Ethical Channel Policy

1. Purpose

This Policy aims to regulate the Ethical Channel of arttalo TECH, through which it is possible to report any incident or irregularity of potential significance and ensure that it will be addressed objectively, independently, anonymously, and confidentially, taking appropriate measures.

The Ethical Channel serves as a tool for employees and other individuals associated with arttalo TECH, such as clients, suppliers, contractors, or subcontractors, to report possible behaviors that may constitute a crime, harassment, or be contrary to the organization’s principles and values, thereby ensuring transparency and good corporate governance.

2. Scope of Application and General Provisions

This document applies to all individuals who report an incident or irregularity through the Ethical Channel.

An incident or irregularity is understood to be any act presumed to be contrary to legal regulations, general principles of conduct, and ethical behavior. This also includes any non-compliance that could constitute the commission of a crime attributable to the legal entity.

By way of example and not limited to, the issues that can be reported through the Ethical Channel include:

  • Financial and accounting irregularities
  • Non-compliance with regulations and internal policies
  • Unethical conduct or conflicts of interest
  • Theft, embezzlement, or fraud
  • Bribery or corruption
  • Misuse of privileged or confidential information
  • Workplace harassment or discrimination
  • Environmental issues
  • Violation of human rights

In this regard, communications addressing issues for which there is a specific channel, such as customer service or sales, will not be processed through the Ethical Channel.

The reporting of incidents will be done through the channels that arttalo TECH has made available on the corporate website.

If a communication that could be addressed through the Ethical Channel is received through a different avenue, employees are obligated to inform the Compliance department for redirection to the Ethical Channel.

3. Reporting Incidents and Irregularities

Any person who becomes aware of an incident or irregularity that contravenes internal regulations and/or applicable legislation has the obligation to report it through the Ethical Channel.

Likewise, any person or stakeholder not directly associated with arttalo TECH who wishes to report irregularities they are aware of can also use the Ethical Channel to report such behaviors.

Based on the reported incidents and factors such as the type of unethical behavior, country, and impact, a dedicated working unit is established to effectively handle each complaint received. The Ethics Manager, as an independent figure, oversees the Ethical Channel, maintaining continuous control over incoming reports and the processing units. Their role is to ensure proper handling and resolution of each complaint.

4. Process Guarantees

4-1 Whistleblower Protection

Any person who reports an incident or irregularity in good faith through the Ethical Channel will be guaranteed protection. Specifically, they have the right to be protected as established in Directive (EU) 2019/1937 of the European Parliament and of the Council, dated 23 October 2019, concerning the protection of persons reporting breaches of Union law.

4-2 Confidentiality and Anonymity

The whistleblower who wishes to make a report without providing their personal details can do so anonymously. Similarly, if the whistleblower chooses not to remain anonymous, they will be assured that their personal information and that of the parties involved will remain confidential.

Similarly, there is an obligation to ensure the protection of the identity of the accused during the management process of the reports and, if necessary, even after the resolution.

Any breach of the duty of confidentiality by individuals involved in managing the reports will be investigated and, if appropriate, sanctioned.

4-3 Conflict of Interest Management

The process of managing the communications received through the Ethical Channel is conducted by an independent, impartial, and objective team.

During the establishment of the investigation and resolution unit for each specific report, a preliminary review is conducted to identify any conflicts of interest involving the chosen team members. If conflicts are found, those conflicted members are excluded, and different members are appointed to handle the investigation, thus ensuring independence is safeguarded.

4-4 Prohibition of Retaliation

arttalo TECH guarantees that no direct or indirect retaliation will be taken against individuals who, in good faith, have reported an incident or irregularity through the Ethical Channel.

Similarly, any actions perceived as threats, retaliation, or discrimination against an employee for making a report through the Ethical Channel will be considered a labor violation.

4-5 Presumption of Innocence and Professional Integrity

Individuals accused or implicated through any communication received via the Ethical Channel will be guaranteed the presumption of innocence, regardless of decisions made by direct supervisors or the Human Resources department.

5. Responsible Use of the Ethical Channel

It is the responsibility of the whistleblower to use the Ethical Channel responsibly, and under no circumstances should they make unfounded or malicious reports. In such cases, applicable legal and/or disciplinary actions may be taken. Additionally, any report made about another person must be respectful and maintain decorum and good manners.

Likewise, the whistleblower must ensure that the information provided is true, accurate, complete, and up-to-date.

6.- Protection of personal data

The Ethics Channel guarantees the security of the process for receiving and resolving incident and irregularity reports, as well as the security of the individuals involved in the process. This is achieved through the application of sufficient and appropriate IT security measures to ensure confidential handling of submitted reports and to protect the confidentiality of individuals involved in both the processing of reports and subsequent investigation and resolution.

The entity responsible for processing your data is arttalo TECH, and the data collected through the Ethical Channel will be processed solely for the purpose of handling the received reports and, if applicable, investigating the reported incidents.

You may revoke at any time the consent given for personal data processing activities by arttalo TECH, as well as exercise your rights to access, rectify, delete, oppose, limit data processing, data portability, and not be subject to automated decisions, as indicated in the “Rights of Data Subjects” section of our Privacy Policy.

Similarly, you are informed that you have the right to file a complaint with the Spanish Data Protection Agency regarding any action related to this procedure.