Procedure for managing communications to the Ethics Channel

1. OBJECT

The purpose of this procedure is to develop the Policy of the Internal Information System and Defense of the Informant of INDUSTRIAS SOMBRERERAS ESPAÑOLAS S.A., regarding the registration, admission, investigation and conclusion of communications on alleged irregularities or non-compliance reported through the Company's Ethics Channel.

The ethical channel of SPANISH HAT INDUSTRIES S.A. It is accessible through the corporate website https://www.fernandezyroche.com/es/ Its use is permitted to persons who are aware of possible risks of serious administrative and/or criminal offences attributable to any person or entity linked to the Group in their professional sphere.

This Channel facilitates the secure formulation of communications, ensuring that the privacy of the persons involved and the confidentiality of the data contained in the complaint are effectively protected throughout the process, and the complaint can be made anonymously if the complainant so deems necessary.

2. SCOPE OF APPLICATION

This procedure is applicable to all communications included in the subjective and objective scope of the Internal Information System and Defense Policy of the Informant of INDUSTRIAS SOMBRERERAS ESPAÑOLAS S.A.

Likewise, all persons involved in managing communications will follow this procedure.

The Ethics Channel should be understood as an instrument that allows for the communication of irregularities or non-compliance. Therefore, it should not be used indiscriminately, but rather for the purposes for which it was conceived.

3. MEANS FOR COMMUNICATIONS

The internal information system must be used preferably to channel information, since diligent and effective action within INDUSTRIAS SOMBRERERAS ESPAÑOLAS S.A. could paralyze the harmful consequences of the actions under investigation.

However, once this preference has been declared, the informant may choose the course to follow, internal or external, depending on the circumstances and the risks of retaliation that he or she considers.

Regarding internal communication channels, the following are recommended, at the informant's discretion:

Through the form enabled on the website https://www.fernandezyroche.com/es/

By communication addressed to C. Castilla la Mancha, 202, CP 41909 Salteras, Seville.

By phone 954666398

At the request of the informant, channelled through these means, he/she may also present himself/herself through a face-to-face meeting within a maximum period of seven days from the date the communication is filed.

Any person from SPANISH HAT INDUSTRIES S.A. Any person who receives a communication and does not have the authority to investigate the facts reported because it is one of the types of communication provided for in the Internal Information System and Defence of Informants Policy must forward it to the Person Responsible for the System without undue delay. Failure to comply with this obligation will be considered a serious breach of confidentiality obligations.

The external channels that the whistleblower may decide to use, if applicable, refer to communications made to the national and European Institutions, Agencies and Authorities, through the means determined by them, and in particular to the Whistleblower Protection Authority to be created in the near future.

In certain cases, and only for breaches that have effects in the territory of the autonomous community, the Autonomous Authorities for the Protection of Informants can be contacted, currently created in: Catalonia, Valencia, the Balearic Islands, Navarre, the Principality of Asturias or Andalusia.

4. PROCESSING OF COMMUNICATIONS

As a general rule, the maximum period for responding to investigation actions may not exceed three months from receipt of the communication or, if no acknowledgement of receipt was sent to the informant, three months from the expiry of the seven-day period in which the acknowledgement of receipt should have been sent, except in cases of particular complexity that require an extension of the period, in which case, this may be extended up to a maximum of another three additional months.

At the various stages of the processing, the possibility of maintaining communication with the informant is provided for and, if deemed necessary, of requesting additional information from the informant, unless the informant has waived this right.

In any case, the right to the presumption of innocence and the honour of the persons affected will be respected, as well as the provisions on the protection of personal data as provided.

Where the facts could suggest a criminal offence, the information shall be forwarded immediately to the Public Prosecutor's Office. Where the facts affect the financial interests of the European Union, it shall be forwarded to the European Public Prosecutor's Office.

4.1. Reception and Registration of Communication.

The information may be provided anonymously. Otherwise, the identity of the informant will be kept confidential.

In cases of verbal communication, the informant will be warned that the communication will be recorded and will be informed of the processing of his/her data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, and Organic Law 3/2018, of December 5.

When submitting the information, the informant may indicate an address, email or safe place for the purposes of receiving notifications, and may also expressly waive the receipt of any communication of actions carried out by INDUSTRIAS SOMBRERERAS ESPAÑOLAS S.A. as a result of the information, in the event that the communication is submitted by telephone, postal mail or in person.

In the case of verbal communication, including those made through a face-to-face meeting, by telephone or through a voice messaging system, the System Manager must document it in one of the following ways:

by recording the conversation in a secure, durable and accessible format, or

through a complete and accurate transcription of the conversation conducted by the staff responsible for handling it.

Without prejudice to the rights that apply to him/her under data protection regulations, the informant will be offered the opportunity to check, rectify and accept the transcription of the message by signing.

Once the information has been submitted, it will be registered in the Information Management System and assigned an identification code. The Information Management System will be contained in a secure database with restricted access, in which all communications received will be recorded, filling in the following data:

Date of receipt.

Identification code.

Actions carried out.

Measures taken.

Closing date.

Once the information has been received, within a period of no more than 7 calendar days from said receipt, receipt will be acknowledged, unless the informant has expressly waived receiving communications related to the investigation, or unless this may jeopardize the confidentiality of the communication, in the cases indicated above.

4.2. Admission Procedure

Once the information has been recorded, the System Manager will check whether it exposes facts or conduct that are within the scope of the Internal System Policy on Information and Defense of the Informant. As well as whether it is necessary to reassign the communication to another person or management team due to any of these situations:

Conflict of interest of the System Manager, as he/she is a person affected by the communication.

Existence of an ad hoc team for managing communication based on the subject matter.

Once this preliminary analysis has been carried out, it will decide, within a period of no more than ten working days from the date of entry of the information in the registry:

a. Refuse to admit the communication in any of the following cases:

When the facts reported lack any credibility.

When the facts reported do not constitute a violation of the legal system included in the scope of application of the Internal Information System and Informant Defense Policy.

When the communication is manifestly unfounded or, in the opinion of the System Manager, there are reasonable indications that it was obtained through the commission of a crime. In the latter case, in addition to the inadmissibility, a detailed account of the facts that are considered to constitute a crime will be sent to the Public Prosecutor's Office.

When the communication does not contain new and significant information on infringements compared to a previous communication for which the corresponding procedures have been concluded, unless there are new factual or legal circumstances that justify a different follow-up. In these cases, the System Manager will notify the resolution in a reasoned manner.

The informant will be notified of the refusal within the following five business days, unless the communication was anonymous or the informant has renounced receiving communications from the System Manager through the means of communication mentioned above.

b. Admit the communication for processing.

The admission to processing will be communicated to the informant within the following five business days, unless the communication was anonymous or the informant had renounced receiving communications from the Responsible for the INDUSTRIAS SOMBRERERAS ESPAÑOLAS System. S.A. in the media of infringements set out above.

c. Immediately forward the information to the Public Prosecutor's Office when the facts could suggest a crime or to the European Public Prosecutor's Office in the event that the facts affect the financial interests of the European Union.

d. Forward the communication to the authority, entity or body considered competent to process it.

4.3. Investigation

The investigation will include all actions aimed at verifying the plausibility of the reported facts.

The person affected by the information will be informed of the information and of the facts described in a concise manner. In addition, the person will be informed of the right to submit written allegations and of the processing of his or her personal data. However, this information may be provided during the hearing if it is considered that providing it beforehand could facilitate the concealment, destruction or alteration of the evidence.

In no case will the affected subjects be informed of the identity of the informant or be given access to the communication. During the investigation, the person under investigation will be informed of the communication with a brief account of the facts. This information may be provided during the hearing if it is considered that providing it beforehand could facilitate the concealment, destruction or alteration of evidence.

Without prejudice to the right to submit written allegations, the investigation shall, whenever possible, include an interview with the person concerned in which, always with absolute respect for the presumption of innocence, he or she shall be invited to present his or her version of the facts and to provide any evidence that he or she considers appropriate and relevant.

In order to guarantee the right of defence of the affected person, he or she will have access to the file without revealing information that could identify the informant, and may be heard at any time.

The person responsible for the System shall be obliged to maintain confidentiality regarding the information they become aware of on the occasion of said exercise.

All the people of the SPANISH HAT INDUSTRIES S.A. They must cooperate with the investigation and will be obliged to respond to requests made to provide documentation, data or any information related to the procedures being processed, including any personal data requested.

4.4. Termination of proceedings

Once the investigation is completed, the System Manager will adopt one of the following decisions:

Filing of the case, which will be notified to the informant and, where appropriate, to the affected person. In these cases, the informant will have the right to the protection provided for in this law, unless, as a result of the actions carried out in the investigation phase, it is concluded that the information, in view of the information collected, should have been inadmissible due to one of the causes provided for in this Procedure.

Referral to the Public Prosecutor's Office if, despite not initially finding any indications that the facts could constitute a crime, this is clear from the course of the investigation. If the crime affects the financial interests of the European Union, the case will be referred to the European Public Prosecutor's Office.

Transfer of all the proceedings to the competent authority, in accordance with the provisions of this Procedure.

Adoption of an agreement to initiate a sanctioning procedure

Once all the actions have been completed, the System Manager will keep information related to the communication in a Register Book, which will contain:

Date of receipt

Classification of communication

Closing date

The actions carried out

This register will not be public and only at the reasoned request of the competent judicial authority, by means of an order, and within the framework of a judicial procedure and under its supervision, may the content of said register be accessed in whole or in part.

Personal data relating to information received and internal investigations referred to in the previous section will only be kept for the period necessary and proportionate to comply with applicable legislation. In no case may the data be kept for a period longer than ten years.

If the investigation resolution clearly proves that the facts investigated are true and are linked to irregular or illicit conduct, the accused may be subject to sanction in accordance with the applicable Collective Agreement in force, labor legislation and other civil and commercial obligations contracted by the member of the INDUSTRIAS SOMBRERERAS ESPAÑOLAS staff. S.A., management staff or the General Director.

SPANISH HAT INDUSTRIES S.A. It may also bring the facts to the attention of the relevant judicial authorities if it deems it necessary.

In the event that the accused is a third party with whom there is no employment relationship (supplier, commercial agent or business partner), the applicable sanctions will be limited to the commercial sphere (limitation of actions, unilateral termination of contract by INDUSTRIAS SOMBRERERAS ESPAÑOLAS). S.A.), without prejudice to the aforementioned communication to the competent judicial authorities.

5. REPORTING FALSE OR BAD FAITH COMPLAINTS

The whistleblower channel of SPANISH HAT INDUSTRIES S.A. It must be used responsibly and appropriately. The communication of false facts, with a malicious and morally dishonest attitude, constitutes a violation of the good faith that must govern labor and professional relations at INDUSTRIAS SOMBRERERAS ESPAÑOLAS S.A., which may lead to disciplinary measures in accordance with the current Collective Agreement, or of a commercial nature in the case of other stakeholders.

If, after the appropriate analysis, it is concluded that the reported facts are manifestly false and that the complaint has been filed with malicious intent and in bad faith: (i) the complaint will be archived, (ii) this circumstance will be transferred to the Human Resources Department so that disciplinary measures can be proposed in accordance with the Current Collective Agreement and; (iii) the proposed sanction will be reported in writing to the Human Resources Department or, where appropriate, to the General Director, who will decide on the disciplinary action to be applied to the bad faith whistleblower.

6. PROTECTION OF PERSONAL DATA

The processing of personal data arising from the application of the Internal Information System and Whistleblower Defense Policy and this Procedure will be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, in Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, in Organic Law 7/2021, of May 26, on the protection of personal data processed for the purposes of prevention, detection, investigation and prosecution of criminal offenses and the execution of criminal penalties, and in Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption.

Information on the processing of personal data is provided below.

Responsible SPANISH HAT INDUSTRIES S.A.

Purpose Manage, process and investigate communications sent through the Communications Channel, as well as to adopt disciplinary measures or process any procedures that may be required.

Legitimation Compliance with a legal obligation

Recipients Authorities with jurisdiction in the matter.

Rights

All rights recognized in the data protection regulations with the limitations established in Law 2/2023 on the protection of whistleblowers.

You can contact SPANISH HAT INDUSTRIES, S.A. POL. IND. LOS LLANOS. C/CASTILLA LA MANCHA, 202 41909 SALTERAS SEVILLA ES., for the exercise of Rights

Extended information You can obtain further information by contacting https://www.fernandezyroche.com/es/

This document has been approved by the GENERAL DIRECTOR of SPANISH HAT INDUSTRIES S.A. on 01/09/2024.