COMPLAINTS CHANNEL

The ICG Group with the objective and commitment to guarantee good corporate social responsibility, as well as good governance practices, in accordance with the provisions of our criminal risk prevention policies and what is contemplated in Law 02/2023 of 20 February, regulating the protection of people who report regulatory infractions and the fight against corruption, the following “Complaints Channel” is established, which will act as an Internal Information Channel and whose legal provisions will be cited succinctly, for information purposes, next.

NATURE OF THE INFORMATION TO BE PRESENTED

Based on this, the presentation of communications on:

Actions or omissions that may constitute violations of European Union Law.

Serious or very serious criminal or administrative infractions.

Any other communications that refer to perceived risks or infractions, in any other area, whether labor, civil, criminal or administrative, that affect the ICG Group.

Said information may be presented, by way of example and not limitation, by:

1. Those who have the status of “Informants”, according to article 3 of Law 02/2023, including: workers, public employees, self-employed workers, shareholders, participants, people belonging to the administrative body, etc.

2. Those informants who publicly communicate or reveal an infraction, including information obtained within the framework of an employment or statutory relationship that has already ended, volunteers, interns, etc. As well as those whose employment relationship has not yet begun, in cases where the information has been obtained during the selection or pre-contractual negotiation process.

EXTERNAL INFORMATION CHANNELS

In addition to the existence of this Internal Information Channel, there are, in turn, External Information Channels, to communicate information to the competent authorities and, where appropriate, to the institutions, bodies and organizations of the European Union.

To this end, they are made up of:

- Institutions, bodies or organizations of the European Union

To this end, it is recommended to go to:

https://european-union.europa.eu/contact-eu/make-complaint_es

- Independent Whistleblower Protection Authority (A.A.I.)

Still pending creation, despite the fact that its regulation is established within Law 02/2023 itself.

- The authority of the Administration of the Autonomous Community competent in the matter.

Being in this case, the Anti-Fraud Office of Catalonia, until its own regional regulations are regulated in this regard, by virtue of the Seventh Additional Provision of Law 03/2023, of March 16, on fiscal, financial, administrative and public sector by 2023.

PRESENTATION METHOD

The information may be provided either in writing, through postal mail or through any electronic means enabled for this purpose, or verbally, by telephone or through a voice messaging system. It may be done confidentially or anonymously. At the request of the informant, it may also be presented through a face-to-face meeting within a maximum period of seven days.

Verbal communications, including face-to-face and telephone communications, must be fully and accurately documented, by recording or transcription, with the prior consent of the complainant and the opportunity to verify, rectify and accept the transcription of the conversation by signing.

In the communication, the informant may indicate the route he chooses to receive notifications.

In addition to contemplating the admissibility criteria of article 18 of the aforementioned Law 02/2023, all complaints must necessarily express in the most detailed way possible the violation being reported and the people involved. In addition, all the evidence available will be attached and any other evidence that is not available but that the Group can obtain will be proposed. If the above is not complied with, and the omission cannot be corrected, the complaint will be eliminated as it lacks sufficient support to be investigated.

Given the possibility that the communication is sent through channels other than those previously established, confidentiality is guaranteed, and to this end, the personnel not responsible for its treatment must be informed that their breach represents a very serious infraction and that they are obliged, as recipients. of the communication, to immediately send it to the person responsible for the Information System.

In this Complaints Channel, other communications that do not fall within the material scope of application of the aforementioned Law may be submitted, but the provision is made, in its article 7.4, that these and their senders are outside its scope of protection.

PROCESSING

Once the communication has been received and has been validly made, acknowledgment of receipt will be given within a period of seven calendar days following its receipt, unless this puts the confidentiality of the communication at risk.

In this, information will be provided on the external information channels before the competent authorities and before the institutions, bodies or agencies of the European Union, as well as information related to data protection.

The possibility of maintaining communication with the informant and the possibility of requesting additional information is reserved.

After that, the study of its admission for processing will proceed. Both in the event of its admission for processing, and in the case of its reasoned inadmissibility, the informant will be notified of this circumstance.

If this preliminary study shows that the facts could constitute a crime, the information will be sent to the Public Prosecutor's Office. And, if they affect the financial interests of the European Union, it will be sent to the European Public Prosecutor's Office.

In the event that, based on the tests carried out, it is found that relevant behavior may exist, the affected person will be informed and given a hearing, as well as their right to be heard at any time.

In no case will the identity of the informant be communicated to the affected subjects nor will access to the communication be given; During this investigation of the facts, notice of the communication will be given with a succinct list of facts.

Furthermore, respect for the presumption of innocence and the honor of the affected persons will be respected and demanded.

TERMINATION

Once the actions are completed, a report will be issued and one of the following decisions will be adopted:

a) File the file, with notification of the decision to the informant and the affected person.

b) Referral to the Public Prosecutor's Office if the facts could have the character of a crime, despite not initially appreciating the evidence.

c) Agreement to initiate the disciplinary regime and/or adoption of measures.

COMPUTATION OF DEADLINES

The files must be resolved within a maximum period of three months from the receipt of the corresponding communication informing of the circumstances.

If acknowledgment of receipt is not sent, the maximum period for resolution will be three months from the expiration of the period of seven days after the communication is made.

In cases of special complexity, this maximum period of three months may be extended to a maximum of another three additional months.

DATA PROTECTION

Regarding the provisions relating to Data Protection, the provisions of Regulation (EU) 2016/679 (RGPD) will be followed, in Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, in Organic Law 7/2021, of May 26, on the protection of personal data processed for the purposes of prevention, detection, investigation and prosecution of criminal offenses and execution of criminal sanctions, and in Law 02/2023 , of February 20, in its entirety and, especially in its articles 29 to 33.

GENERAL CONSIDERATIONS OF PROTECTION OF THE INFORMANT AND PRESUMPTION OF INNOCENCE OF THE ALLEGED OFFENDER

This Whistleblowing Channel guarantees the confidentiality of the identity of the informant and any third party mentioned in the communication, and of the actions carried out in the management and processing of the same, as well as compliance with the data protection regulations of personal nature, preventing access by unauthorized personnel.

At the same time, the protection of the informant against reprisals of any kind is guaranteed.

The presentation, and subsequent processing, of anonymous communications is permitted.

It is guaranteed that the communications presented will be treated effectively within the corresponding entity, addressing them to the Head of Regulatory Compliance of the ICG Group, and then proceeding as appropriate for each company in the Group.

Persons who had reasonable grounds to believe that communication or public disclosure of such information was necessary to reveal an act or omission will not incur liability in relation to communications. This will not affect criminal liabilities.

Se respetará y se exigirá el respeto a la presunción de inocencia y al honor de la persona presuntamente infractora, reconociendo, a su vez, sus derechos a la defensa y al conocimiento de los hechos que se le imputan, de forma anonimizada.

In light of all this, the identification of those responsible for the treatment and the following means of contact are made available:

Responsible for the Internal Information System of the ICG Group:

Criminal Risk Committee.

Designated person responsible for the Internal Information System:

Andreu Purroy Montull

Contact information

INICIATIVES DE COMUNICACIONS GEMINIS, SL
C. Mestral, s/n, Polígono Industrial de Torrefarrera, 25123
Telf.: 973 751 533
Fax.: 973 751 757
Email.: canaletico@icg.es