What is a Claims Channel?

Based on Giropes SL's commitment to compliance with both the external regulations that apply to it and its own policies and Code of Conduct or Ethics, Giropes SL informs employees and persons linked to our Business Group that they can report any breach of this set of regulations, if they know or suspect on reasonable grounds that any member of the organisation is carrying out acts contrary to the law, its Code of Conduct or any of its policies.

At Giropes SL we are committed to transparency and ethical behaviour, which is why we provide our employees and people linked to our Business Group with a valuable means of communication, such as the Claims Channel, in which the confidentiality of the information and of the claimer is guaranteed and we sincerely thank all our employees and people linked to us for using it in order to strengthen the company and its sustainability.

CLAIMER RIGHTS

1. Right to receive prior information.

Before lodging a complaint, the complainant must have access to easily understandable information about the whole process. For this reason, Giropes SL is committed to duly informing the complainant of all the steps involved in the complaint process.

1. Right to the restrictive use of information.

The information provided by the complainant may not be used for purposes other than those of the investigation.

III. Right to confidentiality.

Giropes SL guarantees confidentiality in the receipt and management of communications made through this Claim Channel. The complainant is informed that, both in the complaint form and during the investigation, only the data strictly necessary to process the complaint is requested. Furthermore, only authorized personnel will have access to this data.

IV. Right to Receive an "Acknowledgment of Receipt"

Giropes SL will inform the complainant of the receipt of the communication within a maximum period of 7 days.

V. Right to Receive Reasonable Information

Giropes SL will inform the complainant of the status of the complaint within a maximum period of three months from the dispatch of the acknowledgment of receipt.

VI. Right to Transparent Investigation by an Impartial Interlocutor

Complaints or inquiries received will be treated with maximum transparency and impartiality by those responsible for the investigation, who possess sufficient and adequate preparation to address the complainant's doubts or process the filed complaint.

VII. Rights Derived from Data Protection

Giropes SL ensures that all data provided by the complainant through the reporting channel will be processed in accordance with current data protection regulations, without prejudice to the rights of the complainants, including but not limited to, access, rectification, opposition, and deletion.

VIII. Right to Non-Retaliation

Giropes SL acknowledges the prohibition of retaliation against the complainant; therefore, the complainant cannot be held accountable for the information contained in the complaint unless acting in bad faith.

OBLIGATIONS AND WARNINGS

Giropes SL expects employees and individuals associated with the Giropes SL Business Group to adhere to the following obligations and warnings:

I.Truthfulness

A complaint will be considered truthful when there are reasonable grounds to believe that the reported facts are true, in light of the circumstances and available information at the time of the complaint. Only those who have acted in good faith will be protected against retaliation, even if the communicated information is inaccurate or exceeds their competencies. Good faith maintains claimer protection. Complaints made knowingly false or with reckless disregard for the truth will be penalized following Giropes SL's disciplinary system.

II. Good Faith Throughout the Process

Maintaining confidentiality regarding the investigation and the data requested by the responsible interlocutor of said investigation.

III. Legality in Obtaining Supporting Evidence for the Complaint

CAUSES OF COMPLAINT INADMISSIBILITY

Giropes SL reserves the right to reject the complaint/inquiry under the following circumstances:

I. When the facts are not credible, there are no indications to substantiate them, or they relate to reasons other than those stated above (e.g., those related to human resources management, permissions, promotions, etc.).

II. When the content of the complaint does not involve a breach of the principles established in the Code of Conduct, in which case it will be referred to the competent department.

III. Manifestly unfounded and unsupported facts.

IV. When the facts are described in a generic or imprecise manner unless the deficiencies are corrected.

V. When they concern matters excluded by the company from those that can be reported through the reporting channel and should be communicated directly to the Compliance Body.

VI. When the content is irrelevant, the information insufficient, or the informant lacks credibility entirely.

VII. When it refers to the same facts as another previous complaint that has been investigated and archived if the new complaint does not provide new evidence.

FAQs

• Who can file a complaint?

Any person who has a working relationship with the company.

• Can I feel safe from possible retaliation for filing a complaint? Is the accused informed of the complaint being filed?

In accordance with the European regulations governing the procedure adopted by Giropes SL, this Claims Channel is confidential, and the company guarantees that no retaliation will be taken against complainants for possible complaints. Likewise, complainants have the right to protection whenever there is a reasonable presumption of truthfulness in the reported facts. Also, Giropes SL may provide support measures (advice, assistance from authorities and organization against retaliation, or even legal assistance) if necessary. On the other hand, the accused will not be informed about the procedure until the investigation process is concluded; then the accused will be informed about the procedure.

• What is the process for processing a complaint? How long will it take to resolve the procedure?

Once the corresponding complaint is filed through the designated form, you will receive an acknowledgment of receipt email within a maximum period of seven days. Subsequently, the result of the internal investigation will be communicated to you within a maximum period of three months.

• If I lack evidence, can I still file a complaint?

Yes, although it is desirable for complaints to be accompanied by evidence to facilitate the investigation and prevent the complaint from being archived. The complaint form includes the possibility of uploading supplementary documentation, although it is not a mandatory requirement.

• What happens if a complaint is false?

If suspicions are incorrect or unfounded and the complaint has been filed in good faith, it will simply be archived after informing the complainant. Unlike the previous case, if the complaint is false and is due to bad faith on the part of the complainant, we could be facing a crime of slander or libel provided for in our Penal Code (Articles 205 and following), without prejudice to the consequences that may arise in accordance with Giropes SL's Code of Ethics or Conduct.

• To what extent are the data contained in the complaint protected?

In addition to the confidentiality guarantee mentioned above, all personal data contained in the complaint will be treated in accordance with the provisions of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights. They will be used solely by employees and individuals associated with the company to ensure the successful conclusion of the investigation, with their use and acquisition being proportional to the corresponding purpose.