Whistleblowing Channel

Salvat’s group whistleblowing channel

The Whistleblowing Channel is provided by Grupo Salvat to enable the prompt and confidential communication of irregularities that may involve regulatory non-compliance. Communications can be submitted anonymously.

Grupo Salvat provides this Channel as part of its internal information system and it is essential for the overall compliance with the Code of Ethics and internal regulations. Therefore, it actively contributes to our continuous improvement as a Group.

Communications submitted through the channel should address acts or behaviors, current or past, related to the scope of application of the Code of Ethics, as well as any administrative or criminal irregularities.

The channel is available to directors, employees, interns, Temporary Employment Agency (ETT) staff, agents, clients, collaborators, influencers, suppliers, individuals working for or under their supervision, shareholders, former employees (employment relationship terminated), and job applicants.

The system is available 24 hours a day, 365 days a year through the following access channels:

Upon request, reports can also be submitted through a face-to-face meeting, for which the request must be directed through any of the communication channels mentioned above.

Without prejudice to the detailed access channels, the interested party may also address the Independent Authority for the Protection of Whistleblowers.

Principles of action and guarantees

Grupo Salvat’s whistleblowing channel follows a series of principles of action and guarantees

Authority and independence

The Finance, HR and IT Director, Shall be in charge of the management of the Whistleblowing Channel and shall (i) identify and monitor Grupo Salvat’s risk of penalties and economic losses as a consequence of the infringement of laws or regulations and (ii) advice and assist Grupo Salvat’s top management and governance body in relation to compliance matters.

Confidentiality

Reports shall be resolved under a thorough, transparent and objective procedure, protecting the confidentiality of the involved individuals.

The duty of confidentiality is a principle of action followed at all times in the management of reports.

Access to information shall be restricted and available only to individuals in charge of the management of internal information system and the reports through the whistleblowing channel.

Anonymity and not traceability

Reports can be either nominative, disclosing the identification of the reporter, or anonymous.

Grupo Salvat is fully committed to respect the reporter choice of anonymity.

Traceability of reports is totally forbidden. Violation of this principle shall trigger the imposition of the relevant sanctions. To avoid traceability, Grupo Salvat has set forth the appropriate technological means to guarantee that accesses to the whistleblowing channel are automatically erased.

Non-disclosure of the identity of the reporter

The identity of the reporter shall never be reported to the reported person, and only to the individuals handling the report, when it is strictly necessary for the investigation of the facts and behaviors causing the report. The identity of the reporter can only be disclosed under the prior consent of the reporter.

The non-authorized disclosing of the identity of the reporter shall trigger the imposition of relevant sanctions.

Countermeasures and reporter’s protection

Grupo Salvat does not tolerate any kind of countermeasures on individuals filing for a report nor to those involved in its investigation, as long as they have acted in good faith and have not taken part in the facts reported.

Guaranteeing this principle triggers the adoption of the necessary measures to protect the reporter. If required under the circumstances the reporter shall temporarily be moved or isolated from its working place for protection purposes only.

Rights of the reported person and other persons affected

People reported or affected by the report shall have the right to be informed about the report filed against them as soon as the relevant findings have been made and the procedure has commenced.

Form Whistleblowing Channel

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