NORTIA CAPITAL INVESTMENT HOLDING’S ETHICS LINE CHANNEL

This Ethics Line Channel is established in accordance with the provisions of Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23rd October 2019, on the protection of persons who report breaches of EU law (“Directive 2019/1937“) and Law 2/2023, of 20th February, regulating the protection of persons who report breaches of Union law and the fight against corruption (“Law 2/2023“), in order to promote compliance with the law and the regulations set forth in the Code of Conduct and other internal rules of Nortia Group (the “Code of Conduct“).

Who can file a complaint?

Any person who in an employment or professional context has obtained information about a suspected breach within the Nortia Group, namely directors, managers and employees of Nortia Group, including trainees and apprentices, business partners, contractors and suppliers.

What can I report?

• Actions or omissions that may constitute breaches of EU law.
• Actions or omissions that may constitute a serious or very serious criminal or administrative offence, especially those that involve financial loss to the Treasury and Social Security.
• Other actions or omissions that constitute a breach of Nortia Group’s Code of Conduct.

How do I file it?

This Ethics Line Channel shall be accessible through:

• The digital platform accessible through Nortia Group’s Intranet and website.
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• Email address: lineaetica@nortia.com.
• Request for a face-to-face meeting with the Information System Manager. In this case, the communication and conversations arising from it shall also be recorded and stored as an audio/video recording in accordance with current data protection legislation.

Who is the System Manager?

The Ethics Line Channel shall be managed by the Human Resources Manager.

What does the procedure involve?

1. Receipt of the complaint by the System Manager, who shall send the complainant an acknowledgement of receipt within a maximum of 7 days.
2. Appointment of an investigator to handle the complaint, who may request additional information from the complainant. The investigator shall decide whether there is evidence to open an investigation or, failing that, to close the case on the grounds that the breach has not been proved or does not exist.
3. A justified resolution shall be issued within a maximum period of 30 days, which may be extended in equal periods up to a maximum period of 6 months.
4. Conclusions report with the proposed measures to be taken, which shall be sent to the General Management and the Administrative Body of the parent company of Nortia Group.
5. If the incident could be classified as a crime, the Public Prosecutor’s Office shall be informed.

What general principles govern the Ethics Line procedure?

• Principle of protection of the bona fide complainant and non-retaliation. No communication through the Ethics Line Channel made in good faith shall give rise to any form of retaliation or threat of retaliation against the complainant or their family or friends.
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• Principle of transparency and confidentiality. Nortia Group guarantees the confidentiality of the people who proceed to submit any type of communication through the Ethics Line Channel, also guaranteeing transparency in its management.
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• Respect for the presumption of innocence and personal honour. Throughout the procedure, the right to the presumption of innocence of the complainant as well as the right to the honour of the complainant and the defendant shall be respected.
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• General data protection principles. Nortia Group guarantees that the general data protection principles set forth in the GDPR shall be taken into account, with special consideration of the principles of purpose limitation and conservation periods, data minimisation, loyalty and transparency and confidentiality and integrity. You can read more on how we process your data in our Privacy Policy.

What measures can be taken against the defendant?

The investigation of complaints may entail penalties and lead to any disciplinary measures that the Directorate General deems appropriate, in accordance with the Consolidated Text of the Workers’ Statute Law, the applicable Agreement, and other applicable laws.

Special procedure in case of harassment

When the content of the complaint refers to sexual harassment, whether gender-based or work-related, it shall be the responsibility of the Harassment Investigation Committee, which is made up of the persons responsible for investigating the sexual harassment and gender-based procedure, or by the persons responsible for investigating the work-related harassment procedure, depending on the type of complaint filed, and in accordance with the procedure set forth in Nortia Group’s Protocol for the Prevention, Detection and Action against Harassment.

Complainant Protection

The Ethics Line Channel offers protection against retaliation of any kind to a bona fide complainant, i.e. a complainant who uses the Ethics Line to report matters that they reasonably believe (including reasonable suspicions, actual or potential breaches, which have occurred or are likely to occur) are or could give rise to breaches of applicable law and/or the Code of Conduct.

Therefore, no communication through the Ethics Line Channel made in good faith shall give rise to any form of retaliation or threat of retaliation against the complainant or their family or friends. This implies that Nortia Group, its management body, officers and employees shall not penalise, dismiss, demote, suspend, threaten, intimidate, harass, transfer to unpleasant tasks or locations or in any other way discriminate against a complainant for using this Ethics Line Channel in good faith.

Nortia Group shall therefore not retaliate against the complainants or persons cooperating in the investigation, or their relatives, friends, co-workers and other persons related to them, as a result of the complaint filed.

Every complainant shall be duly protected as to the confidentiality of the facts reported and of their identity. In this regard, the Ethics Line Channel has been designed so that any complainant who wishes to remain anonymous can do so with sufficient guarantees. However, if the complainant freely chooses not to conceal their identity, Nortia Group shall use all its resources to try to ensure that neither their identity nor that of the parties involved (complainant, witnesses, etc.) is made public during the course of the investigation, in order to guarantee due confidentiality, except in the following cases:

1. Where it is required by law to be communicated to a judicial or administrative authority, or
2. When it is essential with regard to external advisors and consultants and other suppliers of Nortia Group for the operation of the Ethics Line Channel or the investigation of the reported facts (in these cases, Nortia Group shall contractually require the utmost confidentiality).

If the identity of the complainant becomes known, and provided that it is an employee, Nortia Group’s Human Resources Department shall be informed in order to monitor the stability of the complainant’s job.

Any action against the complainant that may be considered or may be understood as a threat, discrimination or reprisal for using this Ethics Line Channel shall be considered an employment offence under the terms established in the Workers’ Statute, as well as in the applicable Collective Bargaining Agreement, and may even lead to the application of very serious disciplinary measures such as disciplinary dismissal.

Exclusion from protection

The following are expressly excluded from the protection provided for: (i) information that has been previously rejected by any internal information channel, (ii) information relating to complaints about interpersonal conflicts or that affects only the complainant and the persons to whom the communication or disclosure refers, (iii) information that is already fully available to the public or that constitutes mere rumours, and (iv) information that refers to actions or omissions not covered by Law /2023.

To this end, although employees do not have the protection recognised in this Ethical Line Channel, this does not mean that they are not protected against possible reprisals, and, where applicable, they must resort to the respective legal and conventional regulations, as well as protocols and policies in force at Nortia Group.