Ethics channel

1. What is the ethics channel?

The ethics channel of Impulso Tecnológico S.L. is the route provided to receive and manage confidential reports. Where a report falls within Spanish Law 2/2023 of 20 February, the safeguards and time limits in that law apply.

It is the channel to communicate, in good faith and confidentially, any conduct or fact that may constitute:

• Infringements of European Union law.
• Actions or omissions that may constitute serious or very serious criminal or administrative infringements.
• Violations of the internal Code of Ethics or of Impulso Tecnológico S.L.'s compliance policies.
• Cases of labour, sexual, discriminatory harassment or any conduct contrary to the company's principles.

2. Who can use the channel?

• Current or former employees, interns and volunteers.
• People in selection processes or pre-contractual negotiations.
• Self-employed contractors providing services to the organisation.
• Shareholders and members of administrative bodies.
• Contractors, subcontractors and suppliers.

3. How to submit a report

The following channels are available:

• Email: ethics@impulsotecnologico.com.
• Postal mail: Impulso Tecnológico S.L. — Officer of the Internal Information System, Calle Delmira Agustini 5, local 4, 28021 Madrid – España, in a sealed envelope marked "CONFIDENTIAL — ETHICS CHANNEL".
• In-person meeting: at the whistleblower's request, within 7 days of the request.

You may report without including your identity. Email may contain sender metadata; if you need to avoid providing it, use unidentified postal mail. Any identity provided will be handled confidentially with restricted access.

4. Whistleblower guarantees

Statutory protections apply where the scope and requirements of Law 2/2023 are met.

• Confidentiality. The whistleblower's identity will not be disclosed to unauthorised persons, except for legal obligation as part of a judicial investigation.
• Prohibition of retaliation. Anyone reporting in good faith is protected against any labour or professional retaliation (dismissal, suspension, substantial change in conditions, negative evaluations, etc.).
• Support measures. The whistleblower may request the measures provided by Law 2/2023 from the competent authority where applicable.
• Data processing. Personal data is processed in accordance with the privacy policy and retained only for the time necessary to decide on the merit of the report, with a maximum of 3 months from receipt unless formal proceedings are opened.

5. Procedure

1. Acknowledgement of receipt within a maximum of 7 calendar days from receipt of the report.
2. Preliminary analysis of admissibility. If admitted, a file is opened.
3. Internal investigation with all guarantees of impartiality, hearing and defence.
4. Conclusion and response to the whistleblower within a maximum of 3 months (extendable to 6 in complex cases), under article 9 of Law 2/2023.

6. Channel management

Reports are sent to the contact below. Access and handling are restricted to authorised personnel and must preserve confidentiality, impartiality and the right of defence.

• Channel contact: ethics@impulsotecnologico.com

7. External channel and authorities

Additionally, every whistleblower may directly contact the external channels provided by law:

• Secure external channel of the Independent Whistleblower Protection Authority (A.A.I.), where it has jurisdiction.
• Competent regional authority, where applicable.
• European Union institutions, bodies or organisations.