The channel may be used by anyone who has obtained information in a work-related or professional context linked to the organization, including:

• Employees
• Directors or members of governing bodies
• Suppliers and contractors
• Self-employed professionals
• Former employees
• Candidates in recruitment processes
• Interns or volunteers

You may report any facts that you believe may constitute a breach of legal regulations, the Code of Ethics, or any applicable internal policies.

Two subchannels are available for reporting the following types of irregularities:

Ethics & Whistleblowing Channel

• Law 2/2023-related matters
  • Fraud and corruption-related conduct
  • Workplace health and safety violations
  • Information security and data protection breaches
  • Anti-competitive practices
  • Human rights violations or environmental damage
  • Other serious or very serious criminal or administrative offenses
• Code of Ethics and Conduct breaches

Harassment Protocol Channel

• Sexual harassment or harassment based on gender
• Moral or psychological harassment
• LGTBI harassment
• Sexual harassment policy (Peru subsidiaries)

Confidentiality and anonymity
We understand that confidentiality is essential to encourage reporting. We guarantee full confidentiality throughout the process and protect the identity of the reporting person within the limits permitted by law. Anonymous reporting is also available.

Security
The channel incorporates technical and organizational measures to ensure the confidentiality, integrity and security of the information. Access is restricted to authorized personnel only, preventing unauthorized access or disclosure. Encryption and secure data storage mechanisms are applied.

Omnichannel approach
The channel allows reports to be submitted in writing or verbally, including the option to attach files. All options are integrated into a single system for coordinated and efficient management.

Impartial investigation
Once a report is submitted, our specialized team will investigate it objectively and diligently, in accordance with internal policies and applicable regulations. The rights of all parties involved, including the presumption of innocence, will be respected throughout the process.

Data protection
Personal data will be processed in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Data Protection (LOPDGDD).

Protection against retaliation
We do not tolerate any form of retaliation against individuals who report in good faith. We are committed to safeguarding their rights and integrity. Disciplinary measures will be taken against anyone engaging in retaliation.

Diligence
Reports will be handled diligently. A resolution will be adopted within a maximum period of 3 months, except in particularly complex cases, where the period may be extended by up to an additional three months.

Resolution and follow-up
Once the investigation is completed, we will take the necessary actions to address the issue and, where possible, implement corrective measures to prevent recurrence. The reporting person will be informed of progress and outcomes whenever possible and legally permitted.