1. INTRODUCTION AND PURPOSE

In accordance with the provisions of Law 2/2023, of February 20, regulating the protection of people who report on regulatory and anti-corruption violations (“Law 2/2023”), ITURRI,S.A. (“ITURRI” or the “Group”), has implemented an Ethical Channel that meets all the requirements established in Law 2/2023. The Ethical Channel (the “Channel”) is configured as a fundamental pillar of the culture of compliance with the Group and is aimed at strengthening both the culture of information and the integrity system implemented in ITURRI.

The Channel is applicable to all the European subsidiary companies that form part of the ITURRI Group, therefore the content of this Policy must be respected by all Group companies in Europe. 

Through the Channel, any person linked to the activity of the Group (“Informant”), may communicate those behaviors that may result contrary to ITURRI internal regulations, to current legislation (as long as they constitute a serious administrative offense or very serious, turn out suspected of criminal offences, see about infringements of labor law in terms of security and health at work), or when such conduct may make up infringements of Union law European in relation to their financial interests or influence the internal market, provided that said actions were carried out by the Members of the Organization .

ITURRI has appointed the Compliance Committee as Responsible for the Ethical Channel, having agreed in turn, the outsourcing of the management of this in the company ANDERSEN TAX & LEGAL IBERIA, S.L.P. The management of the Canal will be carried out by said company through the technological tool “icloudCompliance” provided by the Company Klab Corporate Project Management, S.L. 

Through the Channel, information may be transferred in writing and orally. through a recording system. In addition to the Ethical Channel, ITURRI has other communication channels with other purposes that remain in force to deal with the issues that, to date, are communicated through of the same, reserving the Ethical Channel for matters within the material scope of Law 2/2023. In this sense, in the event that such channels received a communication whose content is integrated into the material scope of the aforementioned Law, the people who receive the communications must immediately notify the ITURRI Channel Manager, and must comply with the people who receive the communication with all the guarantees of confidentiality and with the principles that affect the Group Channel Manager. 

2. GUARANTEES OF THE INVESTIGATION PROCEDURE

The procedure that will follow the processing of communications received in the Channel is detailed in the“Procedure for the Management of Information received in the Channel ethics of ITURRI” (el “Procedure”), exposing below the guarantees that will be followed both in the reception and management of information, as in the investigation procedure. 

1. confidentiality: any Information 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 were aware of them.
2. Anonymity: the system attends anonymous communications.
3. Independence and autonomy: the Head of the Ethical Channel appointed by the Group's Board of Directors, is autonomous and for the integral management of the Canal, including the procedure for carrying out the internal investigations.
4. Conflicts of interest:the channel establishes mechanisms to avoid conflicts of interest in the management and investigation of communications received.
5. Protection against retaliation: ITURRI will protect whistleblowers who in good faith report breaches of the law from any retaliation. current legislation or internal regulations of the Group. 
6. Rights of defense and presumption of innocence: ITURRI guarantees the right of defense and the presumption of innocence of the people affected by the communications received through the Channel.
7. haste in the management of communications received, avoiding unjustified delays in the management of the System and in the investigation of communications.

3. ESSENTIAL PRINCIPLES OF THE INVESTIGATION PROCEDURE

1. Shipment of Acknowledgment of receipt of the communication to the Informant within the period of seven (7) natural days dfrom reception, with the The only exception is that said acknowledgment could jeopardize the confidentiality of the communication.
2. In relation to termfor the realization of theinvestigation, this may not be greater thanthree (3) monthscounting from the receipt of the communication or, in in the event that acknowledgment of receipt had not been sent to the informant, three (3) monthsstarting of the expiration of the term of seven (7) days after of the communication, except incases of special complexity, in which the term may be extended by three (3) months additional.
3. The possibility of maintaining communication with the Informant is established and, if deemed appropriate, will request additional information.
4. La affected person has the right to be informed of the actions or omissions that are attributed to him, so like to be heard This communication will take place at the time and in the manner that the Responsible considers appropriate. of the Canal, in order to guarantee the success of the investigation.
5. When thefacts can cover evidence constituting a crime, will proceed toremission from information to fiscal Ministery.

4. EXTERNAL CHANNELS OF INFORMATION

Through this, informants are informed that there are external channels with different areas of competence. The Referred external channels are as of the date of this Policy, the following:

1. Independent Whistleblower Protection Authority. For those infractions or breaches that affect or produce effects in the entire Spanish territory, regardless of whether the Autonomous Communities have designated a own independent authority. It also operates in the communication of those infractions or breaches that occur within the scope of more than one Autonomous Community, or that occur in those Communities Autonomous that have not designated their own independent authority.
2. Valencian Antifraud Agency. For those infractions or breaches that affect or produce their effects in the Community Valencian.
3. Anti-fraud Office of Catalonia. For those infractions or breaches that affect or produce its effects in Catalonia.
4. Andalusian Office against Fraud and Corruption.For those infractions or breaches that affect or produce its effects in the Autonomous Community of Andalusia.
5. Office for the Prevention and Fight against Fraud of the Islands Balearics. For those infractions or breaches that affect or produce their effects in the Balearic Islands.
6. Office of Good Practices and Anti-Corruption of Navarra. For those infractions or breaches that affect or produce its effects in the Autonomous Community of Navarra.

5. DATA PROTECTION

ITURRI informs you that the personal data you provide us with will be processed by the administrative body (as Data Controller), in accordance with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, and Law 3/2018 on Data Protection, for the sole purpose of handling the communication made. The processing of your data is legitimised by law and will be kept for the legally established period. Once the legal limitation periods have elapsed, ITURRI will proceed to destroy them. The identity of the informant shall in all cases be confidential and shall not be communicated to the persons to whom the facts reported refer or to third parties. The person to whom the reported facts refer shall in no case be informed of the identity of the Informant or of the person who has made the public disclosure.

You may exercise your rights of access, rectification, limitation and deletion or extension of information on privacy policies through our data protection officer privacidad@iturri.com, as well as file a complaint with the Spanish Data Protection Agency (AEPD).