Whistleblowing Channel

1. Legal framework

This Whistleblowing Channel is established in compliance with Spanish Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, and as part of the Internal Reporting System implemented by Legalair Abogados S.L.

The Whistleblowing Channel constitutes a confidential mechanism made available to anyone wishing to report conduct that may amount to a regulatory infringement, a breach of professional ethics or a violation of the firm's Code of Ethics.

2. Persons entitled to use the channel

Under Law 2/2023, the following persons may use the Whistleblowing Channel:

• Employees, partners and collaborators of Legalair Abogados S.L.
• Trainees, volunteers and interns, whether paid or unpaid.
• Candidates who have taken part in selection processes.
• Former employees or collaborators whose relationship with the firm has ended.
• Clients, suppliers, contractors, sub-contractors and any other person maintaining a professional relationship with the firm.

3. Subject-matter scope

Through the Whistleblowing Channel the following situations, among others, may be reported:

• Acts or omissions that may constitute infringements of European Union law.
• Acts or omissions that may constitute serious or very serious criminal or administrative offences.
• Conduct contrary to the ethical principles of the legal profession.
• Breaches of the Code of Ethics, internal protocols or commitments undertaken by Legalair Abogados S.L.
• Situations of harassment, discrimination or any other conduct contrary to the dignity of persons.

4. Guarantees for the reporting person

Legalair Abogados S.L. guarantees the reporting person, in any event:

• Confidentiality: the identity of the reporting person and of any third party mentioned in the report will be treated confidentially and will not be revealed without their consent, save where there is a legal obligation in the framework of judicial or administrative proceedings.
• Non-retaliation: any retaliation, threat or attempted retaliation, whether direct or indirect, against persons making a report through the Whistleblowing Channel is strictly prohibited.
• Protection of personal data: data will be processed in accordance with the GDPR and Spanish Organic Law 3/2018, exclusively for the purpose of managing the report received.
• Anonymous reports: the system accepts anonymous reports, which will likewise be handled with the corresponding legal safeguards.

5. Reporting channel

Reports may be submitted through the following means:

• Email: canaletico@legalair.es
• Postal mail in a sealed envelope addressed to the Officer of the Internal Reporting System: Legalair Abogados S.L., Whistleblowing Channel — Confidential, Calle Alaró 12, 28033 Madrid.

6. Procedure

1. Receipt. Once the report has been received, the Officer of the Internal Reporting System will acknowledge receipt within a maximum of seven calendar days, unless such acknowledgement could compromise the confidentiality of the procedure.
2. Admission. An assessment will be made as to whether the report meets the relevant requirements and, if appropriate, additional information will be requested.
3. Investigation. The actions necessary to clarify the facts will be carried out, always respecting the right of defence and the presumption of innocence.
4. Reasoned decision. A decision on the report will be issued within a maximum of three months from receipt, extendable to six months in particularly complex cases.
5. Closure and filing. Documentation will be retained for the time required to evidence the operation of the system and, at most, for the period laid down in Law 2/2023.

7. Officer of the Internal Reporting System

Legalair Abogados S.L. has appointed an Officer of the Internal Reporting System who exercises duties with full autonomy and independence. The identity of the Officer is communicated internally and may be disclosed upon request through the channel indicated above.

8. External channels

Without prejudice to the internal Whistleblowing Channel, the reporting person may at any time approach the Independent Whistleblower Protection Authority, as well as the competent regional authorities, under the terms set out in Law 2/2023.

9. Good faith of the reporting person

Use of the Whistleblowing Channel must be in good faith. Reports knowingly made with false or distorted information may give rise to the consequences provided for by applicable law.