COMPLAINTS CHANNEL
In Odena, on March 19, 2024.
1. PURPOSE
The purpose of this procedure is to regulate the reception, treatment, investigation and resolution of complaints about alleged irregularities or non-compliance committed by employees, commercial agents, managers or business partners that may arise in the course of FUNDICIONES DE ODENA S.A.’s business activities.
FUNDICIONES DE ODENA S.A.’s Whistleblower Channel is accessible through the e-mail account canaldenuncias@funosa.com, facilitating its use by employees, commercial agents, managers, management committee and Board of Directors, and any other interested parties.
The objective of the Whistleblower Channel is to channel and facilitate the safe formulation of any communication regarding suspicions of irregular conduct, bad business practices and any violation of Compliance obligations, fostering a compliance environment based on the principles and values of FUNDICIONES DE ODENA S.A.
In addition, the procedure seeks to ensure that throughout the process the protection of the privacy of the persons involved and the confidentiality of the data contained in the complaint is effectively guaranteed, which may be made anonymously if the complainant considers it appropriate.
This procedure was approved by the Board of Directors on April 25, 2024.
2. SCOPE OF APPLICATION
This procedure is applicable to all employees, commercial agents, managers, Management Committee and Board of Directors of FUNDICIONES DE ODENA S.A.
3. KEY ASPECTS ASSOCIATED WITH THE COMPLAINTS CHANNEL
3.1 DUTY TO COMMUNICATE
Anyone who has well-founded knowledge of any act or fact that could contravene the principles and ethical values or involve an illegal act or contrary to current regulations must inform FUNDICIONES DE ODENA S.A. through the established channel by sending an email to canaldenuncias@funosa.com.
3.2 REPORTABLE EVENTS
The Whistleblower Channel is an instrument for reporting irregularities or non-compliance. It should not be used indiscriminately, but only for the purposes for which it was conceived.
The reportable events must refer to conduct, non-compliance or irregularities that may go against general ethical principles or constitute an unlawful act or an act contrary to the applicable regulations.
3.3 WHISTLEBLOWER RIGHTS
a) Right to protection during the investigation
FUNDICIONES DE ODENA S.A. will provide due protection to all persons making a complaint under this procedure.
b) Prohibition of retaliation
No retaliation will be taken against the complainant provided he/she has not acted in bad faith.
c) Right to receive information
The complainant shall be informed in writing as to whether the complaint is upheld and the outcome of the investigation.
d) Right to choose
The whistleblower may choose the channel he/she considers most appropriate, including external channels before competent authorities.
e) Right to limited information
No information that is not strictly necessary for the processing of the complaint or its investigation will be requested.
f) Right to anonymity
The complainant may remain anonymous throughout the process.
g) Right to confidentiality
The identity of the complainant shall be confidential and may not be disclosed without his or her consent unless legally required.
h) The right to receive a response within a reasonable period of time.
The complainant will receive an acknowledgement of receipt within a maximum period of seven days from receipt of the complaint.
i) Right to data deletion
The data should be deleted from the reporting system after three months unless it is required to be retained for legal reasons.
4. INVESTIGATION PROCEDURE
The internal procedure regulates the entire life cycle of the complaint from its initial communication to its resolution.
4.1 RESEARCH PHASE
4.1.1 Communication and receipt of the complaint
The complainant should send an e-mail to canaldenuncias@funosa.com with the information related to the reported facts.
E-mail address
Identification of the defendant
Description of the facts
4.2 RESOLUTION PHASE
Following analysis of the evidence, appropriate action will be proposed to the Management Committee or the Board of Directors.
Complaint not admissible
The complaint will be closed if no infraction is detected.
Complaint
If the facts are confirmed, the corresponding sanctioning regime will be applied.
5. CONFLICT OF INTEREST
If the complaint involves persons participating in the investigation, they will be excluded from the process to ensure objectivity.
ANNEX I: ACTIONS CONSIDERED RETALIATORY
Actions such as job changes, dismissals, unjustified sanctions, intimidation, harassment or dissemination of information that harms the whistleblower are considered retaliation.
In Odena, on April 25, 2024.