COMPLAINT POLICY – EDEBÉ EDUCACIÓN, SL

1. INTRODUCTION

This Complaints Policy (hereinafter, the “Policy”) aims to explain the operation of the internal tool of EDEBÉ EDUCACIÓN, SL (hereinafter, the “Policy”).
hereinafter, “EDEBÉ”, “Company” or “Company”) to communicate, in a confidential and secure manner, the actions that may be likely to constitute
an irregularity or illegal act or that simply fail to comply with the Company's principles or any internal regulations.

Its implementation has a legal basis in Law 2/2023, of February 20, regulating the protection of people who report regulatory infractions and the fight against corruption (hereinafter, the “Whistleblower Protection Law”).

EDEBÉ is committed to ensuring that the Company is a safe and legally compliant workspace.

In this sense, the Company expresses ZERO TOLERANCE in the event of any action, fact or circumstance that may constitute illegality or crime
or that, as already stated, fails to comply with the Company's guiding principles, this procedure constituting another example of the Company's rejection of such conduct and an invitation for workers and collaborators to use it.

Without prejudice to EDEBÉ's internal channel, which is described in this Policy, complainants are informed that they can also go to the channels
external ones described in Section 7.

2. DEFINITIONS, BASIC PRINCIPLES AND OBJECTIVES

2.1. This Policy is a tool to communicate irregularities or illegal acts, understood as any actions or omissions that may constitute violations of European Union Law that:

a) They fall within the scope of application of Directive (EU) 2019/1937 of the European Parliament and of the Council, of October 23, 2019, relating to the
protection of persons who report infringements of Union law;

b) They affect financial interests or affect the internal market;  

c) They may constitute a serious criminal or administrative infraction;

d) They may violate the Company's internal regulations.  

By way of example and not limitation, the following may be the subject of a complaint:

2.2. The principles that govern the operation and management of this Whistleblowing Policy and the EDEBÉ Whistleblowing Channel are the following:

a) Transparency and accessibility:
The Whistleblowing Channel will be publicly known and will be displayed and communicated, externally through the EDEBÉ website, in a separate and easily identifiable section, and internally, through the corporate intranet.

b) Confidentiality: Unequivocal commitment to the guarantee of confidentiality, on the identity and communications of the informants, of the affected persons and any third party mentioned in the information supplied. Confidentiality is also guaranteed when communication is sent through reporting channels other than those established or to members of the staff not responsible for your treatment, since all the staff of EDEBÉ knows its obligation to forward the communications received to the Responsible for the Internal Channel immediately, being aware that the breach of the obligation of confidentiality is considered as a very serious violation.

c) Good Faith: The communications that are made through the Channel 
Reports will be made with conviction as to truth or accuracy.

d) Objectivity and Impartiality: All communications made and received by the Company through its Complaints Channel will be treated and managed under the same criteria, regardless of who makes them and about whom or what they relate to.

e) Prohibition of retaliation: As set forth in Section 5 of this Policy, the reporting person who exercises his or her right to use this reporting channel in good faith may not be persecuted or retaliated against in any way for this reason, including threats of retaliation and attempted of retaliation.

f) Presumption of innocence: Respect for the presumption of innocence and right to honor of the person affected by the communications made is required. The accused will have the right to present allegations and be heard at all times.

g) Data protection: In any case, the principles and obligations regarding data protection must be respected, in accordance with Regulation (EU) 2016/679 General Data Protection (RGPD) and Organic Law 3/2018, of December 5, of Personal Data Protection and guarantee of digital rights (LOPDGDD).

3. SCOPE OF APPLICATION

The EDEBÉ complaints channel will be available to all people who have an employment or professional relationship with the Company and who carry out activities or provide services in or for it and who are aware of infractions, illegal acts or irregularities that could affect the company.
Specifically, the complaints channel is available to:

a) Working people;
b) Interns;
c) Candidates for jobs who are in a personnel selection or contractual negotiation process;
d) Self-employed;
e) Shareholders, participants and persons belonging to the administrative, management or supervisory body of the company, including non-executive members;
f) Any person who works for or under the supervision and direction of contractors, subcontractors and suppliers of EDEBÉ.

Likewise, it is worth emphasizing that the legal protection measures for the reporting person also apply to:

a) Natural persons who assist the reporting person and who have the same relationship with EDEBÉ;
b) Natural persons who are related to the reporting person and who may suffer retaliation, such as co-workers or family members of the reporting person;
c) Legal entities for which the reporting person works or with which he or she maintains any other type of relationship in a work context or in which
holds a significant participation.

4. COMPLAINT PROCEDURE AND MANAGEMENT: EDEBÉ'S INTERNAL COMPLAINTS CHANNEL.

A) Responsible

The people involved in the procedure have the obligation to maintain strict confidentiality and reserve, and must not transmit or disclose
information on the content of the complaints presented, resolved or in the process of investigation of which they are aware and, above all, the
identity of the reporting person if he had revealed it. According to what is established in the principle of confidentiality, within the section of principles and
guarantee.

An Admission and Management Commission is created that will study and analyze the complaints and will be responsible for the management of the Channel. This Commission will be
made up of HR personnel from the company.

Access to personal data contained in the Whistleblowing Channel is limited, within the scope of its powers and functions, exclusively to:

a) The person responsible for the Internal Channel;

b) The person responsible for HR at EDEBÉ, only when the adoption proceeds of disciplinary measures against a worker;

c) The person responsible for the legal department of EDEBÉ, if applicable. adoption of legal measures in relation to the events reported in the communication.

d) The people in charge of the treatment designated by EDEBÉ and who 
require access to said data within the framework of the provision of their services;

e) The data protection delegate.


B) Procedure:

I. Home:

The investigation begins from the complaint made by the person aware of the alleged irregular act or behavior. The reporting person
You have the right to file the complaint anonymously.

The communication of a complaint may be made in writing or verbally (as described in step II), with the Company guaranteeing the
confidentiality of both the reporting person and any other person involved or detailed during the process.

The reporting person may choose whether he or she wants to receive communications about 
the progress in the investigation and processing of the complaint, or if, on the contrary, He prefers not to have more information about it.

Depending on the above and also on whether the reporting person wants 
maintain anonymity or prefer to reveal their identity, complaints may contain the following data:

1. Data of the reporting person (if not anonymous and if the reporting person wishes to maintain communications with the Head of the Internal Channel about the progress of the investigation and processing of the complaint): Name and surname, ID, address, telephone number and email
electronic.

If provided, this information will be used to maintain communication with the informant or, where appropriate, to request additional information.

2. Exposition of the facts reported in the manner as detailed as possible.

3. How the facts that are reported became known.

4. Person or entity against whom the complaint is directed, indicating, in the case of a natural person, the most detailed information
possible to allow individualization (name and surname, position, company area, etc.).

5. Indication of possible witnesses who may have witnessed the reported events or who have antecedents regarding them.

6. Any other information that may be useful in the evaluation, investigation and final resolution of the reported events.

7. Any documentation that proves the complaint.

The reporting person may not be subject to retaliation of any kind for the simple fact of reporting, in accordance with the provisions of Section 5 of
this Policy.

II. Media:

The reporting person may choose between the following channels to file the complaint:

By regular mail: For the attention of the Whistleblowing Channel

Por correo electrónico:
canaldenuncias@edebe.net

By telephone: To the members of the Commission Admission and Management

In a face-to-face meeting: The reporting person can request the face-to-face meeting by sending an email through any of the indicated means and channels, which must take place within a maximum period of 7 days from the request.

In order to guarantee the content of verbal communications, including the in-person ones, these will be documented, with prior consent of the reporting person. To do this, the following methods may be used:

(i) Recording of the conversation in a secure, durable and accessible format o;

(ii) Through an accurate and complete transcription of the conversation carried out by the personnel responsible for treating it. In this case, it must be offered to the reporting person the opportunity to verify, rectify and accept through his signature on the transcription made.

III. Acknowledgment of receipt:
The Admission and Management Commission will send an acknowledgment of receipt of the complaint to the reporting person, within 7 calendar days following its receipt, provided that it is not anonymous.

IV. Admission for processing:
Once the complaint is received, the Admission and Management Commission will proceed to register it, opening a file and identifying it by a reference, which
guarantee compliance with the provisions of the personal data protection regulations. And they will check all possible non-compliance
careful and confidential.

If it is a complaint related to matters regulated in the Harassment Protocol that is currently in force in the company, once the complaint is received, it will be forwarded to the existing Commission on Harassment for processing through that Channel.

If there are indications that the facts of the complaint constitute a crime, EDEBÉ will immediately forward the communication to the Public Prosecutor's Office. In it
If the facts affect the financial interests of the European Union, it will be referred to the European Public Prosecutor's Office.

The Admission and Management Commission may:

a) In the event that the complaint is not anonymous, require the complainant to provide additional information, proceed to correct formal defects or clarify the information transmitted or provide additional documentation.

b) Admit the complaint to processing, for collecting evidence that the reported conduct constitutes an irregularity or illegal act, in accordance with what is indicated in Section 2.1. of this Policy.

c) Reject the complaint and proceed to file it, when it has manifestly been made in bad faith or abuse of rights or when it is clear from the complaint itself that the conduct or facts reported do not constitute an irregularity or illicit act, in accordance with what is indicated in Section 2.1. of this Policy.

If this occurs, the reasons that justify the reasons for archiving must be recorded in a report.

If there is reasonable evidence, the Admission and Management Committee will refer it, where appropriate, to the Investigation Committee:

In the case of anonymous complaints, the Admission and Management Commission will follow the procedures provided for in sections b) and c) above.

 

V. Commission of inquiry:
Once the complaint is admitted for processing, the procedure will be in the hands of the Investigation Commission. Said Commission will be made up of the people determined by the Company's Management according to competence in the matter and responsibility, unless the person subject to the complaint is the
General Director, in which case it will be the Board of Directors that determines the people who form said Commission.

Additionally, if necessary, an external person who is an expert in the subject matter of the complaint could be part of said Commission.

The Investigation Commission will respect the principle of presumption of innocence in all the procedures and actions it carries out and, obviously, will maintain confidentiality at all times.

The procedure begins by communicating in writing to the interested parties the agreement to begin the investigation procedure, except in the case of
that the complaint is anonymous or that it was necessary to postpone its notification to ensure an effective investigation or that there are other material interests
justified reasons that prevail over the interests of the person(s) investigated or interested.

The functions of the Investigation Commission are:

  • Analyze the complaint and, where appropriate, the attached documentation. Interview with the complainant. If she has decided to go directly to the complaint and investigation phase, she must be informed of the procedure and the possible courses of action. If the facts are not sufficiently described in the complaint, an additional account of the facts will be requested.
  • Interview with the person reported.
  • Interview potential witnesses.
  • Assess whether precautionary measures are necessary.
  • Issue the binding report.

This Commission will conclude with a report, which will be issued, at the latest, within 3 months following the formulation of the complaint, except in cases of
special complexity that an extension of the term is required, in which case, it may be extended up to a maximum of another 3 additional months. The report will include the conclusions reached and the proposal of the measures considered appropriate. The Commission will be responsible for the management, custody, and guarantor of confidentiality, of the set of documents that are generated and handled in this phase. For these purposes, the Company puts at your disposal the necessary means to manage these responsibilities.

The report of the Investigation Commission will be sent to the Resolution Body.

VI. Resolution Body:
The Resolution body will be made up of the General Director and the relevant members of the Company's Management Committee, unless the person
The object of the complaint is the General Director, in which case the Resolution Body will be made up of the Company's Board of Directors.

After analyzing all the circumstances and evaluating the investigation carried out, the Resolution Body will formulate its proposed resolution that it will send in writing to the parties so that, within a period of seven days, they can formulate the allegations they deem appropriate.

After that period, the Resolution will be final. The finality of the Resolution will be communicated to the parties.

The Resolution may have two meanings:

a) Dismiss the complaint. In this case, the complainant and the affected persons will be notified in writing, with a brief detailed explanation of the reasons why this decision is made.

b) Estimate the complaint. In this case, if it affects internal personnel of the Company, it will be communicated to the Human Resources Department or the person who performs these functions, so that they can communicate it to the affected person, applying the appropriate measures and, where appropriate, formulating the appropriate report to the competent authorities.

If the complaint is regarding a person external to the Company but with links to the Company as a Legal Entity, it will be put into
knowledge of the responsible persons and the appropriate measures will be adopted.

5. PROHIBITION OF RETALIALS
Acts constituting retaliation, including threats of retaliation and attempted retaliation against persons, are expressly prohibited.
informants.

Retaliation is understood as any act or omission that, directly or indirectly, involves unfavorable treatment that places informants at a particular disadvantage with respect to other people in the work or professional context, solely due to their status as informants, or for having made a
public disclosure.

The person who sees his or her rights harmed as a result of his or her communication or disclosure after the two-year period has elapsed may request protection from the competent authority which, exceptionally and in a justified manner, may extend the period of protection, after hearing the people or organs that could be affected. The denial of the extension of the protection period must be motivated.

6. TRATAMIENTO DE DATA PERSONAL
6.1 Personal data:
The collection, processing and communication of any personal data submitted through the reporting channel will be carried out in accordance with
in accordance with current legislation on data protection, including the General Data Protection Regulation (RGPD) and Organic Law 3/2018,
of December 5, Protection of Personal Data and guarantee of digital rights (LOPDGDD).

Except in the event that the complaint is submitted anonymously, EDEBÉ will process the personal data of the complainant, as well as the person(s)
person(s) reported and those of other people mentioned in such report, as data controller.

When a complaint is filed and an investigation is initiated, the persons involved will be informed, unless it is necessary to postpone notification to guarantee an effective investigation or there are other justified material interests that prevail over the interests of the person(s).
investigated(s).

If considered appropriate and relevant, the examination of a reported matter could involve the collection and processing of information
additional to that indicated in the initial communication, through interviews or conversations with the complainant, the affected person or witnesses. He
processing could also include information on possible sanctions contemplated by labor legislation, as well as the content of any
relevant notification to authorities, including police reports.

6.2 Purpose and legal basis for processing

The above personal data will be processed for the processing and investigation of the complaint submitted by the informant.

The processing of data necessary to comply with the legally required purposes is based on compliance with the legal obligation of the Law of
Informant Protection. The processing of data linked to complaints that are not directly linked to the previous legal obligation will be based on the legitimate interests of the Company, such as consideration of our business and reputation, or the maintenance of the standards required to perform a job. in the same.

The processing of personal data relating to criminal convictions and offenses will be carried out in accordance with the provisions of article 10 of the
GDPR.

6.3 Recipients of personal data

The personal data collected through the complaints channel may be communicated to public authorities and to third parties involved in the
treatment of complaints received. Such third parties, as data processors on behalf of the Company, could only process the data
personal data after prior agreement to do so and following the instructions given by the same. Said communication will be carried out in accordance with the
applicable data protection legislation, including the GDPR.

6.4 Conservation of personal data

Personal data that is not necessary for the knowledge and investigation of the facts or omissions that are the subject of the complaint will not be in any way
case being processed, so EDEBÉ will immediately proceed to delete it.

If the information contains personal data included within the special categories of data, it will also be immediately deleted, without
their registration and processing proceed.

The rest of the personal data necessary for the processing and management of the complaint will be processed for the essential time. In any case, if in the
After 3 months from receipt of the communication, investigations have not been initiated, EDEBÉ will delete the data, without prejudice to the right to
preserve the data to leave evidence of the operation of the internal complaints channel.

6.5 Data protection rights of complainants
and reported.

EDEBÉ has ​​taken all necessary and appropriate measures to protect both the complainants and the accused and their personal data, and
guarantee their rights as interested parties.

In this sense, the data protection regulations grant such persons, as interested parties, certain rights whose power to exercise them could
be subject to certain limitations. Such is the case that a certain right to obtain information is subject to other rights. Given
such limitations, any interested person may exercise the following rights:

  • Right of access: request to access your personal data and receive a copy of it.
  • Right to rectification: rectification of inaccurate personal data concerning you and completion of incomplete personal data.
  • Right of deletion: the Company will be obliged to delete the personal data processed referring to the complaining or reported persons, which
    concern them, if they request it, unless they are necessary for the ongoing investigation or future judicial proceedings.
  • Right to limit processing: in certain cases, there is the right to limit the processing that the company carries out on personal data.
    that refer to the affected people.
  • Right to data portability: right to obtain personal data that affects the affected person, in a structured, commonly used and machine-readable format, and to transmit it to a third party, when the treatment is based on the person's consent. affected or is due to the fulfillment of obligations derived from a contract with it.
  • Right of opposition: right to oppose the processing of the personal data of the affected person unless that information is
    necessary for the development of the investigation or future judicial proceedings.
In the event that the processing of personal data is based exclusively on consent, this may be withdrawn at any time, without prejudice to the processing carried out before withdrawing such consent. Both the person reported and the complainant may present, at any time, a claim to the competent supervisory authority. In Spain, this authority is the Spanish Data Protection Agency https://www.aepd.es/es.

7. EXTERNAL CHANNELS
EDEBÉ informs you that, in addition to the internal reporting channel described in this Policy, whistleblowers have external channels.
to the Company, to whom they can contact to present the information, in a complementary or alternative way to the internal channel.

Specifically, you can contact:

  • The Independent Whistleblower Protection Authority, AAI
  • Public Prosecutor's Office or European Public Prosecutor's Office, as appropriate
  • Tax Agency
  • sepblac
  • Any other competent administrative authorities

ANNEX I: Complaint form. Whistleblowing channel protocol