INTRODUCTION AND OBJECTIVE

Alcaliber, S.A. and Alcaliber Investigación, Desarrollo e Innovación, S.L. (hereinafter, Alcaliber or the Company) aims to implement the highest standards in the area of ethics and wishes to maintain high standards in terms of Regulatory Compliance. For this reason, it has set up an independent whistle-blowing channel to be used to report potential practices or behaviour contrary to the Internal Code of Conduct and the regulations in force, constituting one of the guarantees of the company's reputation.

This whistle-blowing channel procedure allows for the anonymous reporting of a possible breach of regulations, allowing for the rapid implementation of corrective actions, as well as, where appropriate, avoiding possible subsequent reprisals. In any case, the anonymity of the whistleblower is always guaranteed to the person being reported.

On the other hand, the identity of the whistleblower and the persons involved in the complaint, as well as all information gathered by the person in charge of handling the complaint, must be treated confidentially.

SCOPE

The complaints channel is based on three fundamental principles that must be respected at all times and without exception by all persons subject to it:

- Prioritise the interests of Alcaliber's clients.

- Respect legal, regulatory, professional and ethical obligations, as well as internal policies and procedures.

- Not to damage Alcaliber's reputation.

All persons subject to Alcaliber may be whistle-blowers or reporters through this internal whistle-blowing channel. The complaint may only be made for causes that may affect the maintenance or development of the contractual relationship that links the person being reported to the company.

All complaints must include the following information:

- Details of the complainant (although the complaint may be made anonymously and under no circumstances will they be communicated to the person complained of if the details have been provided).

- Details of the person being reported.

- The facts reported, with an indication of the date or dates on which they occurred.

- Provision of evidence of plausibility, documents or evidence, if available.

- Date of the complaint.

The information will only be accessible by the Alcaliber Regulatory Compliance Committee (CCN), as well as those persons or subcontracted personnel necessary to carry out the relevant investigations.

With regard to the reception and treatment of complaints, once they reach the Regulatory Compliance Unit, after a preliminary analysis, it will proceed to adopt one of the following decisions:

- To archive the procedure, registering the complaint together with the corresponding reasoned decision to archive it. The decision to close the case must be approved by the NCC.

- Agree on the continuation of the procedure and the initiation of the internal investigation.

Upon completion of the investigation, the Regulatory Compliance Unit shall issue an investigation report in PDF format regarding the complaint received. This report shall include a summary of the facts complained of, a description of the investigation carried out (detailing the actions taken and the analysis performed), the results of the investigation and the conclusion reached.

In the event that the complaint is not admitted for processing, either because it does not comply with the minimum contents, or because it is considered that the facts reported do not correspond to any breach or transgression of the Internal Code of Conduct, or do not constitute a criminal offence, it shall be filed, informing the sender of its filing and indicating the reasons why it was not admitted for processing, and it shall also be brought to the attention of the CCN.

The data subject shall be informed as soon as possible of the facts reported, the recipients of the information and his or her data protection rights. Where informing the data subject that he/she has been the subject of a complaint jeopardises Alcaliber's ability to investigate or gather evidence effectively, due to the risk of destruction or alteration of evidence by the data subject, this may be delayed up to a maximum of three months.

The data will be deleted within a maximum period of one year after the end of the investigations if the facts have not been proven. Otherwise, they will be kept for as long as they are necessary for Alcaliber's defence in court.

On the other hand, the Regulatory Compliance Unit shall keep a record of all complaints and queries received, provided that the complainant has been properly identified. This register must comply with the requirements of current legislation on the protection of personal data.

Finally, the information registered through the Whistleblowing Channel will be analysed and assessed by the Regulatory Compliance Unit, with the aim of improving the measures aimed at preventing and discovering crimes and breaches of Alcaliber's Criminal Risk Detection and Prevention Model that may be committed within the Company.