Whistleblowing Channel / Internal Information System

1. Purpose

This whistleblowing channel enables reporting of breaches or misconduct in accordance with Law 2/2023.

2. Scope

This channel may be used by:

• Employees and former employees
• Candidates
• Suppliers, clients and collaborators
• Any person with a professional relationship with the organisation

3. Reportable matters

• Criminal or administrative offences
• Breaches of internal rules
• Fraud or corruption
• Harassment
• Health and safety risks

Not intended for complaints or service issues.

4. Guarantees

• Confidentiality.
• Anonymous reporting.
• Protection against retaliation.
• Independent handling.

5. Operation

Submit reports via:

Process:

• Acknowledgement within 7 days.
• Investigation.
• Response within 3 months.

6. System manager

Managed by an independent designated person.

7. Data protection

Data processed for managing reports under Law 2/2023.

Contact: info@escubedo.com.

8. External channels

Reports may also be submitted to competent authorities.