based on the previous question, “What types of crimes can I report?” , those issues that are likely to be reported through this channel. In accordance with art. 35.2 of Law 2/2023, on Whistleblower Protection:

Persons who communicate or disclose: a) Information

contained in communications that have been inadmissible through any internal information channel or for any of the reasons provided for in article 18.2.a) are expressly excluded from the protection provided for

b) Information related to complaints about interpersonal conflicts or that only affect the informant and the persons to whom the communication or disclosure relates.

c) Information that is already fully available to the public or that constitutes mere rumors.

d) Information referring to actions or omissions not covered by article 2.

Users of this Channel should know that the communications submitted will be considered confidential and confidential information. For this purpose, the identity of the reporting person will be especially safeguarded in good faith, who will be protected against any kind of retaliation, due to the communication made, in accordance with the provisions of Law

The Ethical Channel is designed, established and managed in a secure manner, allowing anonymous communications to guarantee the confidentiality of the identity of the informant and of any third party mentioned in the communication and of the actions carried out in the management and processing of the communication, preventing access by unauthorized personnel.

For more information, please see the Privacy Policy in the footer of this channel.

The Ethical Channel guarantees anonymity to the extent that it is so requested by the complainant, although the information systems from which they formulate the communication may not be so. In this regard, some tips for maximizing anonymity, in addition to informing that the report is anonymous, are:

• Make sure that the description of the communication does not include information with which it is easy to identify you. The same applies to the documents you attach as possible evidence.

Ethical Channel allows communications to be made in writing or verbally, or in both ways. By clicking “Report a complaint” through the external portal https://anerpro.canaldenunciasanonimas.com or verbally, through a voice recording system by pressing the microphone of

To make communications using the voice, the informant before sending the report, can listen to what was recorded, and if he wishes to preserve anonymity, he can make an alteration of the recording by selecting from the available voice distortion options.

Once the recording of the complaint has been received by voice, the Internal Information System Manager will document a complete and accurate transcript of the recording so that it can be validated by the reporting person.

Without prejudice to their rights in accordance with data protection regulations, the reporting person will be offered the opportunity to verify, rectify and accept the transcript of the conversation through validation.

Within a maximum period of seven (7) days from the receipt of the information, the Head of the ANERPRO Internal Information System will carry out a preliminary examination of the communication received and the existence of reasons for its admission (or not) for processing, as well as the possible occurrence of conflicts of interest, proceeding to send an acknowledgment of receipt of the communication to the reporting person in which he will be informed, if appropriate, of: a) The non-relevance and referral, in

where appropriate, to the means of contact established by the organization for the management of the matter.

b) The relevance of the communication, informing you of the deadlines set for its resolution and requesting, if necessary, more information to process the complaint.

The maximum period for responding to investigative actions may not exceed three (3) months (except in cases of special complexity that require an extension of the deadline), in which case, it may be extended to a maximum of another three (3) months from the receipt of the communication.

In accordance with the provisions of current data protection regulations, ANERPRO is responsible for the processing of the personal data of all people involved in communications. In this regard, both ANERPRO and the data processors linked to the management of the Ethical Channel comply with the technical and organizational measures necessary to guarantee data security and prevent its alteration, loss and unauthorized treatment or access.

The platform is designed to apply current regulations on the protection of personal data, specifically Article 24, of reporting channels. For more information, please see the Privacy Policy in the footer of this channel.

The Ethical Channel operates on an external platform of DIGITAL PRODUCTS DEVELOPMENT SL (Ithikios) certified in accordance with the ISO 27001 standard for Information Security Management.

Ithikios, as a data processor, has considered security to be a key element since the original design, implementing elements that both by design and by default help to minimize risks in data processing managed in accordance with the principles established in the GDPR and in the European directive 2019/1937.

The ithikios servers are in CPD's in European territory. Your data is encrypted to avoid intrusion risks as much as possible.

Complaints must be submitted in good faith and with reasonable grounds to believe that the facts reported are true. It is necessary to provide a principle of proof (documentary, testimonial, computer, etc.) that allows us to prove the facts, at least in an indicative way. The reporting person undertakes to the veracity of the data provided

If no violation is detected and the person has acted in good faith, there will be no retaliation.

If the complaint is proven to be false and was filed in bad faith, the organization may initiate legal or disciplinary action.

Filing a false report may constitute a crime under article 456 of the Criminal Code, especially when:

• There is an awareness of the falsehood of the alleged acts.

In these cases, ANERPRO reserves the right to take appropriate legal action.

We inform you that it is also possible to report, either directly or after communication through this Ethical Channel, of the commission of any actions or omissions included in the scope of application of Law 2/2023: