Last Update: December 1, 2023

In our ongoing commitment to maintaining the highest standards of integrity and ethical conduct, we have established a Whistleblower Channel to provide a confidential avenue for reporting any potentially violation of law or irregular behavior within Inbenta.

This reporting channel is intended exclusively for people with whom Inbenta Holdings Inc. Branch in Spain has obligations or maintains or has maintained a contractual relationship, in accordance with 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, and with Spanish Law 2/2023, of February 20, regulating the protection of people who report breaches of law and the fight against the corruption.

To ensure effective communication and a thorough investigation, please adhere to the following guidelines when making a complaint:

Descriptive and Detailed Communication:
All communications should be as descriptive and detailed as possible. This will assist the recipients in identifying the potentially irregular behavior and the person(s) or department(s) involved. It is essential that your complaint contains all the necessary information for a comprehensive analysis. This may include:

• A clear and detailed description of the facts.
• Identification of the persons involved in the reported behavior or with knowledge thereof.
• Timeframe of the event or whether it is an ongoing occurrence.
• Quantification, whenever possible, of the impact of the reported event (economic or financial information).
• Provision, if considered necessary, of documents, files, or other information deemed relevant for the assessment and resolution of the complaint.
• The communication means you prefer to receive our notifications.

Principle of Good Faith:
Complaints must be made in accordance with an unwaivable principle of good faith. Provide sufficient reasons and objective evidence to demonstrate the existence of the alleged breach.

Acknowledgement of Receipt and Notifications:
An acknowledgment of receipt of the complaint shall be sent within a maximum period of seven days from its receipt to the communication channel that you have indicated to us. Communication with the reporter may be maintained, and, if necessary, additional information may be requested that may be useful for the handling of the complaint, always in a secure and confidential environment.

Confidentiality:
Inbenta will manage your report with the maximum degree of confidentiality and only a few people at Inbenta, duly authorized, will be able to handle your report. However, you have the right to submit your report anonymously. Thus, it is important that you let us know the communication means you prefer to receive notifications related to your report (for example, a PO box, an email address, or a postal address you consider secure).

Your commitment to these guidelines ensures the effectiveness of our Whistleblower Channel and contributes to maintaining an environment of transparency and accountability.

Regardless of whether you have decided to make an internal report or not, you can use the official reporting channels that the Spanish authorities make available to citizens. In Spain you can contact the A.I.I. (Autoridad Independiente del Informante) once constituted, as well as the AEPD (Agencia Española de Protección de Datos), the CNMC (Comisión Nacional de los Mercados y la Competencia), the CNMV (Comisión Nacional del Mercado de Valores), the ITSS (Inspección de Trabajo y Seguridad Social), or to the AEAT (Agencia Estatal de Administración Tributaria), depending on the nature of the irregularity.
For more information about our privacy practices, see our Privacy Policy.