Purpose of the Whistleblower Channel

The Whistleblower Channel is designed to provide a secure and confidential mechanism for employees and other stakeholders to report any behaviors, actions, or irregularities that may constitute non-compliance with internal policies, breaches of applicable laws, or actions against the interests of the company or its stakeholders.

This channel aims to:

• Promote a culture of transparency and accountability within the organization.

• Ensure that potential issues are identified and addressed promptly to mitigate any risks or damages.

• Protect the whistleblower from retaliation and maintain confidentiality throughout the reporting and investigation process.

Reportable Behaviors and Irregularities

The Whistleblower Channel is intended for reporting a wide range of behaviors and irregularities, including but not limited to:

• Fraud and Corruption: Any acts of fraud, embezzlement, bribery, or corruption.

• Violation of Laws and Regulations: Breaches of local, national, or international laws, including regulatory non-compliance.

• Workplace Misconduct: Harassment, discrimination, bullying, or other workplace misconduct.

• Health and Safety Violations: Actions that compromise the health and safety of employees or other individuals.

• Environmental Violations: Activities that harm the environment or breach environmental regulations.

• Financial Misconduct: Misappropriation of funds, false accounting, or financial misreporting.

• Conflict of Interest: Any situation where personal interests conflict with professional duties and obligations.

• Confidentiality Breaches: Unauthorized disclosure of confidential or sensitive information.

• Ethical Violations: Actions that violate the company’s code of conduct or ethical standards.

By providing a clear and secure avenue for reporting these issues, the Whistleblower Channel helps the company maintain high standards of integrity and compliance, fostering a positive and ethical work environment.

Rights of the Whistleblower When Reporting a Case via the Whistleblower Channel

Right to Anonymity: Whistleblowers can choose to remain anonymous when submitting a report. Their identity will be protected throughout the process unless they choose to reveal it. Anonymity is preserved to ensure that individuals feel safe to report without fear of personal repercussions.

Right to Confidentiality: The content of the report and the identity of the whistleblower (if provided) will be kept confidential. Information will only be shared with personnel authorized to handle and investigate the reports unless disclosure is required by law during investigations or judicial proceedings.

Protection Against Retaliation: Whistleblowers are safeguarded against any form of retaliation, including dismissal, demotion, harassment, or any other adverse actions, even if the investigation concludes that there was no wrongdoing, provided the whistleblower did not act in bad faith.

Right to Information: Whistleblowers have the right to be informed about the status of their report and the outcomes of the investigation. This includes receiving an acknowledgment of receipt within seven calendar days of receiving the report, unless doing so could jeopardize the confidentiality of the communication, and updates on the progress and final resolution within three months.

Right to Limited Disclosure: Whistleblowers are only required to provide information that is essential for processing the report. Additional unnecessary data will not be requested or retained. If information needs to be shared with third parties (e.g., legal advisors), the whistleblower will be informed unless such transfer is legally mandated.

Right to Data Protection: Personal data provided by whistleblowers will be handled under data protection regulations, including the General Data Protection Regulation (GDPR) and national laws. Whistleblowers can exercise their data protection rights, such as access, rectification, and deletion of personal data.

Right to a Reasonable Response Time: Whistleblowers will receive an acknowledgment of their report within a maximum of seven days. The investigation and resolution of the report should not exceed three months, except in exceptional cases where the period may be extended to six months due to the complexity of the case.

Right to Data Deletion: Data related to the report will be deleted after three months, unless needed to preserve evidence or if legal proceedings or investigations are ongoing. This ensures that personal data is not retained longer than necessary.

Right to Fair Treatment: Whistleblowers will be treated fairly and respectfully throughout the process. Any form of discrimination or unfair treatment related to their reporting will not be tolerated.

By ensuring these rights, the Whistleblower Channel aims to encourage the reporting of misconduct while providing a safe and supportive environment for whistleblowers.

Whistleblower Channel Investigation Procedure

Initial Phase:

1. Submission: Whistleblowers must fill out the available complaint form individually, even if multiple people are aware of the same issue.

2. Form Details:
• Email
• Identification of the reported party (optional for anonymous reports)
• Description of the facts
• CAPTCHA verification to prevent false entries

3. Details: Whistleblowers should provide sufficient information and may attach relevant files.

4. Acknowledgment: The company will acknowledge receipt within 7 even calendar days of receiving the report, unless doing so could jeopardize the confidentiality of the communication, and may request additional details like:
• Location and description of the irregularity
• Time and frequency of occurrence
• Identification of responsible persons
• Evidence or indications

If no response is received within 30 days, the report is considered waived, except for critical cases.

Instructive Phase:

1. Investigation Start:
• Assign a risk level (LOW, MEDIUM, HIGH, CRITICAL)
• Record the date and set a resolution deadline
• Develop investigation and collect evidence
• Prepare a report on investigative actions

2. Deadline: Resolution should be within 3 months from acknowledgment, extendable to 6 months in complex cases.

Resolution Phase:

1. Issuing Resolution:
• Document and present the facts and investigation results
• Communicate the resolution to both the whistleblower and the reported party

2. Possible Resolution:
• Verification of Facts: Propose corrective measures.
• No Verification: Close the case and provide information on external reporting procedures.
• Referral: If a crime or another entity is responsible, the report may be referred, potentially requiring whistleblower identity disclosure with consent.

This streamlined procedure ensures thorough and confidential handling of reports, protecting the rights of whistleblowers and maintaining the integrity of the investigation process.

Misuse of Reporting Channels and False Allegations

In cases of improper utilization of the whistleblower channel or the dissemination of false allegations, comprehensive measures will be implemented in adherence to company protocols and applicable legal statutes.

These measures may encompass a thorough investigation to ascertain the veracity of the claims and identify any deliberate misuse of the reporting system, irrespective of whether the source is an employee or a third party associated with the company. Depending on the severity of the infraction, disciplinary actions will be taken or other appropriate actions in the case of third-party involvement.

We prioritize the integrity of our reporting channels to uphold ethical standards and foster a transparent and equitable work environment for all stakeholders.