The whistleblowing channel is a confidential and anonymous means of communication so that you can inform us of those breaches of the rules of conduct established in our Code of Conduct and of those behaviours that are contrary to the law or to the rules in force applicable to the entity.

This is the person who reports or alerts about a possible breach of the Code of Ethics or Conduct or other mandatory internal rules or an offence that may have been committed using the company's resources, so that the facts he or she provides can be investigated.

It is a channel open to all persons who may report in good faith facts that may contravene the internal code of ethics or criminal law, i.e., customers, suppliers, advisors/consultants, employees, former employees, or any other person related to the organisation.

The following behaviours can be reported in this channel:

1. Public health
2. Transport safety
3. Environmental protection
4. Consumer protection
5. Competition
6. Public procurement
7. Prevention of money laundering
8. Corporate taxation
9. Financial interests of the Union
10. Protection of personal data and privacy
11. Network and information systems security
12. Non-compliance with the Code of Conduct
13. Non-compliance with applicable law
14. Non-compliance with internal regulations

If you would like to report other types of situations, please use the reporting channel.

Situations of harassment usually require speed and special attention, such as the adoption of precautionary measures, which this channel cannot provide. The most appropriate channel for reporting this type of situation is the one established in the Protocol against sexual or gender-based harassment in the Equality Plan implemented in your workplace. Please follow the indications established therein to be able to report the facts. If you consider that you have already followed the established protocol and that no one has attended to your request, let us know through this channel, indicating what has happened.

The whistleblowing channel is managed by the Armas Trasmediterránea Group, which is responsible for receiving complaints and deciding on the suitability of opening an internal investigation file, with the collaboration of external professionals with expertise in the matter

Once your communication has been received, it will be studied by those responsible for managing the channel in a totally confidential manner (if you identify yourself) or anonymously (if you have chosen to do so) and you will be informed of the decision taken.

Channel managers may respond in the following terms on a case-by-case basis:

• Redirect you to the appropriate channel for your communication if the ethical channel is not the appropriate one due to the type of issue.
• Request further information if they consider that there are indications but not enough information to make a first decision.
• File the communication if it is considered that there is insufficient evidence, or the communication has been made in bad faith.
• Open an investigation file if it is determined from what has been communicated that there is sufficient evidence of an alleged wrongdoing or non-compliance.

An acknowledgement of receipt shall be issued within seven days of receipt of the communication.

A reply shall be given within a reasonable period, which shall not exceed three months from the date of acknowledgement of receipt.

It is strictly prohibited to take retaliatory or punitive action against any person who, in good faith, reports through the whistleblowing channel any breaches of which he or she becomes aware.

The whistle-blower must have reasonable grounds to believe that the facts presented are true. This protection shall not be lost where the information is inaccurate but can be associated with a bona fide error.

Malicious, frivolous, or abusive reports or reports that deliberately and knowingly provide incorrect or misleading information are excluded from this protection.

The identity of the whistle-blower, and of any third party named in the communication, shall be protected, and kept confidential from unauthorised access.

The identity of the whistle-blower shall not be disclosed without his or her express consent to any person other than a member of staff authorised to receive or follow up complaints. This shall also apply to any other information from which the identity of the whistle-blower can be deduced directly or indirectly.

The whistle-blower has the right to effective judicial protection and to an impartial judge, as well as the presumption of innocence and the right of defence, including the right to be heard and the right of access to his or her file.

The identity of the whistle-blower shall be protected while any investigation triggered by the complaint or public disclosure is ongoing, and the same guarantees of confidentiality and protection of personal data as foreseen for the protection of the identity of the whistle-blower shall apply in any case.

If the complaint concerns the Compliance Officer, you may select the option of contacting an alternative person through this same channel.

Yes, you can consult the Code of Conduct at [incluir link]

In the reporting process you can decide whether to report your personal data or not. If you choose not to do so, the report will be anonymous, so the channel will not store your personal data or contact information. To access the channel and follow up on your report, you can only do so by using the report code provided by the channel and the password you have defined during the reporting process.

The channel is independent of the company and does not record information about the IP address from which you connect.

Some tips to achieve maximum anonymity, as well as informing that the report is anonymous, are as follows:

• Make sure that in the description of the communication you do not include information from which you can be easily identified. The same applies to documents that you attach as possible evidence.
• Do not report from a computer connected to the company network, including a mobile phone connected to the corporate Wi-Fi.
• Ithikios does not log information, but before it reaches our systems it must pass through our own control systems such as proxy's or firewalls and there may be configurations that allow us to know which services it connects to.
• You can use the open-source browser TOR, which anonymises the IP address.

Unfortunately, for security reasons, only the whistle-blower knows your access code and password. If you lose either of them, you will not be able to follow up on the communication. This does not mean that the communication will not continue, but simply that you will not be able to see how it is progressing, or to provide further information if the company requires it.

Please be especially careful with your password and reporting code and keep them in a safe place.

The personal data that you provide to us as a user of the channel or that you provide from third parties (e.g., witnesses) will be treated in accordance with the privacy policy of this channel, accessible from[Política de Privacidad] and which you will also find in the last step of the complaint process. All persons accessing this channel and participating in the handling of communications are bound by a duty of secrecy and confidentiality.

In the first instance, only the Compliance Officer may access the communications received through the channel. If the collaboration of other persons or external advisors is necessary, action will always be taken to guarantee the protection of the whistle-blower and the reported, and the persons involved will be subject to the duty of secrecy and confidentiality.

The whistleblowing channel operates on an external platform: https://ithikios.com. This company receives the complaints and automatically sends them to the company for evaluation. Ithikios servers are in European CPD’s. Your data is encrypted to avoid the risks of intrusion as much as possible.