Whistleblowing channel

Whistleblowing Channel policy

1. Whistleblowing Channel

The Whistleblowing Channel is a means through which anyone connected with the organisation can report irregularities or inappropriate conduct within it.

This channel is governed by Spanish Law 2/2023 of 20 February on the protection of persons who report regulatory breaches and on the fight against corruption, which transposes Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 into Spanish law.

2. Purpose

The purpose of the Whistleblowing Channel is to provide a secure and confidential means of submitting reports.

3. Appointment of the Channel Manager

The company will appoint a Whistleblowing Channel Manager. This person will be responsible for diligently monitoring the channel.

4. A secure and confidential channel

Under Law 2/2023 of 20 February, companies are required to protect persons who, in an employment or professional context, detect serious or very serious criminal or administrative offences and report them through the established procedure.

Reports may be submitted anonymously or under the reporter's name. Where the reporting person identifies themselves, it is easier to obtain detailed information about the incidents reported, so that they can be investigated more quickly and effectively. In that case, the Whistleblowing Channel guarantees the absolute confidentiality of the reporting person's personal data and of the communications received.

5. Personal data

All personal data used in the Whistleblowing Channel will be processed and retained for the appropriate period, as set out in Article 24 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD).

Data may be retained for longer, provided the purpose of retention is to keep a record of the operation of the Whistleblowing Channel.

6. Reportable conduct

Any action or conduct contrary to company regulations or to the laws in force may be reported.

The Whistleblowing Channel must not be used to make false or intentional accusations against third parties, and inaccurate or misleading information must not be provided. Nor should it be used to submit proposals or suggestions, or to create unfounded conflict situations, as evidence of the reported facts will be required. Complaints from customers arising from commercial dealings must be directed to the Customer Service department. Employment-related complaints, such as leave, working hours, pay, holidays, etc., will not be processed through this channel.

7. How to use the Whistleblowing Channel

Reports can be submitted by e-mail to canaldenuncias@kerajet.com.

8. Submitting a report

A report should include as much information as possible so that its investigation can proceed quickly. As a guide, this may include:

• Identifying details of the reporting person, if the report is not anonymous.
• The facts being reported.
• Details of the person reported, if a natural person.
• The date of the events.
• Identification of witnesses.
• Etc.

9. Admission of the report

Once the report has been received, and within no more than 7 days, an acknowledgement of receipt stating the report's registration number will be sent to the e-mail address from which it was submitted. The reporting person will also be informed whether the report has been admitted for processing or filed.

To follow up on a report, you can e-mail canaldenunciasseguimiento@kerajet.com quoting the registration number.

10. Investigation

If the report is admitted for processing, a case file will be opened and an impartial and objective investigation will begin to verify the truth of the reported facts. In order to clarify the reported facts, any information and documentation deemed appropriate may be requested. The investigation should not exceed 3 months, although it may be extended by a further 3 months in more complex cases.

All parties affected by the report must be kept informed during the investigation process, always respecting confidentiality and data protection.

11. Resolution

Once the investigation is complete, the report may be:

• Filed: the report will be filed when the reported facts have not been proven or do not constitute any offence.
• Upheld: where the reported facts have been substantiated and constitute an offence, a decision will be issued and the appropriate disciplinary measures will be adopted.

The reporting person will be informed of the outcome of the investigation, unless there are circumstances in which it is advisable to keep the conclusions reached confidential.

Where deemed necessary, the reported facts may be referred to the relevant Authorities.

12. Protection of the reporting person against retaliation

The company undertakes not to retaliate against anyone who submits a report in good faith.