[ETHICS CHANNEL]Facilitating communication

Code of Ethics and Conduct

At AFIRMARE AUDITORES, we are committed to acting professionally among ourselves, with our clients and with the other organisations in the business environment in which we operate. This commitment encourages us to demonstrate our culture of integrity and good professional practice, and to uphold the values and principles set out in our Code of Conduct, which have always been a defining feature of everyone who forms part of AFIRMARE AUDITORES. We want this to continue to be the case. Accordingly, any situation in which our values may be placed at risk will never be acceptable. To strengthen our culture of integrity, AFIRMARE AUDITORES has an Ethics Channel or whistleblowing channel.

This Ethics Channel facilitates the reporting of possible irregular, unethical or inappropriate conduct where normal communication channels are ineffective. The Ethics Channel may be used by all members of the firm, as well as by clients, contractors, service providers and any other party that maintains a business relationship with AFIRMARE AUDITORES. Our core values and ethical principles, now reflected in this Code of Ethics and Conduct, have always been a defining feature of all the firms that make up AFIRMARE AUDITORES, and we want this to remain the case.

How can a report be submitted?

If you become aware of the commission, by action or omission, of an offence, unlawful act or breach of the AFIRMARE AUDITORES Code of Ethics, you have a duty to submit the corresponding report. Reports may be submitted through either of the following channels:

1.- Through the web form provided below.

2.- By email to info@afirmare.com, setting out the facts to be reported and, where appropriate, including any additional information relevant to the report submitted.

What will happen to my report?

The authorised personnel of the organisation will receive the anonymous report by email. The report will initially be reviewed by the <<Ethics Officer>>, who will determine the most appropriate initial action based on the facts reported and their suitability under the established procedure. However, if your report relates to a member of the quality and risk management team, only the firm’s Quality Officer will receive the report, and the provisions of Policy 3.3 on the operation of the whistleblowing channel within the Ethics Channel will apply.

Confidentiality and data protection

AFIRMARE AUDITORES guarantees the confidentiality of any information submitted through a report and the anonymity of those who wish to remain anonymous, in accordance with the internal operating policy of this Ethics Channel, based on the principles of good faith and non-retaliation.

The processing of personal data within the framework of this Ethics Channel is based on the existence of a public interest, pursuant to Article 6(1)(e) of the General Data Protection Regulation, in detecting and preventing claims and, consequently, preventing damage and liability risks for the entity.

Protection of the reporting person

AFIRMARE AUDITORES undertakes to ensure that no person who reports in good faith a matter of concern under this policy is in any way disadvantaged as a result of submitting that report, whether or not the reported matter is ultimately substantiated. If any person believes that they are being discriminated against or disadvantaged by another member of the firm as a result of having reported a case or assisted the firm in any investigation under this policy, they must immediately inform the Ethics Officer of AFIRMARE AUDITORES, and appropriate measures will be taken to protect them against any retaliation.

Please consult our Code of Conduct here.

Report form:

At AFIRMARE AUDITORES, we remain committed to acting professionally among ourselves, with our clients and with the other organisations in the business environment in which we operate.

This Ethics Channel facilitates the reporting of possible irregular, unethical or inappropriate conduct where normal communication channels are ineffective. If you become aware of the commission, by action or omission, of an offence, unlawful act or breach of the AFIRMARE AUDITORES Code of Ethics, you have a duty to submit the corresponding report. To do so, please complete the following form:

Reporting person’s full name:

Please state your relationship with AFIRMARE AUDITORES, SLP (service provider, partner/shareholder, client, employee, network member, etc.):

Address or means chosen by the reporting person for notification purposes (email):

Full name of the reported person:

Type of breach:

Details of the breach:

Additional information (optional):

Attach documentation (optional):

The reporting person expressly accepts the Legal Notice and Privacy Policy of AFIRMARE AUDITORES, SLP.

I declare that I submit this report in good faith and that, except in the case of unintentional error or omission, the information provided is true. I also declare that I am aware of the processing that may be carried out in relation to the personal data included in this report and of the content of the “Policy on the Use of the AFIRMARE AUDITORES, SLP Ethics / Whistleblowing Channel”.

The data subject expressly accepts the information clause for the report form.