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Ethical Channel Policy - GRUPO SH

The fundamental function of GRUPO SH's Ethical Channel is to receive communications in good faith and based on reasonable indications about circumstances, facts, or behaviors that may constitute the materialization of infractions, irregularities, non-compliances, or weaknesses in the SGC (Quality Management System), any of its policies and procedures, and/or the regulations it intends to cover. This also includes those that may represent a regulatory non-compliance within the organization.

A communication is considered to be in good faith when the person making it has reasonable grounds to believe, based on the information available at the time of the report, that the facts being reported are true.

Information that is entirely public, rumors, and unconfirmed gossip will not be considered infractions or irregularities subject to reporting through the Ethical Channel.

Interpersonal claims that affect only the reporting person, such as interpersonal conflicts between the whistleblower and other members of the organization, as well as any other doubts, complaints, or inquiries about their employment situation, should be directed to the appropriate procedures separate from the Ethical Channel.

Communications made in bad faith, false, or malicious may result in corresponding penalties, without prejudice to civil and even criminal liabilities that may arise according to current and applicable regulations.

GRUPO SH guarantees that there will be no reprisals against individuals who, in good faith, have reported infractions and irregularities through the Ethical Channel.

The data of the person making the report and of those involved in the reported incidents will be treated in accordance with current and applicable data protection regulations.

Access to the data contained in the Ethical Channel management system will be limited exclusively to those who perform internal control and compliance functions, or to data processors who may be designated for this purpose. However, access by other individuals or even their communication to third parties will be lawful when necessary for the adoption of disciplinary measures or for the processing of judicial proceedings, where applicable.

Personal data will be retained in the system only for the time necessary to decide whether to initiate an investigation into the reported incidents.

GRUPO SH has provided the following means to facilitate the aforementioned communications:

Specific email address: lembun@shbarcelona.com

GRUPO SH allows for communications regarding possible regulatory violations and violations of the SGC and its measures, policies, and procedures to be made either anonymously or confidentially. For this reason, the following measures are established to facilitate anonymous communications:

Send the communication by postal mail to the attention of the Compliance Officer (LAIA EMBUN) at the organization's address (CALLE CASANOVA 99 BAJOS, 08011 BARCELONA (BARCELONA)).

If the Model of Communication of Indication or Suspicion of Non-compliance is not used, the minimum information to be provided is as follows:

Date of the communication submission.
Organization receiving the information.
Incidents subject to reporting:

Data of the person or persons involved in the incidents.
Date of the reported incidents.
Description of the incidents to be reported.

In any case, whether the communication is made anonymously or confidentially, evidence must be provided at the time of making the communication to substantiate the reported facts.

GRUPO SH guarantees confidentiality or anonymity, as appropriate, for individuals using the Ethical Channel, as well as the management of all personal data of those involved in the procedure in accordance with current and applicable data protection regulations.

Furthermore, the organization prohibits any form of retaliation against individuals who make good faith communications based on reasonable indications through the Ethical Channel.

In accordance with current and applicable regulations on the protection of personal data, we inform you that your data will be included in the processing system owned by Grupo Sh, with a registered office at CALLE CASANOVA 99 BAJOS, 08011 BARCELONA (BARCELONA).

Purpose: Manage the reported complaint.
Retention period: Once the reason for the complaint is concluded, Grupo Sh will keep your personal data blocked for the periods of legal prescription or claims. Once the periods of legal prescription have expired, we will destroy your data.
Legal basis: Consent of the interested party and legitimate interest.
Transfers: Data will not be transferred to third parties, except where legally required.

In accordance with the rights granted by current and applicable regulations on the protection of personal data, you may exercise the rights of access, rectification, limitation of processing, deletion ("right to be forgotten"), portability, and opposition to the processing of your personal data, as well as revoke the consent given for the processing of the same, by sending your request to the postal address indicated above or to the email address info@shbarcelona.com. You may also address the competent supervisory authority to file any relevant complaints.