1. PURPOSE AND SCOPE

The main objective of the Internal Information System Policy, hereinafter “the System” or “IIS”, is to establish the commitment of MANUBENS GROUP to comply with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption – hereinafter Law 2/2023 -, as well as to establish the fundamental principles of the regulation of the IIS so that all interested parties can report possible irregular conduct or acts contrary to the Law.

The scope of this Policy covers the following entities, all of which are referred to as the “MANUBENS GROUP”:

• MANUBENS Y ASOCIADOS S.L.P.
• MANUBENS MADRID ABOGADOS S.L.P.
• MANUBENS MÁLAGA ABOGADOS S.L.P.

This policy is applicable to all interested parties of the MANUBENS GROUP, being, internally, all employees, collaborators, partners and administrators of the company and, externally, any person who has had any kind of link or relationship with the company, including the relatives of the employees of the MANUBENS GROUP.

2. APPLICABLE PRINCIPLES

This Policy is governed by the following principles:

a) Completeness, integrity and confidentiality. Communications received within the framework of the SII shall be processed in accordance with the provisions of Law 2/2023 and the SII manual itself. The completeness, integrity and confidentiality of the information, the prohibition of unauthorised access, the durable storage of the information, the full protection of the informant and respect for good faith shall be guaranteed.

b) Independence and autonomy of the System Manager. The System Manager shall not be subject to any hierarchy in the performance of the functions inherent to this position, nor may he/she receive instructions in this respect from any person.

c) Objectivity and impartiality in the examination of the information received. Independence and impartiality shall be maintained at all times, respecting at all times the legislation in force. Conflicts of interest shall be avoided, the presumption of innocence shall be respected and the right to defence shall be guaranteed.

d) Transparency and accessibility. Access to the SII and to the information channel tool implemented in the company shall be guaranteed. The information shall be provided in a clear and simple manner, easily accessible and with sufficient publicity about its use and principles.

e) Absence of reprisals, protection of the informant and other parties involved. The commitment to whistleblower protection will be ensured and respected provided that the communications are made in good faith and in accordance with the provisions of the company’s SII and Law 2/2023 and other legislation in force.

f) Confidentiality and anonymity of the informant. The SII shall ensure anonymity and/or confidentiality.

3. LEADERSHIP AND COMMITMENT

Society leaders take on the role of enforcing and ensuring that the Internal Reporting System functions successfully and fostering an appropriate culture of compliance in society.

4. RESPONSIBLE FOR THE SYSTEM

The System Manager is responsible for the operation of the Internal Information System. His/her functions include the following:

• Receive the communications made in the information channel set up for this purpose.
• Initiate, if necessary, the investigation procedure.
• Appoint, if necessary, external third party experts, experts or professionals to intervene in the investigation process.
• Ensure that the information channel is properly enabled.
• Publicise the information channel so that all internal and external members are aware of it.
• Report annually the communication register and the information channel report to the governing body.

5. PUBLIC CHANNEL

MANUBENS GROUP has set up a public channel of a confidential and/or anonymous nature, with the aim of promoting compliance and complying with the requirements of Law 2/2023, on the protection of informants.

The purpose of this channel is to enable all internal and external members, as well as any person who has a contractual or extra-contractual relationship with MANUBENS GROUP, to communicate facts or conducts that may be of an illicit nature, as well as the communication of any fact, conduct or suspicion that may be considered contrary to the objectives and rules established in the Internal Information System.

Access to the channel is via the following link: https://www.ovetauki.com/index.php?route=login/complaint&c_key=zWvfmosFvqMNapLFrzVUsXABfozhDVPenCDj

The System’s own manual, as well as its policy and protocol of use, are published on the corporate website.

6. NON-COMPLIANCE INTERNAL REPORTING SYSTEM

The procedures, principles and rules established in this Policy are mandatory for the MANUBENS GROUP, thus complying with Law 2/2023.

Failure to comply with this policy may result in sanctions for both the organisation and the individuals involved. Sanctions may include, but are not limited to, disciplinary action, dismissal, fines and/or the initiation of civil, administrative or criminal proceedings against the individuals involved.

Any actual or imminent action that involves a violation of this Policy must be communicated through the information channel implemented in MANUBENS GROUP, without tolerating or exercising any retaliation against the person who refuses to practice corrupt actions.

The consequences of non-compliance with the Internal Reporting System shall be governed in accordance with the provisions of the Collective Bargaining Agreement and the Workers’ Statute, as well as other applicable legislation in force.

7. MONITORING, EVALUATION AND REVIEW

The System Manager shall be responsible for monitoring the implementation, development and compliance of the Internal Information System; he/she shall assess, when deemed appropriate, the compliance and effectiveness of the IIS and, in any case, when relevant breaches of the System become apparent or when significant changes occur in the company.

This Policy shall be reviewed by the System Manager every three years, and the Manager shall propose to the Administrative Body the modifications and updates that contribute to its development and continuous improvement, taking into account, in any case, the suggestions and proposals made by the professionals of the MANUBENS GROUP.

8. APPROVAL

The present Internal Information System Policy has been approved by the MANUBENS GROUP’s Board of Directors by Act dated 30 November 2023.