Policy for reporting irregularities

POLICY FOR REPORTING IRREGULARITIES

ALGETRANSIT, S.L., complying with the requirements established in Law 2/2023, of February 20, regulating the protection of people who report regulatory infractions and the fight against corruption, bases its IRREGULARITY REPORTING CHANNEL POLICY, providing a framework of reference for establishing the objectives of the whistleblowing channel, based on the following principles of action:

• Establishment of a Channel for Reporting Irregularities in our scope of service, both within our organization and with the interested parties defined in the Integrated Management Manual.

• Promotion of continuous improvement of the implemented system through its updating and periodic review.

• Any harmful behavior in the organization is expressly prohibited.

• Trust, impartiality and protection of confidentiality throughout the whistleblowing process; guaranteeing said confidentiality in the reporting of irregularities throughout the reporting process.

• Two-way communication and continuous collaboration is established, both within the organization and with interested parties.

• The organization will provide guidance on how to present information and where to seek support or advice on the whistleblowing process.

• It is guaranteed that the person responsible for the whistleblowing channel will carry out his or her investigation and protection functions independently, confidentiality between those involved, the whistleblower, the complainant and the members of the investigative team, as well as correctness in all aspects of the process related to the complaints channel.

• Absolute respect for the presumption of innocence and the honor of the affected people.

• Any breach of our whistleblowing channel policy, such as deliberately false reports or conduct that is detrimental to the organization, will result in disciplinary action assessed based on the classification of the infraction in accordance with the sectoral agreement in the case of company workers. organization, (APEMAR), from the province of Cádiz. In the case of other interested parties, it could mean reporting to the competent authorities.

• The competent authorities establish alternative reporting channels, such as the Andalusian Office against Fraud and Corruption (OAAF).

• The irregularity reporting management system includes the reception of the complaint, for its subsequent evaluation and, if deemed appropriate, the complaint will be processed to finally issue a conclusion and resolution of the complaint.

• The possibility of establishing restrictions on the right to report is totally excluded, based on contractual obligations, such as disclosure agreements or clauses such as those relating to commercial confidentiality and employee confidentiality, among others.

• Our data protection policy complies with the requirements established in Law 3/2018 on the Protection of Personal Data and Guarantee of Personal Rights.

For this Policy to be real and effective, it is available to clients, workers and other interested parties, integrated into the general management of the company.