Compliance

CODE OF CONDUCT

  1. Preamble

The Code of Conduct from the Inox Torres Group, S.L (ITG), summarizes the main principles and rules governing our actions. It represents respect towards equality, ethical values and human rights, as well as total agreement with his stakeholders (employees, clients, suppliers,) and its environment.

The Company assumes compliance in always acting according on existing laws in countries, rejecting illegal activities and exploitation, child labor included. Furthermore it is committed to make rules and internal regulations of Society been accomplished.

We deeply trust in each person to have in mind these commitments and consequently act in his daily activities.

2. Commitments with stakeholders 

ITG understands that each involved person in commercials relationships must follow moral rules, which are very important to achieve a well-done work, and bringing vale to society.

3. Commitments with the organization

3a) Use and protection of assets: The Company will provide employees with all necessary means and resources to carry out their work, and requires a responsible and efficient use of them.

Means that the Company offers employees should be used for purposes devoted to the performance of professional activity only.

3b) Corruption and bribery: Bribery is the act of giving someone or receiving from someone anything of value, either directly or indirectly, as an inducement to influence the will of people outside the Company to gain an advantage or influence contrary to the principles of honesty and integrity.

ITG will not tolerate bribery of any kind.

Employees must not under any circumstances give or accept, directly or indirectly, bribes of any kind, either in their relationship with public or private entities. In addition, the Company does not tolerate other persons or entities use these practices with ITG’s employees.

The prohibition on the use of bribery extends to third parties acting on behalf of the companies of the Company.

3c) Conflict of interest: Those activities or personal interests of the employee who collide with the interests of the Group, either directly or indirectly, must be avoided.

3d) Data processing and data protection: ITG has all the necessary means to protect personal data of employees, customers and suppliers.

The information from IT systems such as e-mail and other Internet systems, is owned by ITG and must be used for commercial purposes.

Those employees whose functions or responsibilities require the management of confidential information must preserve it and not disseminate and communicate it to others.

4. Implementation and contact address. 

All ITG’s employees, customers and suppliers can consult any doubt about the interpretation of the behavior patterns that appear in this Code, and shall report, in good faith and without fear of reprisal, any breach of the Code guidelines they encounter in their professional performance, to their manager or the representative of the Code of Conduct Committee via e-mail codeofconduct@aguilarysalas.com.

Communications made to the Code of Conduct Committee will be treated confidentially and in accordance with the provisions of the Organic Law on Data Protection.

Les Franqueses del Vallès, November 2023

VLADIMIR MARTÍNEZ TORRES

CEO

Inox Torres Group, S.L

JUAN MARTÍNEZ TORRES

CEO

Inox Torres Group, S.L

1. INTRODUCTION

“Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and fight against corruption” (hereinafter Law 2/2023) has transposed into Spanish law European Directive 2019/1937, also known as the “Whistleblowing” Directive, concerning the protection of persons who report breaches of Union law.

This regulation establishes the obligation for legal entities in the public and private sectors with more than 50 employees, and those private sector legal entities that fall within the scope of application of European Union acts on financial services, products, and markets, to have an Internal Information System (IIS) to communicate, in a timely, adequate, and confidential manner, the actions or omissions provided for in this Law.

This Internal Information System is configured as the preferred channel for receiving information about the actions or omissions identified therein, and for these purposes it must:

  • Allow communication about the infringements provided for in the Law.
  • Guarantee the confidentiality of the identity of individuals using the information system, and of any third party mentioned in the communication and of the actions developed in its management.
  • Allow the submission of communications in writing or verbally, or both.
  • Integrate the different internal information channels that may be established in the entity.
  • Guarantee the effective processing of submitted communications.
  • Have a System Manager.
  • Have a Policy and a Procedure for Managing received communications.
  • Establish guarantees for the protection of whistleblowers.

Inox Torres Group, S.L. has implemented an “Internal Information System and Whistleblower Protection Policy” which establishes the general principles of the Internal Information System, to which it commits in the development of the business activity of the companies that comprise it.

This Policy outlines the internal functioning of the Whistleblower Channel as a means to confidentially, transparently, and adequately communicate behaviors that may entail an irregularity or an act contrary to legality, or to applicable internal regulations, when committed by members of Inox Torres Group, S.L., including its management team, employees in general, as well as representatives or employees of companies collaborating with the entity in its various activities.

Taking into account all these precedents, the present “Procedure for Managing Communications of the Internal Information Channel” (hereinafter the “Procedure”) is developed, which elaborates on the aforementioned Policy and constitutes a corporate tool made available to all individuals who will be identified later, to facilitate the communication, management, investigation, monitoring, resolution, and confidentiality of communications made in good faith, in relation to possible behaviors or actions contrary to current legality, and likewise, to the principles, ethical and internal norms of Inox Torres Group, S.L., and their consequent protection against any type of retaliation.

2. SCOPE

This Procedure is applicable to Inox Torres Group, S.L. For these purposes, the Group shall be considered to include the parent entity and its subsidiaries (those entities over which it holds control) listed below:

  • Inox Torres Group, S.L.

3. SCOPE OF APPLICATION

3.a. Material Scope

Regarding the subject matter of the information, it follows from Law 27/2023 that the internal information channel can be used to report serious misconduct or alleged corruption, which may constitute serious or very serious criminal or administrative offenses related to the entity’s activities, which the whistleblower has observed or about which they have received information in the course of their work or professional relationship.

Law 2/2023 itself and Directive (EU) 2019/1937 list as such, information referring to:

  1. Infringements falling within the scope of application of the European Union acts listed in the annex to the aforementioned Directive relating to the following areas:
    a) public procurement
    b) financial services, products and markets, and prevention of money laundering and terrorist financing
    c) product safety and compliance
    d) transport safety
    e) environmental protection
    f) radiation protection and nuclear safety
    g) food and feed safety, animal health and animal welfare
    h) public health
    i) consumer protection
    j) protection of privacy and personal data, and security of network and information systems
  2. Affecting the financial interests of the European Union as contemplated in Article 325 of the Treaty on the Functioning of the European Union (TFEU).
  3. Impacting the internal market, as contemplated in Article 26, paragraph 2 of the TFEU, including infringements of European Union rules on competition and state aid, as well as infringements related to the internal market in relation to acts that infringe corporate tax rules or practices whose purpose is to obtain a tax advantage that distorts the object or purpose of the applicable corporate tax legislation.
  4. Actions or omissions that may constitute a serious or very serious criminal or administrative offense. In any case, all criminal or administrative offenses, serious or very serious, that imply economic damage to the Public Treasury and Social Security will be understood to be included.
  5. Infringements of labor law regarding safety and health at work reported by workers, without prejudice to the provisions of their specific regulations.

The whistleblower must provide, at a minimum, a reference to the subjective scope of the infringement (matter or regulation infringed: European Union law; criminal offense; or administrative offense); and a description of the facts being communicated (relevant information about what happened), as detailed as possible, attaching any available documentation, if applicable.

Similarly, they may provide their name and surname, and a contact phone number, if they do not choose to make this communication anonymously.

If they know the identity of the person responsible for the reported irregularity, or have brought these facts to the attention of another body or entity through an external channel, they may also provide this information.

The Whistleblower Channel cannot be used as a suggestion box, nor as a means to submit inquiries or requests, complaints, or claims.

By way of example, the following cannot be communicated through this channel:

  • Complaints or claims made by policyholders about the insurance contract they have subscribed. These must be submitted to the Entity’s Customer Service.
  • Subjective comments or value judgments that are in no way related to an action, conduct, or behavior contrary to current legality, or unethical.

3.b. Subjective Scope

Individuals who have a labor or professional relationship with the AEPD can use the internal information channel and benefit from the protection granted by Law 2/2023 as whistleblowers, to communicate information about the actions or omissions described in Article 2 of Law 2/2023.

This labor or professional relationship, which implies dependence on the AEPD, is what makes special protection against possible retaliation necessary and appropriate.

In any case, for this AEPD, for the purposes of Law 2/2023, the following are considered whistleblowers:

  • Persons who are employees or employed workers.
  • Collaborating self-employed persons (freelancers).
  • Shareholders, participants, and persons belonging to the administrative, management or supervisory body of the company, including non-executive members.
  • Any person working for or under the supervision and direction of contractors, subcontractors, and suppliers.
  • Whistleblowers who communicate or publicly disclose information about infringements obtained within the framework of a terminated employment or statutory relationship, volunteers, interns, workers in training periods regardless of whether or not they receive remuneration, as well as those whose employment relationship has not yet begun, in cases where information about infringements was obtained during the selection process or pre-contractual negotiation.

It is important to highlight that reports made through the whistleblower channel must be made in good faith, meaning they must be supported by evidence and concrete facts.

4. INFORMATION SYSTEM MANAGER

The administrative body of Inox Torres Group, S.L. shall be competent for the appointment of the natural person responsible for the management of the information system (hereinafter the “System Manager”), and their removal or dismissal.

The System Manager shall perform their duties independently and autonomously with respect to the other bodies of the Inox Torres Group, S.L. to which this Procedure applies. They may not receive instructions of any kind in the exercise of their duties, and shall have all the personal and material means necessary to carry them out.

It is the responsibility of the System Manager to monitor, comply with, and verify the sufficiency of the measures included in this Procedure, as well as to process and manage the communications that may be made under the provisions of this document, guaranteeing confidentiality in the processing of such communications at all times.

The System Manager will manage all communications received through the established Information Channel regarding the possible commission of an illicit or irregular act described in section 3.1 of this procedure.

Access to this channel will be limited, within the scope of their competencies and functions, to:

  1. The Internal Channel System Manager
  2. The administrator(s) delegated by the system manager.
  3. The managers designated for processing certain reports according to their scope.

The functions of these bodies, as appropriate, shall be:

  • Receipt, registration, and management of reports received through the whistleblower channel.
  • Designation of the person or team responsible for investigating received reports.
  • Ensuring the protection of whistleblowers and the confidentiality of received reports.
  • Evaluation of the veracity and credibility of received reports.
  • Decision-making on appropriate measures based on investigation results.
  • Monitoring and periodic review of the report management process and the company’s internal policy.
  • Preparation of reports and recommendations for senior management on received reports and measures adopted.

5. INFORMATION CHANNEL

Inox Torres Group, S.L. has enabled the “Whistleblower Channel” section on its website

https://www.inoxtorres.com/ and https://www.aguilarysalas.com/, where information about the internal channel for communicating actions or omissions referred to in section 3.1 of the Procedure, related to the activities carried out by Inox Torres Group, S.L. companies, will be published.

This is a secure channel, with guarantees of confidentiality and whistleblower protection.

Making a communication through the Whistleblower Channel does not prevent the whistleblower from making the same communication to any other competent body.

Similarly, any natural person may use the external information channel of the Independent Authority for Whistleblower Protection (A.A.I.) regulated in Law 2/2023, or of the corresponding regional authorities or bodies that have also established a general information channel, or of any other national or European public body that has a specific channel to communicate the commission of any actions or omissions included in the material scope of this Procedure, either directly or after communication through the internal channel.

6. RECEIPT OF COMMUNICATIONS

Any whistleblower who detects conduct liable to be communicated through the Information Channel enabled by Inox Torres Group, S.L., must bring it to the attention of the System Manager through the following means:

  • Communication using the whistleblower channel by accessing the following URL:
    https://compliance.legalsending.com/canal/?C=48604629019042042
  • Sending a communication to the email address: dlopez@aguilarysalas.com
  • Sending by post, addressed to Inox Torres Group, S.L., attn: Internal Information System Manager, Mr./Ms. Juan Martínez Torres.
  • At the request of the whistleblower, by means of a request addressed to the System Manager, communication may be made through a face-to-face meeting. In this case, the whistleblower will be warned that the communication will be recorded and will be informed of the processing of their data in accordance with the provisions of Regulation (EU) 2016/679 and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.

Persons making a communication through the means provided in this procedure must ensure that, if personal data is provided, it is true, accurate, complete, and up-to-date.

Persons submitting a communication reporting an irregularity or non-compliance with applicable regulations must do so in good faith, with respect for the truth, with the conviction of acting correctly and solely for the benefit of Inox Torres Group, S.L., and society in general.

A communication will be understood to have been made in good faith, and in accordance with what is established in this Procedure, when:

  • The information transferred is based on facts or indications from which it can reasonably be inferred that an action or omission contrary to current legality has been committed.
  • The communication has been made without contempt for the truth, and without intent of revenge, moral harassment, causing professional or employment harm, or damaging the honor of a person or a third party.

The misuse of the Information Channel, or the making of false or bad faith communications, may, when appropriate and these circumstances have been verified, lead to the imposition of disciplinary sanctions by Inox Torres Group, S.L., without prejudice to any civil liability for harm to honor or the commission of a crime of libel or slander that such behaviors or actions may entail.

Inox Torres Group, S.L. will not allow any type of retaliation against persons who make communications that have been submitted in good faith. In this regard, whistleblowers will be protected as expressly established later and as set forth in the Group’s Internal Information System and Whistleblower Protection Policy.

7. CONFIDENTIALITY AND PERSONAL DATA PROTECTION

The Procedure regulated in this document involves the storage of personal data, so the conditions of its implementation are subject to current legislation. Consequently, all processing of personal data carried out in application of this Procedure will be carried out in accordance with the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and fight against corruption, with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter GDPR), as well as with Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (hereinafter LOPDGDD).

In accordance with the aforementioned regulations, it is informed that the personal data provided as a result of this Procedure will be processed as data controller by the corresponding administrative or governing body of Inox Torres Group, S.L., and are cited in section 2 “Scope” of this Procedure, for the purpose of processing, investigating, and managing the received communication.

The processing is supported both by compliance with the legal obligation established in Law 2/2023 and by public interest.

During its processing, the information established in Articles 13 and 14 of the GDPR will be provided to both the whistleblower and the affected party.

Access to the data is limited, within its competencies and functions, exclusively to the System Manager, the administrators or managers designated by them, the Compliance Officer, and the Data Protection Officer.

Inox Torres Group, S.L. has implemented security measures in the Whistleblower Channel and in the internal information channels that are integrated into said channel, which guarantee maximum confidentiality regarding the communications made, prevent access by unauthorized personnel, and potential loss of such information.

In adherence to the principle of confidentiality, the person affected by the communication sent through the Whistleblower Channel may not access the data of the person who made it, nor of any person who may be involved in the communicated actions or omissions, during the processing of the procedure.

The affected person’s right of access is therefore limited to their own personal data.

The data subject to processing may be stored in the Internal Information System only for the time strictly necessary to decide on the advisability of initiating an investigation into the reported facts. This period shall in no case exceed three months from the receipt of the communication without investigative actions having been initiated, unless the purpose is to provide evidence of the system’s operation or administrative or judicial proceedings arise.

Interested parties may exercise their data protection rights by sending a written communication to the postal address: C/ Irlanda 6, 8520, Les Franqueses del Vallés, Barcelona, or to the email address info@inoxtorres.com, with the subject: “Canal del informante” (Whistleblower Channel).

You can consult more information in our whistleblower channel privacy policy, which is located in this section of the previously indicated web pages.

8. RIGHTS AND DUTIES OF THE WHISTLEBLOWER

8.a. Rights of the whistleblower:

  • Right to confidentiality, so that the System Manager may not communicate the whistleblower’s identity to the affected person, with the exceptions legally provided or in those cases where the latter expressly consents when, otherwise, it would not be possible to continue with the investigation.
  • Right to know the information related to the processing of personal data within the framework of the Internal Information System.
  • Right to information about the possible communication of data, under the regulations, both to judges and courts, and to the persons or bodies deemed appropriate, involved in any phase of the investigation.
  • Right not to suffer retaliation for the communication made, provided that they act in good faith.
  • Right to be informed of the resolution or archiving of the communication made, where applicable.

8.b. Duties of the whistleblower:

  • Duty to act in good faith. Communications made in bad faith may lead to disciplinary and/or sanctioning measures against the reporting person, where appropriate.
  • Duty to provide the data and documents they have related to the reported facts.
  • Duty of confidentiality. The whistleblower may not communicate the identity of the person affected by the communication they make to any body or person other than the System Manager, with the exceptions legally provided.

The conduct of the whistleblower who acts in good faith and with a willingness to cooperate may be taken into account by Inox Torres Group, S.L. for the purpose of qualifying or, where appropriate, sanctioning their participation or relationship with the facts subject to communication.

9.RIGHTS OF THE AFFECTED PERSON

  • Right to be informed that they are involved in an investigation process, resulting from a communication submitted through the Information Channel, at the appropriate time and in the appropriate manner to ensure the successful outcome of the investigation of the facts.
  • Respect for the presumption of innocence.
  • Right to receive information about the actions or omissions attributed to them.
  • Right to submit written allegations, to be heard, and to provide any means of proof they deem appropriate and relevant.

10. COMMUNICATION REQUIREMENTS

For a communication made through the Whistleblower Channel to be adequately managed, as far as possible, it must contain the following minimum content:

11. RECEIPT AND PROCESSING OF COMMUNICATIONS

11.a. Registration

Upon receipt of a communication through the information channel, the System Manager shall proceed with its registration, assigning it an identification code.

This registry shall have adequate levels of protection to guarantee the security of the incorporated data and prevent its manipulation.

Access to this registry shall be restricted exclusively to the System Manager, and administrators or managers designated by them.

All received communications shall be documented in said registry, completing the following data for each of them:

a) Identification code

b) Date of receipt

c) Nature of the communication and persons involved

d) Date of inadmissibility, if applicable

e) Status of the investigation and inquiry

f) Resolution of the file

g) Measures adopted

h) Date of closure

 

11.b. Acknowledgment of receipt

Within a period not exceeding seven working days from said receipt, acknowledgment of receipt of the communication shall be made, unless the whistleblower has expressly waived receipt of communications related to the investigation, or the System Manager reasonably considers that the acknowledgment of receipt of the information could compromise the protection of the whistleblower’s identity, or that the communication was made anonymously.

11.c. Verification

Once the communication is registered, the System Manager will verify whether it exposes facts or conduct that fall within the material scope of application described in section 3.a. above.

In the event that the System Manager verifies that the received communication is relevant but its content is insufficient, incomplete, or does not provide the necessary detail to initiate the investigation of the file, a communication will be sent to the whistleblower requesting additional information or documentation within a maximum period of five (5) working days from the receipt of said communication, unless the communication was made anonymously.

If no response is received from the whistleblower within this period, the file will be closed.

After this preliminary analysis, the System Manager will decide, within a period not exceeding five (5) working days from the date of entry of the information in the registry:

a. To dismiss the communication, in any of the following cases:

  • When the information transferred lacks all credibility, proves unfounded, is notoriously false, or has no evidentiary support whatsoever.
  • When the information provided is generic and does not refer to concrete, verifiable facts or data.
  • When the facts narrated in the communication made do not constitute an infringement of the legal system or Inox Torres Group, S.L.’s internal regulations, as set forth in section 3.a. of this Procedure.
  • When the communication is manifestly unfounded or there are, in the opinion of the System Manager, reasonable indications that the communicated information was obtained through the commission of a crime. In the latter case, in addition to the inadmissibility, a detailed report of the facts deemed to constitute a crime will be sent to the Public Prosecutor’s Office.
  • When the communication does not contain new and significant information about infringements compared to a previous communication regarding which the corresponding procedures have concluded, unless new factual or legal circumstances arise that justify different follow-up. In these cases, the System Manager will notify the motivated resolution.
  • When, regarding the same reported facts and conduct, investigation actions that are already closed have been previously carried out.
  • When the facts and circumstances are being or have already been investigated by the judicial authority, the Public Prosecutor’s Office, or the judicial police.
  • When there is another justified circumstance assessed by the System Manager.

The inadmissibility will be communicated to the whistleblower within five (5) working days, unless the communication was anonymous or the whistleblower had waived receipt of communications from the System Manager, also proceeding with the deletion of the personal data collected in the record of the communication made.

b. To admit the communication for processing: The admission for processing will be communicated to the whistleblower, unless the communication was anonymous, or the whistleblower had waived receipt of communications from the System Manager.

c. To immediately forward the information to the Public Prosecutor’s Office when the reported facts could be prima facie constitutive of a crime, or to the European Public Prosecutor’s Office if the facts affect the financial interests of the European Union.

11.d. Exceptions

If the information transmitted through the internal information channel is related to both infringements of anti-money laundering and terrorist financing regulations, and insurance distribution regulations, the specific regulations on communication of infringements in these matters will apply, as established in Law 2/2023.

Consequently, the System Manager will inform the whistleblower of the means through which the corresponding communication should be made.

Without prejudice to its responsibility under the Purchase Order and/or Service Agreement, which shall not be limited by this clause, the Provider shall arrange the insurance policies described below and keep the same in effect at all times over the term of the Purchase Order or the Service Agreement:

  1. a) Sickness and workplace accident insurance for all employees assigned to the work.
  2. b) Property loss insurance covering all equipment used with a limit that is not less than the replacement value thereof.
  3. c) Civil liability insurance with minimum cover of two million euros (EUR 2,000,000) per claim.


This insurance policy shall include INOX TORRES GROUP as an additional insured party, but without affecting its third-party status.

12. INVESTIGATION

If the content of the communication made through the Information Channel indicates the commission of a legal breach or some irregularity, the investigation phase of the opened file regarding said communication will begin.

The investigation shall comprise all appropriate and relevant actions, and the carrying out of all necessary evidence, aimed at the proper clarification and determination of the reported facts, and the verification of their veracity and materialization, including the following:

  • Investigate the facts and gather the necessary evidence to support the investigation results.
  • Document the actions carried out.
  • Document the actions carried out.
  • Prepare the final report with the results of the investigation.

During this Investigation phase, the affected person will be given a hearing, unless it jeopardizes the ability to effectively investigate or collect evidence due to the risk of its destruction or alteration by said person, in which case this hearing may be delayed for a maximum of two months.

Likewise, a hearing will be granted to third parties who may act as witnesses, whose intervention will be strictly confidential.

If a communication received in the Information Channel is related to the scope of competence of the Harassment Action Committee, the Information System Manager will duly transfer it to said Committee for its complete processing and resolution, all in accordance with the “Protocol for the prevention and treatment of moral, sexual or gender-based harassment” established for these purposes.

This Committee will inform the System Manager of the closure of its procedures so that the latter can record the closure of the file in their register.

If at any time during the investigation, information is obtained about ongoing judicial or administrative proceedings for the same facts, the System Manager may decide to suspend the ongoing investigation and resume it if there are relevant aspects not decided in those areas.

Conflict of interest: In no case may a person participate, directly or indirectly, in the investigation (processing and inquiry) of a communication that affects them, being excluded from the management/investigation of the communication, and their access to any action related to it being blocked.

Likewise, persons hierarchically dependent on the affected person, or persons on whom the affected person hierarchically depends, may not participate either.

13. RESOLUTION

Upon completion of all actions carried out in the investigation phase of the file, a Report will be prepared, which, at a minimum, will contain the following:

a) A brief exposition of the reported facts, the registration date, and the internal code assigned for the identification of the communication.
b) The actions carried out to verify the veracity of the reported facts.
c) The conclusions reached in the investigation and the assessment of the proceedings and the evidence that supports them, also recording any recommendations deemed appropriate.

The System Manager, in accordance with the content of this report, shall adopt one of the following decisions:

Likewise, a hearing will be granted to third parties who may act as witnesses, whose intervention will be strictly confidential.

  1. Archiving of the file, which will be notified to the whistleblower and, where appropriate, to the affected person. The whistleblower shall have the protection provided in Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and fight against corruption, unless, as a result of the actions carried out in the investigation phase, it is concluded that the communication, in view of the information gathered, should have been dismissed due to the concurrence of any of the causes provided for in section 11.3 of this Procedure.
  2. Referral to the Public Prosecutor’s Office if, despite not initially detecting evidence that the reported facts could constitute a crime, this becomes apparent during the course of the investigation. If the crime affects the financial interests of the European Union, it will be referred to the European Public Prosecutor’s Office.
  3. Transfer to the Management of Inox Torres Group, S.L., for the application of corrective and/or, where appropriate, disciplinary measures that may correspond, if from the actions carried out it is concluded that a member of the Inox Torres Group, S.L. has carried out irregular or illicit conduct, breaching internal or external mandatory regulations.


If the involvement in the reported and finally proven facts concerns a Business Partner, supplier of goods, services and/or supplies, the System Manager shall transfer the matter to the Department or Area of Inox Torres Group, S.L. that carried out the contracting or that is responsible for the fulfillment of its commitments, for the adoption of the measures deemed appropriate.

When the content of the communication or its investigation reveals the possible existence of relevant criminal liabilities that may affect Inox Torres Group, S.L., the System Manager will immediately inform the corresponding Board of Directors.

In the event that a communication is found to have been made in breach of contractual good faith, by providing false or distorted information about facts and/or data by a member of Inox Torres Group, S.L., this fact will be brought to the attention of the person responsible for the Management of Inox Torres Group, S.L., so that, where appropriate, the relevant disciplinary measures may be adopted.

The period for processing the file, completing the actions, and responding to the whistleblower, if applicable, may not exceed three months from the date of registration of the information, except for cases of special complexity that require an extension of the indicated period, which may be extended for a maximum of an additional three months.

Whatever the decision, it will be communicated to the whistleblower, unless they have waived it or the communication is anonymous.

14. REPORT ON THE INTERNAL INFORMATION CHANNEL

Periodically, and at least once a year, the System Manager shall inform the Board of Directors of Inox Torres Group, S.L., about the number of communications submitted, processed, and archived, their typology, as well as the need to adopt additional or complementary measures, in order to improve, if applicable, the management of the procedure.

This information will be analyzed and evaluated with the aim of improving measures aimed at preventing any non-compliance with applicable regulations, as well as mitigating the risk that crimes and infringements included in the internal model for the Prevention of Criminal Risks that could be committed by means or under the coverage of Inox Torres Group, S.L., may occur.

15. DISSEMINATION AND TRAINING ON THE INTERNAL INFORMATION CHANNEL

In order for the Internal Information System and the Information Channel to be effective, their existence will be made known to all personnel of Inox Torres Group, S.L. through an internal communication indicating how to access it and the procedural steps.

This information must necessarily include the following aspects:

  • Use of the Internal Information Channel.
  • General principles of the communication management procedure.
  • Confidentiality of received communications.
  • Protection of the whistleblower, making it known that the company will guarantee that no type of retaliation will be taken against persons who report the commission of irregularities, with the sole exception of those cases in which the bad faith of the whistleblower is proven, in which case the legally corresponding sanctioning measures may be adopted.
  • Processing of personal data within the framework of the Internal Information System.

16. PROCEDURE UPDATE AND VALIDITY

This Procedure must be reviewed, and if necessary updated, at least once a year, and when necessary due to material changes in its content, with a record kept of each update process, its reasons, and the changes made.

The responsibility for such review and update shall fall on the System Manager, who shall send the new updated version to the management or Compliance department of Inox Torres Group, S.L., for their analysis and evaluation.

The aforementioned Committee will evaluate whether its content remains adequate and will submit it for approval to the Board of Directors of the parent entity.

The evolution contemplated in this section is shown at the beginning of the document in ‘Version Control’, recording each new version with the update date and a summary of the modifications made.

This Procedure shall enter into force on the day following its approval by the Board of Directors of the parent entity Inox Torres Group, S.L.