WHISTLEBLOW CHANNEL

The Ethics Channel or Reporting Channel is the channel provided to report incidents and irregularities related to non-compliance with the company’s Code of Ethics , regulated by Law 2/2023 , of February 20, on the protection of persons who report regulatory violations and the fight against corruption.

It is a medium open to workers, suppliers, clients and any person or entity related to the organization. 

At Teléfono Permanente S.L., we position ourselves as a company committed to economic and social progress. We maintain an ethical commitment based on values ​​that are part of our culture.

Our code of conduct reflects the core values ​​of Teléfono Permanente. All departments within it will adopt decisions and conduct behaviors aligned with these values. Our actions are based on the values ​​of Integrity, Excellence, Trust, Sustainability, and Profitability, which guarantee:

• Generating value for all employees and customers
• Sustainable and profitable company growth

Teléfono Permanente Ethics Channel is available to anyone who wishes to report a potential ethical breach within our organization, including board members, managers, employees, and other stakeholders.

The complaint can be filed anonymously through the complaint mailbox, under the guarantee of compliance with the non-retaliation policy, as the Teléfono Permanente ensures the confidentiality and security of the internal complaint process.

The increase in legal obligations, complexity, and variability of laws affecting businesses has multiplied in recent years. The need to comply with these legal obligations in order to assume the ethical commitments demanded by society has contributed to the creation of management systems aimed at preventing, detecting, and responding to risks arising from noncompliance with various regulations, such as ethical standards.

Therefore, at Teléfono Permanente S.L., we have created this ETHICAL CODE as a declaration of our unwavering commitment to integrity, transparency, and responsibility in every aspect of our operations.

We are committed to acting with integrity, transparency, and responsibility in all our business activities, doing everything possible to maintain the trust of our customers, employees, suppliers, and society at large.

This CODE aims, among other things, to provide all people who are part of our ecosystem with confidence in our services and in the entire team that makes up the company.

This document contains guidelines for understanding the basic principles of ethical management and relationships with colleagues, collaborators, managers, suppliers, clients, and anyone with a direct or indirect interest in the company’s activities.

This document also serves as a guide, along with established work standards and procedures, for:

• Provide guidance to all employees regarding their daily professional performance, the resources used, and the business environment in which they perform their duties.
• Always ensure proper conduct and that no violations occur within the company.

At Teléfono Permanente, we comply with all applicable regulations, which is essential to maintaining the trust of our stakeholders and preserving the ethical values ​​and good reputation that characterize us.

Therefore, we are committed to ensuring that our operations are always transparent, fair, and free from undue influence. This also includes preventing corruption and combating fraud in all its forms.

The Ethical Code will need to be updated regularly to adapt to the changing realities of the business environment and the rapid pace of legal changes. It may be amended at any time, when deemed appropriate, to meet the changing needs of the moment.

CONSULT THE ETHICAL CODE OF TELÉFONO PERMANENTE SL

The following constitute facts that may be the subject of reporting through the channel: actions or omissions that may constitute violations of European Union Law, provided that they fall within the scope of the Union acts listed in the Annex to Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption, as well as Directive (EU) 2019/1937, violations of Spanish criminal, administrative and labor law, violations of the internal regulations of TELÉFONO PERMANENTE SL, (including Policies, Bylaws, Regulations on Functions and Healthcare Practice, as well as the internal protocol of conduct in the field of intra-group related-party transactions, among others), as well as any other violation of the legal system that directly affects or undermines the general interest.
Any risk of regulatory non-compliance that the company incurs in its activities and that is considered insufficiently covered, as well as any recommendations for improving the entity’s regulatory compliance system, may also be reported through the reporting channel.

The whistleblowing channel cannot be used as a suggestion box for suggestions unrelated to improving THE COMPANY’s level of regulatory compliance, and its use for this purpose will not be tolerated. Likewise, the whistleblowing channel should not be used for complaints unrelated to regulatory compliance within the company. The following are some examples:

• Complaints or claims related to the working or contractual conditions applicable to each worker or group of workers, unless they may involve the commission of unethical or illegal conduct (for example: employing people without an employment contract).
• Complaints or claims made by policyholders regarding the insurance contract must be filed with the Entity’s Customer Service Department.
• Mere rumors, gossip, comments or value judgments that are not in any way related to unethical or illegal conduct (example: personal opinions of employees, clients, suppliers, etc.)

PLEASE REMEMBER that complaints are admissible in a work or professional context, as well as serious or very serious criminal or administrative violations.

If the complaint is accepted, the following will be done:

• Acknowledge receipt within 7 days and response to the complaint no later than 3 months.
• Classification of the complaint.
• Analysis of causes and investigation.
• Solution provided.
• Measures taken.
• Disciplinary regime.
• Resolution and report.

PLEASE REMEMBER that complaints are admissible in a work or professional context, as well as serious or very serious criminal or administrative violations.

If the complaint is NOT admitted, the following will be done:

• The complainant is informed that the complaint has not been admitted.
• REASONED communication as to why the complaint is not admitted.
• Archive.

THE COMPANY will provide due protection to all persons who make a report in good faith in accordance with the rules contained in this Manual, and always in compliance with Law 2/2023, of February 20, regulating the protection of persons who report regulatory breaches and the fight against corruption and relating to the protection of persons who report breaches of European Union law.

Specifically:
a) No person who reports in good faith may be dismissed, disciplined, or suffer any other type of detriment to their employment relationship or promotion as a result of reporting such an incident.
b) Reporting in good faith does not constitute a breach of the principle of good faith in employment relationships or the disclosure of a company secret.
c) If negative employment consequences have been adopted against the whistleblower in retaliation for making a report in good faith, THE COMPANY will revoke such negative measures as soon as possible and restore the whistleblower’s rights, as well as sanction, as appropriate, those who adopted or instigated the retaliation.
d) THE COMPANY will investigate for disciplinary purposes any type of threat or situation of discrimination, harassment, or other negative measures, whether formal or informal, suffered by the whistleblower or persons close to them. When these acts could constitute a crime, THE COMPANY may report them to the competent authorities.

The COMPANY’s whistleblowing channel must be used responsibly. Reporting false information or information that does not comply with the principles of using this channel could constitute a breach of the good faith that must govern labor relations and could result in disciplinary sanctions and other legal consequences.

The COMPANY will not tolerate the indiscriminate use of the reporting channel for purposes other than those established by Directive (EU) 2019/1937 and Law 2/2023, of February 20, applicable, and will act immediately against those whistleblowers who, in bad faith, violate the provisions contained in the Internal Information Management Procedure of the COMPANY’s reporting channel. 

The protection of the whistleblower necessarily requires the presence of good faith, understood as an honest awareness of the occurrence or possibility of significant harmful events. This good faith reflects civic behavior and opposes other actions that should be excluded from protection, such as the transmission of false or distorted information, as well as information obtained illegally.

Article 63. Infractions 

1. The following intentional actions or omissions  will be considered very serious violations:

            … 

     f) Communicating or publicly revealing information that is known to be false

Article 65. Sanctions 

1 The commission of infractions provided for in this law will entail the imposition of the following fines:

a) If natural persons are responsible for the infringements, they shall be fined between €1,001 and €10,000 for minor infringements; between €10,001 and €30,000 for serious infringements; and between €30,001 and €300,000 for very serious infringements . 

b) If they are legal entities, they will be fined up to 100,000 euros for minor infringements, between 100,001 and 600,000 euros for serious infringements, and between 600,001 and 1,000,000 euros for very serious infringements. 

Submitting false information can have serious consequences for the informant, leading, in some cases, to a prison sentence of six months to two years. Therefore, it is important to be careful when submitting information through the Reporting Channel. 

If you are unsure of the veracity of the information you have, it is best not to provide it.

The personal data provided during the reporting process will be treated with the strictest confidentiality by TELEFONO PERMANENTE, SL , as Data Controller , in accordance with Regulation (EU) 2016/679 of April 27, 2016 (GDPR) and Organic Law 3/2018, of December 5 (LOPDGDD) .

The technical management of the reporting channel is carried out by ESCURA , which acts as the Data Processor under a contract signed with Teléfono Permanente SL, guaranteeing the security and confidentiality of the data processed.

Purpose of processing: Receiving, analyzing, monitoring, and resolving complaints, ensuring the confidentiality of the information and protecting the rights of data subjects.

Data retention: Once the complaint has been resolved and, where applicable, the sanctioning procedure has concluded, the data will be kept blocked for the duration of the sanction’s statute of limitations or as long as it may be required in a judicial proceeding.

Recipients: Only authorized personnel of Teléfono Permanente SL and ESCURA, as the data controller, and competent authorities if required by law, may access the data.

Legal basis: Compliance with legal obligations and legitimate interest in proper risk management and regulatory compliance.

Data subject rights: Access, rectification, deletion, restriction, objection, and portability of data, as well as withdrawal of consent at any time, by contacting info@telefonopermanente.com