Ethical
Channel

EXLABESA's Ethics Channel

EXLABESA is committed to strengthening the culture of information or communication as a mechanism to prevent and detect threats to the public interest, in compliance with the regulations on the protection of personal data and Law 2/2023, of 20 February, regulating the protection of persons who report regulatory and anti-corruption infringements and Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law.

In compliance with this commitment, this Ethics Channel has been set up, which constitutes the internal information system through which people who interact with EXLABESA in a work or professional context can report any irregular conduct of which they are aware that involves:

• Infringement of EXLABESA's Code of Ethics or its harassment prevention protocol.
• Acts or conduct with possible criminal significance;
• Serious or very serious administrative offences;
• Actions or omissions likely to constitute infringements of European Union law under Law 2/2023.

The use of the Ethics Channel for other purposes is excluded, such as matters related exclusively to labor matters that do not generate legal breaches (such as interpersonal conflicts that do not constitute harassment) or claims regarding the ordinary management of the products supplied by companies operating under the EXLABESA brand, which must be managed through the channels established for this purpose.

EXLABESA guarantees maximum confidentiality and anonymity in the investigation processes of the information received and the treatment of the same with objectivity, impartiality and transparency. Likewise, EXLABESA expressly prohibits acts constituting retaliation, including threats of retaliation and attempts at retaliation against persons who submit a communication, in accordance with the provisions of Law 2/2023.

Please bear in mind that the use of the Ethics Channel requires good faith on the part of users. The information you provide through the Ethics Channel must be truthful and exclusively related to an action or omission in the areas indicated. Therefore, when filling out the forms, you should take into account the following rules:

• Communications must be made in good faith, with truthful information.
• Do not share personal data of third parties unrelated to the reported facts.
• Do not share personal data included within the special categories of data (health, ideology, trade union membership, religion, sexual orientation, beliefs or racial or ethnic origin, etc., art. 9 LOPDGDD), unless it is essential to substantiate the complaint.

A reporting person who, in bad faith, submits a manifestly unfounded or malicious communication with the intention of causing unjustified damage, may be subject to the adoption of the appropriate measures or, where appropriate, to the communication to the competent authorities for the initiation of those proceedings that may be of purpose.

Written communications made through the Channel may be anonymous, if so decided by the informant, who may follow up on the communication submitted, through the tracking number that will be provided. However, we encourage you to identify yourself when you make a communication, as this will help us in the development of a correct investigation. Your identity and the information you provide will be treated with absolute confidentiality.  In addition, we ask that you please provide us with all the necessary details to allow us to investigate the matter.

We inform you that communications may also be made externally through external information channels to the competent authorities and, where appropriate, to the institutions, bodies, offices or agencies of the European Union. These channels can be:

• Independent Whistleblower Protection Authority (A.A.I.).
• Before the corresponding authorities or regional bodies.
• Prosecution.
• European Public Prosecutor's Office, in the event that the facts affect the financial interests of the European Union.
• State Security Forces and Corps.
• Other competent bodies.

Please note that this is not an emergency service. In the event of any imminent danger, contact the appropriate authorities.

For more information on the general principles of the information management procedure and the use of the channel, please refer to the documents "Canal Policy" and "Channel Management Procedure".

You can also consult the EXLABESA Code of Ethics below.