The Code of Ethics of INDALOBLANC S.L., which was approved by the company’s management body in December 2019, reflects the company’s core values and contains the general principles that must govern the actions of all professionals who are part of it.

Consequently, the Code of Ethics of INDALOBLANC S.L. is a key element in the integrity of our business and represents who we are and how we act as a company, both internally, regarding the company and all its employees, executives, and management body, and externally, in the market and with other competitors. All professionals in the company, regardless of their position in the organization, must be aware of the mission and values outlined in the Code of Ethics, adopt them, and use them as guidelines and conduct standards in their daily activities.

The document is periodically reviewed to incorporate the necessary changes to respond to new internal and external requirements and ensure its continuous improvement.

The company’s management body has also approved a series of policies and protocols aimed at promoting the organization’s actions in accordance with ethics and current regulations in each of the identified risk areas, through a set of procedures and actions designed to prevent, detect, and respond to irregular actions, fraud, or acts contrary to the company’s Code of Ethics or the applicable regulations. These policies and protocols, along with the Code of Ethics, represent the organization’s firm commitment to its professionals, clients, suppliers, competitors, and other stakeholders with whom it interacts, to conduct all its activities in accordance with current laws and regulations, as well as with the highest ethical standards and values.

Furthermore, the company has established a communication and whistleblowing channel, consisting of the email address canaldedenuncias@indaloblanc.com, for use by employees and other stakeholders. This channel aims to fulfill the objectives set out in both the Code of Ethics and the set of internal policies and processes approved within the company.

A secure and anonymous channel is also available for employees and other stakeholders to report any behaviors, actions, omissions, or events that may constitute a criminal or administrative offense or a violation of the company’s Code of Ethics or its internal company rules established in corporate policies and specific action protocols. This applies to actions performed during the professional duties of the person committing the violation or that have an impact on the contractual relationship with clients or suppliers or on the company’s interests and image with third parties.

For the purposes mentioned above, the following PRINCIPLES govern the operation of the whistleblowing channel:

• i. Employees, shareholders, partners, and members of the company’s management body can be whistleblowers or individuals being reported.
• ii. The possibility to report through the internal channel, as well as to the competent authority via existing external channels.
• iii. Communications must meet the criteria of truthfulness and proportionality and may not be used for purposes other than compliance with the law or the company’s internal policies and protocols.
• iv. The whistleblower may choose to report conduct anonymously.
• v. The identity of the whistleblower and the individual being reported, along with the information and data related to the report, will be considered confidential, if applicable.
• vi. It is possible to provide the whistleblower’s and reported person’s data and identity to the administrative or judicial authorities if required as part of any procedure derived from the report, as well as to individuals involved in any subsequent investigation or judicial proceedings. Data sharing will comply with current personal data protection laws.
• vii. The Compliance Committee and specifically the Channel Manager will be responsible for managing communications received through the whistleblowing channel and handling investigations.
• viii. Reports can involve behaviors, actions, omissions, or events that may constitute a criminal or administrative violation or a breach of the company’s Code of Ethics or internal rules, committed during professional duties or with implications for the contractual relationship with clients or suppliers or for the company’s interests and image with third parties.
• ix. An acknowledgment of receipt of the report will be sent to the whistleblower within a maximum of seven (7) days from receipt, unless this would compromise the confidentiality of the communication.
• x. A motivated communication, via email, based on the factual elements provided by the whistleblower, will inform whether the reported matter warrants initiating the procedure, within a maximum of ten (10) days from receipt.
• xi. The maximum response time for actions will be three (3) months from receipt of the communication, extendable by an additional three (3) months if the case is particularly complex.
• xii. The whistleblower may be required to provide additional information or documentation to substantiate the existence of the reported irregular conduct.
• xiii. The person being reported will be informed of the conduct attributed to them and of their rights, and they will have the opportunity to be heard at any time.
• xiv. If applicable, there may be abstention from participating in the process for the individual being reported.
• xv. Data treatment will be in accordance with Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, and Spanish Organic Law 3/2018 of December 5 on Personal Data Protection and the guarantee of digital rights. Access to such data will be limited to the Compliance Committee, the Channel Manager, the HR Department (if disciplinary measures are necessary), the Legal Department (if legal actions are needed), designated data processors, and the Data Protection Officer.
• xvi. The facts will be communicated immediately to the Public Prosecutor’s Office if they constitute a crime.

It is also stated that, in any case and regardless of the above, actions or omissions that may constitute a serious or very serious criminal or administrative offense, as well as actions or omissions that may violate European Union law, may be reported to the Independent Whistleblower Protection Authority (A.A.I.), the relevant regional authorities, and where appropriate, to EU institutions and bodies through their own channels (external to the company).