INTRODUCTION TO THE IDEA ORO Y GEMA WHISTLEBLOWING CHANNEL

IDEA ORO Y GEMA, SL is an organization committed to complying with current legislation, as well as to ethics and transparency in all its operations. For this reason, it actively works to prevent and detect any irregular conduct that could damage its image and reputation.

In this regard, IDEA ORO Y GEMA, SL complies with the provisions of the European General Data Protection Regulation of April 2016 (GDPR), Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSICE) and current legislation Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption, which requires companies to have control mechanisms that allow them to prevent, detect and react to the risk of committing a crime.

Therefore, IDEA ORO Y GEMA, SL has implemented a «"Whistleblowing Channel"», a fundamental tool for all staff and network of collaborators acting on its behalf to report potential risks and breaches.

This Policy describes all matters related to the operation of the Whistleblowing Channel of IDEA ORO Y GEMA, SL: who can file a complaint, against whom, in what situations, and, above all, what steps will be followed when a complaint is received. All of this is subject to the strictest confidentiality.

The Whistleblowing Channel at IDEA ORO Y GEMA, SL is a valuable and useful tool for preserving and protecting the company's image and reputation. The cooperation of all employees is expected in detecting any potential misconduct and acting accordingly, always adhering to the ethical and compliance values that characterize IDEA ORO Y GEMA, SL.

WHO SHOULD REPORT THROUGH THE REPORTING CHANNEL?

All employees, management, clients, partners, and regular suppliers of IDEA ORO Y GEMA, SL, hereinafter referred to as “Stakeholders,” are encouraged to use the Whistleblowing Channel if they become aware of any irregularity that falls within its scope. It is important to emphasize that the use of this channel is fully guaranteed confidentiality and without fear of retaliation, such as dismissal or other similar measures. All reports received will be treated with the utmost seriousness and responsibility.

WHO CAN BE REPORTED THROUGH THE REPORTING CHANNEL?

Any person, internal or external to the company, considered an interested party, who has carried out any irregularity or conduct detailed in this document may be subject to a complaint through the Whistleblowing Channel.

WHAT CONDUCT IS SUBJECT TO REPORTING?

Those behaviors that are contrary to the principles and standards of conduct that violate ethics as a principle practiced at IDEA ORO Y GEMA, SL, and that any reported incidents, such as violations or irregularities, are declared through this channel. This fosters a culture of ethics and compliance within the company, where all stakeholders can report potential breaches without fear of retaliation and with the assurance that their report will be treated with the utmost confidentiality.

In addition, there are also those classified as crimes in the Penal Code and other special laws, which may generate criminal liability.

The following are details of these incidents that can be reported through the reporting channel:

• Sexual harassment or harassment based on sex in the workplace.
• Any discriminatory conduct based on race, religion, sexual orientation, ideology, disability, or appearance.
• Degrading treatment, humiliation, or behavior that can objectively be considered workplace harassment (mobbing).
• Serious or very serious criminal or administrative offenses.
• Non-compliance with the Code of Conduct, internal policies, protocols or regulations defined by the organization for this purpose.
• Fraud and corruption.
• Tax fraud, scams, bribery, embezzlement, money laundering, or any type of corruption.
• Violations of Personal Data Protection and Information Security.
• The manipulation, falsification or publication of confidential data.
• Violation of the principle of confidentiality.
• Misuse of classified information or disclosure of secrets.
• Crimes relating to intellectual and industrial property.
• Illegal conduct and actions related to work performance.
• Inadequate or lucrative management of business resources.
• Robberies, thefts or the taking of personal or work-related property belonging to others.
• Crimes against personal privacy.
• Irregularities related to occupational safety and health.
• Deceptive advertising.
• Unfair competition.
• Irregularities related to environmental protection.
• Other: if there is any complaint that does not fit into any of these categories.

HOW SHOULD IT BE REPORTED?

All complaints must be submitted in writing through any of these channels.

1. 1. Electronically: Through the secure link enabled on the website for the reporting channel: belen@belenbajo.com
   2. Via postal mail addressed to the attention of the Head of the Whistleblowing Channel of IDEA ORO Y GEMA, SL, Belén Bajo Cacho, at the address postal 13 San Bernardo Street, 2 center, 28015 Madrid, Spain.
   3. In-person/verbal: At the informant's request, an in-person meeting can be arranged within a maximum of 7 business days by sending an email to  belen@belenbajo.com. In this case, the conversation will be recorded (with prior consent) by means of voice recording or agreed full transcription.

In any case, it will be mandatory in cases 1.1 and 1.2 to complete the complaint form, which will be available for download from the website.

Any complaint that is not made through the means indicated above will not be received or admitted for processing and will be destroyed.

Complainants must identify themselves when filing a complaint; anonymous complaints will not be accepted. However, the confidentiality of the complainant's identity will be guaranteed throughout the entire process, in compliance with the privacy requirements established by the Spanish Organic Law on Data Protection and the Spanish Data Protection Agency.

PROTECTION AND CONFIDENTIALITY OF THE WHISTLEBLOWER

At IDEA ORO Y GEMA, SL, the Whistleblowing Channel is managed by Belén Bajo Cacho.

All those who file a complaint in good faith are protected against any kind of retaliation., Discrimination or penalties resulting from the complaint filed. In the event of any type of retaliation against a whistleblower acting in good faith, such as unfair dismissal or a change in responsibilities, the Management of IDEA ORO Y GEMA, SL will take disciplinary action.

It is important to note that the prohibition of retaliation will not prevent the adoption of disciplinary measures if it is determined that the complaint is false and that the complainant acted in bad faith.

At IDEA ORO Y GEMA, SL, the absolute confidentiality of the whistleblower's identity is guaranteed as one of the fundamental principles of its Whistleblowing Channel. To ensure this confidentiality, it is established that the accused's access to personal data will not include the whistleblower's identity, except in the case of a court order.

This approach allows whistleblowers to be confident that their identity will be protected. The Whistleblower Channel Manager is obligated to maintain professional secrecy and the confidentiality of the whistleblower's identity. If an external advisor or a member of IDEA ORO Y GEMA, SL is involved in the investigation, they will also be subject to the same obligation of confidentiality and professional secrecy to protect the whistleblower's identity.

PROCEDURE FOR HANDLING COMPLAINTS

1. COMPLAINT RECEIPT PHASE AND ACKNOWLEDGMENT OF RECEIPT

All complaints will be received by the Head of the Complaints Channel at IDEA ORO Y GEMA, SL, who will conduct a preliminary analysis of the reported incidents and their suitability for the designated form. Once received, the complaint will be registered, assigned a unique identification code, and filed in the Complaints Information System database.

Meeting the indicated deadlines of maximum of 3 working days to activate the procedure for processing the complaint and maximum of 7 calendar days counting from receipt, unless the informant has expressly waived this requirement or the communication is anonymous without a means of contact, to send the acknowledgment of receipt of the complaint.

2. PHASE FOR ADMISSIBILITY ANALYSIS AND/OR MEDIATION

A decision will then be made as to whether to initiate the corresponding investigation or to accept the complaint, as provided for in the company's Complaints Policy when the reported facts fall within the scope of the complaint channel and present minimal indications of truth.

If the complaint meets the required formal requirements and the reported facts fall within the objective scope of the Complaints Channel, it will be processed. admission The process will begin and the investigation phase will commence.

Furthermore, any person who is the subject of a complaint that has been accepted for processing will be informed of aspects such as the receipt of the complaint, the fact attributed to them, or third parties who may be recipients of the complaint, if any, and how to exercise their rights of access, rectification, cancellation and opposition, in accordance with the provisions of the data protection regulations, among others.

It will be carried out inadmissibility The complaint will be processed if it does not meet the formal requirements established in the Complaints Policy, if it is determined that the reported facts do not fall within the objective scope of the Complaints Channel, if they lack any truthfulness or are notoriously unfounded, or if the information is brief or vague and no documentation or clarification is provided after being requested.

It is important to note that inadmissibility does not imply that the reported facts are false or unimportant, simply that they do not meet the necessary requirements to be investigated through this Channel.

The Head of the Complaints Channel will inform the complainant that the complaint has been rejected and, if possible, will offer alternative channels for their communication.

During this phase, and considering the seriousness of the complaint, before proceeding to a criminal investigation, a process can be initiated to mediation if the parties voluntarily agreed.

When the complaint requires it, since the facts could be indicative and/or constitute a crime outside the scope of the reporting channel, the Head of the Reporting Channel must forward the information to the competent authority or the Public Prosecutor's Office.

Within the deadline 10 to 15 business days Upon receipt, the person in charge of the Whistleblowing Channel will determine whether the complaint is admissible or inadmissible, in order to decide whether or not to continue with the investigation. Likewise, the results of any mediation will be recorded within this same timeframe.

The agreed admissibility decision will be reasoned and notified to the informant in the same term.

3. RESEARCH PHASE

Once a complaint has been accepted, the necessary investigations will be carried out to verify the authenticity of the reported events. IDEA ORO Y GEMA, SL staff will be required to cooperate with the investigations when requested. If the reported events are complex, the assistance of an external expert may be requested outside the reporting channel for advice and support in the investigation.

The Head of the Complaints Channel will carry out the necessary procedures to verify the veracity of the facts.

Hearing for the accused: The person affected by the information will be informed of the alleged facts and will be granted a hearing to argue and provide the evidence they consider relevant.

The investigative process will respect the principles of due process, confidentiality, and proportionality. The procedure must be as swift and efficient as possible and, in all cases, protect the privacy and dignity of the individuals involved. All internal investigations will be conducted with tact and due respect for the individuals involved.

The completion of the investigation, for cases or complaints of harassment, which includes interviews with the parties, collection of evidence, taking statements from witnesses, allegations, etc., will be 10 to 15 business days the investigation began.

For reports or complaints other than those related to harassment, these time limits may be extended up to a maximum of three months from the date of acknowledgment of receipt of the notification.

4. CASE RESOLUTION PHASE

Once the investigation phase is complete, several actions will be carried out in this phase of resolving the complaint.

First, the Head of the Complaints Channel will prepare a report that will include the results of the investigation and one of two possible resolutions: to file the complaint or to formulate a proposed resolution.

If the reported facts are not duly substantiated or do not constitute an infringement within the scope of the Whistleblowing Channel, the complaint and the proceedings will be dismissed. However, if the reported facts are deemed proven and constitute an infringement within the scope of the Whistleblowing Channel, a reasoned decision will be issued specifying the legal measures to be taken.

At any stage of the proceedings, you may seek legal advice from a subcontracted external expert to assist you in drafting the facts, classifying them, or taking appropriate disciplinary action in each case. If a conflict of interest arises, the company's management will make the final decision jointly.

The maximum time limit for issuing a decision on the notification from the receipt of the complaint, in cases of sexual harassment, harassment based on sex and work-related harassment, shall not exceed 30 calendar days (extendable with justification to a maximum of 45 days in cases of extreme complexity.

The maximum time limit for responding to investigations other than those related to sexual harassment or harassment based on sex and employment, It will not exceed 3 months Starting from the date of acknowledgment of receipt or from the expiry of the 7-day period following receipt of the information. This period may be extended up to a maximum of 3 additional months in cases of particular complexity.

5. EXECUTION PHASE OF THE RELEVANT SANCTIONS

It will be the responsibility of the person or persons authorized by the Management and with sufficient power to apply the sanctions or disciplinary measures agreed upon in each case.

6. CASE FOLLOW-UP PHASE

The case file will be monitored at intervals determined by the conclusions set forth in the proposed resolution, with a maximum timeframe of one year, to verify the implementation of the proposed measures. This monitoring will generate a new report resolving the case file, either for closure or to adjust the measures.