Information clause for the Ethics Channel policy

1. Purpose

This information clause of the Policy on the management, investigation and response to reports governs the management and investigation procedures carried out by AFIRMARE AUDITORES, SLP in compliance with its Code of Conduct and in accordance with the standards established in the applicable audit legislation in force. The Ethics Channel is a transparent and strictly confidential means of communication intended to channel reports submitted by members of the organisation, as well as by third parties with whom it may have dealings, concerning reasonable indications of breaches of the general principles of professional conduct established by the firm, applying criteria of truthfulness and proportionality.

We appreciate your willingness to inform us of any improper conduct or breach of policies within our organisation. We use this whistleblowing channel with the aim of maintaining an ethical and safe environment. Your contributions are essential to preserving integrity and transparency in our relationships with third parties.

2. Information on the Ethics Channel policy

This information clause is promoted by the governing body of AFIRMARE AUDITORES, its administrative body, and is based on a full and absolute commitment to compliance with the applicable legal regulations in force on audit activity, as well as on the implementation of a genuine culture based on values and ethical principles. It is also based on compliance with general principles of conduct and on the application of the principle of due control, in order to promote compliance with internal and external rules and to prevent, detect and eradicate irregular conduct. Its operation is based on the following principles of action:

• Confidentiality: Your identity and the details provided in your report will be treated with the highest possible level of confidentiality, in accordance with applicable laws and provided that this does not compromise the security of the firm.
• Protection against retaliation: The firm prohibits any form of retaliation against those who submit reports in good faith. Any attempt at retaliation will be treated as a serious breach of the firm’s policies and may give rise to disciplinary measures.
• Investigation procedure: Your report will be assessed impartially. An appropriate investigation will be carried out and, where possible, suitable corrective measures will be adopted based on the outcome of the investigation.
• Measures in the event of a conflict of interest: If the reported facts fall within the scope of any member of the administrative body of AFIRMARE AUDITORES, SLP, the company’s Ethics Officer or any other member who could in any way give rise to a conflict of interest for any of those persons, their abstention from participating in the investigation and processing of the report is guaranteed.
• Data protection: The processing of personal data within the framework of the Ethics Channel is based on the existence of a public interest, under the terms established in Article 6(1)(e) of the General Data Protection Regulation, in detecting and preventing claims and, consequently, preventing damage and liability risks for AFIRMARE AUDITORES, SLP, as defined in the Internal Organisation Model and Code of Conduct, and in accordance with Article 24 of Organic Law 3/2018 of 5 December on Personal Data Protection and the guarantee of digital rights. This consists of creating and maintaining an internal reporting information system and investigating possible irregularities or acts contrary to ethics, legality or corporate rules.