Ethical channel

At Solera, we provide you, in compliance with and under the protection of Law 2/2023, a communication channel for the receipt of information related to:

• Actions or omissions that may constitute a serious or very serious criminal or administrative breach.
• Actions or omissions that may constitute breaches of European Union Law, in accordance with Art. 2.1.a).
• Breaches of Labour Law in occupational safety and health matters.

In addition, we have enabled the communication channel to receive information that involves a breach of current legal regulations, as well as to receive any questions, complaints or suggestions regarding Compliance. Communications made will be received and processed by the Body Responsible for the Channel (Ethics Committee - Role Compliance Officer) and by the Governing Body (Sole Director) of Solera.

If you consider that any of the persons who will receive your complaint (Channel Responsible Body or Governing Body) is involved in the reported events, you may block the communication to that body, leaving it out of the processing and investigation.

Solera expressly prohibits acts constituting retaliation, including threats of retaliation and attempted retaliation against persons who make a complaint in accordance with the Law.

Maximum confidentiality and anonymity is guaranteed in the processes of investigation of the information received and the processing of it, with objectivity, impartiality and transparency, subject to the regulations on the protection of personal data and in compliance with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory breaches and the fight against corruption and Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union Law.

The identity of the informant shall in any case be kept confidential and shall not be disclosed to the persons to whom the facts reported refer or to unauthorised third parties.

The following rules must be observed when filling out the complaint forms:

• The information provided must be truthful.
• Communications must be made in good faith.
• Do not share personal data of third parties unrelated to the reported facts.
• Do not share personal data included in the special categories of data (health, ideology, union membership, religion, sexual orientation, beliefs or racial or ethnic origin, etc., Art. 9 LOPDGDD) (Organic Law on the Protection of Personal Data).

Any person who, in bad faith, submits a manifestly unfounded or malicious communication with the intention of causing unjustified damage, may be subject to the adoption of the appropriate measures or, as the case may be, to the communication to the competent authorities for the initiation of all the proceedings that may be appropriate.

Once the corresponding form has been filled in, ÉticoAldía will generate a receipt confirming that it has been received that you can print or "save as a PDF".

For more information on the general principles of the information management procedure and the use of the channel, please refer to the following documents:

Communications can also be made externally through external reporting channels to the competent authorities and, where appropriate, to the institutions, bodies, authorities or agencies of the European Union.

These channels can be any of the following:

• Independent Whistleblower Protection Authority
• The corresponding authorities or autonomous bodies.
• Public Prosecutor's Office.
• European Public Prosecutor's Office, in the event that the facts affect the financial interests of the European Union.
• State Security Forces and Corps.
• Competent Anti-Fraud Agency.
• Other relevant agencies.