INESCOP, (“Inescop”, the “Company” or the “Organization”), has an Internal Information System (the “System”), which is configured as a fundamental pillar of the Company's compliance culture. With the entry into force of Law 2/2023, of February 20, regulating the protection of people who report regulatory infractions and fights against corruption, Inescop has modified its System with the aim of strengthening both the culture information such as the integrity system implemented in the Organization.

Through the System, any person linked to the Company's activity may communicate those behaviors that may be contrary to current legislation, when they constitute a serious or very serious administrative infraction, are suspected of a criminal offense or when the above could constitute infringements of the law of the European Union in relation to its financial interests or that affect the internal market, in addition to those that are contrary to the internal regulations of Inescop, provided that the above were carried out by the members of the Organization.

Through the System, information may be transferred in writing and verbally through a voice recording system. Inescop integrates into this System all existing communication channels to date, and has designated its Compliance Officer as Responsible for this. The management of the internal information system has been outsourced to Inescop, who will manage it through the technological tool “icloudCompliance” provided by the company Klab Corporate Project Management, S.L.

The procedure that will follow the processing of communications received in the Internal Information System is established in the Procedure for the Management of Information received in the Internal Information System of Inescop (the “Procedure”), with the guarantees set out below. and principles that will be followed both in the reception and management of information and in the investigation procedure.

Guarantee

1. Confidentiality: any information will be treated with the utmost confidentiality and will respect, in all cases, the legislation and regulations regarding data protection. The person responsible for managing the System and the investigation will keep the strictest secrecy regarding the identity of the informants and those affected, when they have knowledge of them.
2. Anonymity: the System handles anonymous communications.
3. Independence and autonomy: the System Manager designated by the Organization's Board of Directors is autonomous and independent for the management of the System.
4. Conflicts of Interest: the System establishes mechanisms to avoid conflicts of interest in the management and investigation of communications received.
5. Protection against retaliation: Inescop will protect informants who in good faith report breaches of current legislation from any retaliation.
6. Rights of defense and presumption of innocence: Inescop guarantees the right of defense and the presumption of innocence of the affected people.
7. Speed in the management of communications received, avoiding unjustified delays in the management of the System and in the investigation of communications.

Essential principles of the Procedure

1. Sending the acknowledgment of receipt of the communication to the Informant within a period of seven (7) calendar days from receipt, with the sole exception that said acknowledgment could jeopardize the confidentiality of the communication.
2. Regarding the period for carrying out the investigation, this may not exceed three (3) months from the receipt of the communication or, in the event that acknowledgment of receipt has not been sent to the informant, three (3) months. months from the expiration of the period of seven (7) days after the communication is made, except in cases of special complexity, in which the period may be extended for an additional three (3) months.
3. The possibility of maintaining communication with the Informant is established and if it is considered that they contributed, additional information will be requested.
4. The affected person has the right to be informed of the actions or omissions attributed to him or her, as well as to be heard. This communication will take place in the time and manner considered appropriate by the System Manager in order to guarantee the successful completion of the investigation.
5. When the facts may show evidence of a crime, the information will be forwarded to the Public Prosecutor's Office.