Ethical Channel

INTRODUCTION

ALMETAC is a company committed to compliance with all applicable legislation and aims to progressively go beyond the legally required minimums. Our work is based on responsibility to society, transparency and the mutual benefit of companies, workers and all those involved in the activities we carry out. ALMETAC strives to promote values such as: respect, communication, trust, honesty and transparency in all the activities it carries out and encourages them among all the people who make up the organisation and among the rest of its stakeholders.

Since its foundation, ALMETAC has defended and continues to defend its firm commitment to the continuity of its activity in the medium and long term, understood as a means of life for its workers and a contribution of wealth to its closest environment and to society in general, without this being endangered by a reduction in short-term profits.

OBJECT

The purpose of this document is to establish a channel of communication for the reception of queries, complaints and/or claims related to legislative breaches and/or practices contrary to the provisions of the ethical principles and values of ALMETAC, any other regulation or internal policy, as well as any situation or fact that requires the attention of the body responsible for compliance with these principles (hereinafter the "Ethical Channel").

This document is established to guarantee that, should any action be taken that is contrary to the legislation and/or internal rules and policies of ALMETAC, as well as any irregular conduct, the complaint will be treated in a professional and confidential manner, adopting the appropriate measures to protect the interests of ALMETAC and ensure effective compliance with those rules.

SCOPE

Any ALMETAC director, manager, or employee, supplier, customer, or any other interest group may send inquiries, complaints or claims through the established Ethical Channel.

The responsible for receiving the aforementioned queries and/or complaints (the "Supervisory and Control Committee") will ensure that all queries, complaints or claims received are analysed independently and confidentially by processing the corresponding file. It will also guarantee the confidentiality of the identity of the person making the enquiry and of the accused or accused, informing only those persons strictly necessary in the process.

SUPERVISORY AND CONTROL COMMITTEE

The Supervisory and Control Committee, through the person responsible for the Ethical Channel, is the body to which all parties with a legitimate interest must address themselves in order to report any possible Ethical non-compliance, whether it affects them personally or third parties.

Likewise, the person in charge of the Ethics Channel may have external advisory advisors who may collaborate on occasions when the appropriate internal resolution of the complaint is compromised.

The Supervisory and Control Body is made up of the ALMETAC Management Team and the person responsible for the Ethics Channel is the person responsible for the Internal Management System.

REPORTING IMPROPER ACTIVITY

Identification of the irregularity

Any person who becomes aware of the existence of irregular conduct, non-compliance or violation of the legislation in force or of ALMETAC's rules and policies, must report it immediately.

The Ethical Channel is the main means through which communications will be made and channelled, although these may also be transmitted directly to a superior officer or to the General Management, who will pass them on to the person responsible for the Ethical Channel for processing.

Communication and reception of the communication

A person who becomes aware of an irregularity may report it in the following ways:

Personally and verbally before any superior, who will collect it in writing, together with the signature of the complainant, and will always forward it to the person responsible for the Ethical Channel for processing.
By e-mail to the following address canaletico@almetac.com, whose recipient will be the person responsible for that channel, who will be responsible for opening and processing the corresponding file.

In any case, an attempt will be made to make the communication as descriptive and detailed as possible, thus making it easier for the recipient to identify the potentially irregular conduct and the person(s) or department(s) involved.

All communications submitted through the Ethical Channel must be made in good faith. False or malicious communications or reports may give rise to the corresponding sanctions, without prejudice to the civil and even criminal responsibilities that may arise under current law.

Minimum requirements for reporting

In order for it to be considered as such and to have a minimum set of elements for the subsequent investigation to take place if necessary, the communication of the complaint shall contain, as far as possible, the following information:

Identification, where appropriate, of the complainant
Description of the suspicious event in detail, consigning
- What the potentially irregular behaviour consists of.
- Possible persons involved.
- Approximate dates of occurrence.
- Means by which the potentially illegal conduct was carried out.
- Area of activity affected.
- Possible impact on relevant ALMETAC processes.

If applicable, documents or evidence of the facts will be provided.

Notwithstanding the above, for the purposes of investigation, anonymous complaints will be admitted. All requests or communications will be treated as confidential.

Classification of the complaint

impact, the person responsible for the Channel, who receives them, must classify them according to the following categorization:

Priority I: Communications alleging conduct contrary to current legislation that may involve or be related to the commission of a criminal offense, as well as those others that, due to their seriousness, may warrant such classification.
Priority II: The rest of the communications

Valid Priority I reports should be forwarded to the person responsible for the Ethical Channel within 3 working days of receipt of the report, who will make initial contact with the author of the report, if not anonymously, within 7 working days of receipt, in order to obtain additional data and explain the next steps.

For valid Priority II complaints, the person responsible for the Ethical Channel must make an initial contact with the author of the communication, if not anonymous, within 10 working days after receipt of the communication.

If there is any doubt about the seriousness of the reported event, it will be classified as a Priority I complaint and will be dealt with.

Action and research

The person in charge of the Ethical Channel will identify with a code the investigation file, so that it safeguards the identity of the same in the documentation and communications that are generated.

The person responsible for the Ethical Channel, once he/she has obtained all the relevant information about an irregular conduct, if he/she considers that there is reasonable evidence of the existence of an action or omission contrary to the legislation in force and/or to ALMETAC's Ethics, will initiate an investigation procedure. To this end, various measures will be taken:

Appoint an investigating person (internal or external to ALMETAC) to initiate the investigation file and draw up the investigation report.
Establish the procedures for carrying out the investigation that will allow both the preservation of evidence and respect for workers' rights. These procedures may include personal interviews with the source to gather more information; personal interviews with the departments and/or persons involved in the reported irregular conduct; analysis of data or obtaining information from external sources; request for expert evidence from professionals within or outside ALMETAC, or others.
Establish which department(s) or area(s) should be informed of the investigation and at what level in the hierarchy, depending on:
- The hierarchical level and number of possible persons involved.
- The need to involve other departments, in order to obtain contrasting data (economic information, access to databases, data from servers or email,).

Once the investigation has been completed, the instructor will make a proposal for a report with the main conclusions that will be sent to the Supervisory and Control Body so that it can take the necessary measures.

The confidentiality of the investigation and its content, as well as the confidentiality of the persons involved in the investigation, shall be guaranteed at all times.

If, upon receiving the communication, the person responsible for the Ethical Channel considers that the reported facts do not represent a violation of the legislation in force or of the Ethical Rules of ALMETAC, he or she will proceed to reject the complaint, stating the reasons, and will file the case and communicate it to the person who made the report with the reasons for the rejection, reporting it in a timely manner.

Regardless of whether the complaint is filed or not, the person responsible for the Ethical Channel will inform the denounced party in an express, precise and unequivocal manner of the content of the complaint, the employees and third parties that may have access to it, as well as their rights and obligations, including the rights related to the protection of personal data. In the event that the communication of the complaint to the denounced party could in any way hinder the internal investigation, said communication could be delayed by a maximum of three months from the date of the complaint.

Así mismo la persona responsable del Canal Ético informará al denunciante sobre las medidas tomadas.

Conclusions

The report issued by the instructor will be collected:

The communication of the irregular conduct received,
the procedures used for its investigation,
the documented results of the investigation,
the corrective measures to be taken, if any, as well as the disciplinary sanctions that may be applicable, in accordance with the provisions of the disciplinary system (in the case of ALMETAC staff) or the conditions established by contract (in the case of external staff),
the recommendations or proposals for prevention or improvement in the control, supervision, evaluation and updating of the Ethical Model necessary to avoid its repetition in the future.

Likewise, the person responsible for the Ethical Channel shall inform the complainant of the measures taken.

Igualmente, el Órgano de Supervisión y Control garantizará en todos los casos la máxima confidencialidad en los procesos de investigación de las denuncias recibidas, a los efectos de proteger la identidad de los denunciados y su reputación en el seno del grupo, informando, tan sólo, a las personas estrictamente necesarias en el proceso.

PROTECTION OF WHISTLEBLOWERS AND RESPONDENTS

The Supervisory and Control Committee shall ensure that there is no retaliation of any kind against the person or persons who have made inquiries, complaints or allegations in good faith. If it is confirmed that such persons have been subjected to reprisals, the perpetrators will be investigated and, if appropriate, sanctioned.

Likewise, the Supervisory and Control Committee will guarantee in all cases the maximum confidentiality in the processes of investigation of the complaints received, for the purpose of protecting the identity of those reported and their reputation within the group, informing only those persons strictly necessary in the process.

PROTECTION OF WHISTLEBLOWERS AND RESPONDENTS

DATA RETENTION

The Oversight and Control Committee will keep a record of information on complaints received, investigation reports, as well as periodic and/or timely reports issued.

The personal data obtained on the occasion of the complaint and as a result of the corresponding internal investigation shall be deleted from the complaints system three months after the data have been entered, without prejudice to the fact that they may be kept in other systems on the occasion of the investigation that may result from them. In addition, they will be kept as evidence of the operation of the crime prevention model until the legal actions that the object of said denunciation could derive from are prescribed, in accordance with article 24.4 of Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights. In the event that the complaint is not accepted for processing, it will be kept anonymous.