Compliant – WR Freiria

WHISTLEBLOWING CHANNEL / COMPLAINTS POLICY

1. PURPOSE AND SCOPE

The purpose of this Whistleblowing Channel (hereinafter, the “Channel”) is to establish a procedure for communications with the Compliance Team — responsible for managing the internal reporting system — in order to facilitate the reporting of irregular conduct or doubts regarding potential breaches of regulations or internal company policies, in accordance with Law 2/2023 of February 20, governing the protection of persons who report regulatory infringements and the fight against corruption.

This Channel must be used by all employees of the WR FREIRIA Group, including its governing bodies, directors, managers, and staff, as persons subject to the Compliance Program (CPP).
It may also be used by partners, contractors, subcontractors, suppliers, or any person working under the direction or supervision of the Group or otherwise linked to the company.

2. MANAGEMENT OF THE CHANNEL

The Compliance Team is responsible for managing the Channel and will receive written reports through the designated means, including the specific web platform provided for this purpose. Reports may be submitted anonymously.

In handling all reports, the Compliance Team shall observe the principles established in Law 2/2023, guaranteeing the confidentiality of the whistleblower’s identity and protecting them against any form of retaliation.
Likewise, the rights of the reported person — such as privacy, defence, and the presumption of innocence — shall always be respected.

3. PERSONAL DATA PROTECTION

WR FREIRIA, S.L. ensures that the personal data of whistleblowers are processed confidentially, in accordance with Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018, and Law 7/2021 when applicable.

The identity of the whistleblower shall not be revealed to the reported person, unless strictly necessary and with the proper safeguards.
Whistleblowers will be informed of their data protection rights (access, rectification, erasure, restriction, objection, portability), except in cases where the report was submitted anonymously.

4. SUBMISSION OF REPORTS

Anyone who becomes aware of conduct that may constitute a violation of internal policies, applicable laws, or that could affect the financial interests of the European Union, may submit a report through the means provided (web platform, email, postal mail, etc.).

Reports should include, as far as possible:

A description of the conduct or facts being reported
The persons involved
Approximate dates
How the events occurred
The processes or departments affected
Any supporting evidence or documentation

Once a report is received, the Compliance Team shall send an acknowledgment of receipt within seven (7) calendar days, unless the report is anonymous or acknowledgment could jeopardize confidentiality.

5. HANDLING OF REPORTS

If the report is admitted for processing, the Compliance Team shall conduct the corresponding investigation, either internally or with external support if necessary, and shall adopt appropriate measures.

The person subject to the report shall have the right to be informed of the allegations, to present their version of the facts, and to provide evidence — always respecting the presumption of innocence.

The investigation file shall document all actions taken, and the final report shall include findings, involved parties, relevant documents, and recommendations.

6. CONCLUSION OF THE INVESTIGATION

The investigation must be completed within a maximum period of three (3) months from the submission of the report. This period may be extended if the complexity of the case so requires, in which case the whistleblower will be informed.

The final report will state: the place, date, and nature of the facts; the persons involved; actions taken; evaluation of the facts; and recommended measures (case closure, disciplinary action, referral to authorities, etc.).

7. DOCUMENTATION AND RECORD-KEEPING

The Compliance Team shall retain all documentation related to the procedure in confidential case files, in accordance with legal record-keeping obligations.
Personal data linked to reports will only be stored for as long as necessary, and in no case beyond the periods established by applicable regulations.

8. PROTECTION OF THE WHISTLEBLOWER

WR FREIRIA, S.L. guarantees that no retaliation shall be taken against any person who, in good faith, reports irregular conduct or breaches of law or company policy.
Any act of retaliation shall be subject to disciplinary measures and, where appropriate, legal action.

CONTACT INFORMATION

WR FREIRIA, S.L.
Lugar Cerquillo 33, 36475 Salceda de Caselas, Pontevedra (SPAIN)
Email: compliance@wrfreiria.com (or the address you prefer to use for receiving reports)
Phone: (+34) 986 555 555
Website: www.wrfreiria.com