1. INTRODUCTION AND OBJECT

HELADOS ESTIU S.A. (“ESTIU”, the “Society” or the “Organization n”) has an Internal Communication Channel (the “Channel”), which is configured as a fundamental pillar of the Organization's culture of compliance. With the entry into force of Law 2/2023, of February 20, regulating the protection of people who report violations of regulations and the fight against corruption, ESTIU has modified the previous Channel with the purpose of to strengthen both the culture of information and the integrity system implemented. 

Through the new Channel, any person linked to the Organization's activity will be able to register. communicate those conducts that may be contrary to the internal regulations of the Organization, concerns or information regarding safety, quality, authenticity and legality in accordance with the provisions of the standards BRC and IFS. Conduct contrary to what is established in the current legislation , when these constitute an infraction administrative serious, very serious, also violations of labor law in matters of safety and health, conduct suspicious of a criminal offense , infringements of European Union law in relation to your financial interests or that affect the internal market. As long as the previous ones were carried by the members of the Organization .

Written and verbal information may be transferred through the Channel through a recording system. ESTIU integrates, in this Channel, all existing communication channels to date, designating the Internal Communication Channel Responsible for the Internal Communications Committee of Compliance. 

The procedure that will be followed by the search engine. the processing of the communications received is established in the Procedure for Management of Information received in the Internal Communication Channel of ESTIU (the “Procedure ”), explaining below the guarantees and principles that will be followed both in the reception and management of communications and in the procedure research. 

2. GUARANTEES OF THE INTERNAL COMMUNICATION CHANNEL

1. Privacy: any information will be confidential. It will be treated with the utmost confidentiality and will respect, in any case, the legislation and regulations on data protection. The people responsible for the management of the Canal and the investigation will keep the strictest secrecy regarding the identity of the informants and those affected, when they become aware of them.
2. Anonymity: the Internal Communication Channel serves anonymous communications.
3. Independence and autonomy: the Head of the Internal Communication Channel designated by the Board of Directors of the Organization is autonomous and independent for the management of the Channel.
4. Conflicts of Interest: the Canal establishes mechanisms to avoid conflicts of interest in the management and investigation of communications received.
5. Protection against retaliation: ESTIU will protect any person who may be subject to retaliation. of any retaliation against whistleblowers who, in good faith, report breaches of current legislation. 
6. Rights of defense and presumption of innocence: ESTIU guarantees the right of defense and the presumption of innocence of the affected persons.
7. Celerity in the management of the communications received, avoiding unjustified delays in the management of the communication. n del Canal and in the investigation of communications.

3. ESSENTIAL PRINCIPLES OF THE INVESTIGATION PROCEDURE

1. Sending acknowledgment of receipt of the communication to the Informant within seven (7) calendar days from the reception, with the sole exception that said acknowledgment could jeopardize the confidentiality of the communication.

• Regarding the term for investigation, he will not be able to do so. be greater than three (3) months from the receipt of the communication or, in if acknowledgment was not sent to the informant, three (3) months from the expiration of the seven (7) day period after the communication has been made, except in cases of special complexity , in which it will be possible to extend the term by three (3) additional months.

1. The possibility of maintaining communication with the Informant is established and if deemed appropriate, you will be prompted for a password. additional information.
2. The affected person has the right to be informed of the actions or omissions strong> that are attributed to it, as well as to be heard. This communication will have place at the time and in the manner deemed appropriate by the Channel Manager in order to guarantee the success of the investigation.
3. When the facts may have indications constituting a crime, the investigation will proceed. to the remission of the information to the Fiscal Ministry.