Our legal system is increasingly encouraging citizen participation in order to
the proper functioning of public and private institutions. This gives the citizen the possibility to denounce infractions detected within an organization in order to act accordingly and be able to remedy them.

MINCEB ASESORES, S.L. guarantees its commitment to the principles of legality, transparency, corporate and professional ethics, thus rejecting any type of irregular action within our organization. Therefore, we provide an anonymous channel of communication of incidents or illegal actions that occur or may occur in the entity reinforcing our culture of regulatory compliance.

Therefore, this Manual on the operation of the ethical channel of MINCEB ASESORES, S.L. has been created so that it is known by its employees, by anyone who has an employment or professional relationship with MINCEB ASESORES, S.L. and, ultimately, for all persons.
interested and related to us.

 his Manual regulates the procedure necessary for the correct implementation and adequate
operation of the ethical channel of MINCEB ASESORES, S.L..

The ethical channel is a communication channel through which information can be provided, including the following
anonymously, about irregularities committed within the organization and of which they are
real knowledge is available.

2.1. Who can use our ethical channel?

This channel can be used by any person with a professional and/or employment relationship
with MINCEB ASESORES, S.L., such as employees, shareholders, partners, collaborators, etc., but also suppliers, customers and, in short, any person who knows of behaviors within the organization that may be harmful to the citizen or to society as a whole can report information.

2.2 What issues can be reported through the channel?

As a guideline, and without limitation or exclusion, unlawful or potentially unlawful conduct may include the following
The illicit activities that can be communicated through the channel are: harassment, fraud and corruption (bribery),
document forgery...), theft, data protection or information security,
unethical practices or malpractices (misleading advertising), etc.

In addition, doubts or queries may be raised on issues related to our
compliance culture and may even be asked for advice or counseling on
practices or processes related to the organization.

 he operation of the ethics channel is governed by the principles of good faith, confidentiality, and
indemnity, and independence and impartiality.

3.1. Principle of good faith.

The person who uses the ethical channel to report an irregularity must comply with the
principle of good faith, which requires that any communication or complaint made through the ethics channel must be based on facts or evidence from which it can reasonably be concluded that
commission of a reportable act. It is strictly forbidden to report a fact knowing it to be false or with the intention of harming a third party. Any person who files a report that is untrue or that is based on the criteria of revenge or with the intention of harming the accused shall be sanctioned.

3.2. Principle of confidentiality and indemnity.

MINCEB ASESORES, S.L. will guarantee the maximum confidentiality of the communications received through the ethical channel, as well as of the person concerned and the person reported, preventing such data from being disclosed. Only the persons in charge of the proper management of the procedure will have access to it and will keep the due confidentiality.

Said confidentiality obligation shall not apply when the entity is obliged to disclose and/or make available information and/or documentation relating to its actions, including the identity of the parties involved, at the request of the competent judicial or administrative authority.

Likewise, MINCEB ASESORES, S.L. guarantees the protection to any person who communicates
any irregularities and to those who may be involved in the investigation of the facts, as well as to those who may be involved in the investigation of the facts.
to possible retaliation within the organization.

3.3. Principle of Independence and Impartiality.

MINCEB ASESORES, S.L. has outsourced the ethical channel management service in order to comply with the necessary principles of objectivity, independence and impartiality when investigating complaints or advising on the procedure, thus avoiding any conflict of interest that may arise.

4.1. Internal information system: ethical channel.

The channel provided by MINCEB ASESORES, S.L. as a channel of communications related to our organization, will be the ethical channel accessed through the following link:

mcadvisors.channels-ethics.com.

In addition, MINCEB ASESORES, S.L. guarantees the availability of the ethical channel through media such as the website in case we have it, always in a visible and independent section of the other headings so that it is easily accessible to the user.

The use of the organization's ethical channel does not prevent the whistleblower from using the external channels created by the competent authorities, State Security Forces and Corps, as well as Judges and Courts.

4.2. How to send a communication through the ethical channel platform.

The informant, when accessing our ethical channel, will be warned of the possibility of downloading the Tor Browser as it is a browser that completely protects the identity of the informant due to the fact that the IP of the device is not registered. This download can be done directly through the information window at the top of the home page of the ethical channel and thus ensure maximum confidentiality in communications.

To file a communication, go to the New Communication tab and click on the following link
proceed to complete the following points:

1. Description. The subject matter of the communication shall be indicated, as well as a description of the same as detailed as possible, and files may be uploaded as documentary evidence.

2. Identification. It is not obligatory and, in this section, the informant is advised of the possibility that he/she has of not revealing his/her identity. If he/she wishes to prove his/her identity, he/she shall provide his/her name and surname together with his/her e-mail address.

3. Conditions and rules of use. The informant must read and accept the rules governing the ethical channel as proof that he/she has been informed.

Once the communication has been delivered, the platform will provide a code to carry out the
follow-up of the procedure.

In order for users to be able to follow up on their procedure and check its status, they should go to the "Follow-up" option on the same home page of the ethical channel by entering the numerical code provided to them when they sent their communication.

All communications between informant and Instructor will be carried out through the platform established for this purpose, including a chat between informant and Instructor. However, when the user has identified himself/herself by providing his/her e-mail address, communications between informant and Instructor will be carried out through this medium.

The report must be individual. In the event that several people have knowledge of the same event, each of them must report it individually through the channel.

4.3. Reporting of false or bad faith allegations.

The ethical channel of MINCEB ASESORES, S.L. must be used in a responsible and appropriate manner. The communication of false facts, with a malicious and morally dishonest attitude, is a breach of the good faith that must preside over the labor and professional relations with MINCEB ASESORES, S.L., and may result in disciplinary measures in accordance with the collective agreement in force, applicable to labor personnel.

If, after the appropriate analysis, it could be concluded that the reported facts are manifestly false and that the complaint has been filed with a malicious attitude and in bad faith:
(i) the complaint shall be closed, documenting the reasons that have led to the closing of the file, ending the investigation work;
(ii) the proposed sanction shall be reported, in writing, to the Management Body or, as the case may be, to the Board of Directors, which shall decide the disciplinary action to be applied to the complainant in bad faith, and/or the possibility of claiming civil or criminal liability.

 he processing or management of the procedure, from the moment a communication or complaint is filed, is carried out by a third party outside MINCEB ASESORES, S.L. (Instructor) in order to comply with the due impartiality and objectivity required in this type of procedure, as well as to avoid the existence of conflicts of interest.

The processing of the procedure encompasses from the time the complaint is communicated through the channel until its resolution, and for this purpose, we have divided this process into the following phases:

5.1. Reception phase: reception, examination and categorization of the communication.

Once the Instructor has received the communication, he/she will issue an acknowledgement of receipt to the informant within seven (7) calendar days and will report one of the following results:

- Admission for processing. The facts reported or denounced are susceptible to be considered illicit acts or irregular behaviors that violate the principles and values of the organization for which it will be necessary to continue with its investigation.

- Inadmissibility. The complaint shall be rejected as inadmissible and the procedure shall be closed in the following cases:
(i) The facts described are not susceptible of being considered illicit or irregular;
(ii) The facts described are not supported by sufficiently convincing evidence.

There will be cases in which the informant will be advised on other ways in which he/she should proceed, referring him/her to the most appropriate procedure for the resolution of the matter that is the subject of his/her communication. In some cases, if the communication may be relevant to any other department for the purpose of improving the service, it will be referred to the corresponding department or area of the organization.

In any case, the decision taken and the reason for the decision shall be informed in writing.
the admission or inadmissibility of the complaint.

5.2. Research phase.

5.2.1. Opening of a file and investigation of the reported facts.

The Instructor of the procedure, once the communication has been evaluated, assessed and admitted, will proceed to the preparation of an opening file on the complaint under investigation.

The purpose of the opening file is to obtain maximum traceability of the investigation process, in case the complaint may be required by any competent judicial authority.

The Instructor will act with the due guarantees of confidentiality and the rest of the applicable principles of action, who will be in charge of the investigation and the collection of evidence of the complaint.

In the course of the investigation, the different areas of the organization may be called upon to effectively develop the claim of evidence and analysis to contrast the facts denounced.

The Management Body of the organization may be required at any time by the Instructor to complement, in a coordinated manner, the investigation actions carried out by the latter, always with the utmost confidentiality and discretion.

The Instructor will undertake, if deemed necessary, actions aimed at deepening the facts and gathering additional information to make a correct decision, in an objective manner, based on the evidence gathered. Investigation actions may include: requesting new evidence and/or proof from the complainant to improve the investigation process; arranging interviews with the persons involved; reviewing all information relating to the professional relationship of those involved with the organization, always in compliance with the data protection and privacy laws of those involved; forensic analysis by an independent external expert; any other action deemed necessary to continue with the investigation process, in compliance with current data protection regulations.

The investigation will consist, at all times, of an objective analysis of the documentation
available, evidence gathering, evidence collection, and evidence analysis.
The investigation period shall not exceed three (3) months from the date of receipt of the
communication or, if no acknowledgment of receipt was sent to the informant, three (3) months from the date of the communication or, if no acknowledgment of receipt was sent to the informant, three (3) months from the date of the communication.
of the expiration of the seven (7) day period after the communication is made, except in cases of
of special complexity that require an extension of the term, in which case, the term may be extended.
extended for a maximum of three (3) additional months.

5.2.2. Resolution of the investigation and Report of conclusions.

Once the allegations and evidence collected by the Instructor have been analyzed, the investigation phase is closed and a conclusions report is drawn up reflecting the outcome of this phase. This conclusions report will contain, in a clear manner, the assessment of the facts and a proposal for action with possible measures to be applied. If there is any limitation in the course of the investigation, it must be reflected in the report.

5.3. Decision phase.

After the investigation phase, in the decision phase, the entity's management body or board of directors will analyze the report drawn up by the investigating team with the proposed measures to be adopted, in order to issue the appropriate resolution determining the measures to be applied.

The informant and the respondent shall be informed in writing of the agreed decision and its justification, and one of the following options may be given:
- Dismissal of the complaint. Assumption in which the investigation of the reported facts shows the absence of non-compliance.
- Estimate of the complaint. Assumption in which it is proven that the facts denounced are true, having to proceed to detail the actions that support such conclusion and the measures that will be adopted.

In cases of extreme seriousness, it will be the obligation of the entity to report such events to the
State Security Forces and/or Judges and Courts.

MINCEB ASESORES, S.L. has a log-book of the information received and of the internal investigations to which they have given rise, guaranteeing, in any case, the confidentiality requirements foreseen.

This register shall not be public and only at the reasoned request of the competent judicial authority, by means of an order, and within the framework of a judicial proceeding and under the guardianship of that authority, may access all or part of the contents of the said register.

Personal data relating to the information received and to the internal investigations referred to in the preceding paragraph shall only be kept for the period necessary and proportionate for the purposes of complying with the law. In no case may the data be kept for a period longer than ten years.

MINCEB ASESORES, S.L. guarantees the confidentiality of the personal data of the informant who has been identified and that they will not be disclosed to the persons to whom the facts related or to third parties. Appropriate technical and organizational measures will be taken to preserve the identity and ensure the confidentiality of personal data.

Data subjects may exercise their data protection rights referred to in Articles 15 to 22 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

Finally, access to the personal data contained in the ethical channel will be limited exclusively to those persons who must do so within the scope of their powers and functions in order to manage the procedure.