1. Purpose

This document outlines the Procedure for managing communications received through the Internal Information Channel of INTELLIGENT CUSTOMER ACQUISITION SLU, or any other subsidiaries of the group (hereinafter referred to as «Convertia»).

2. Channel Instructor

The Instructor of the Internal Information Channel will be responsible for its proper functioning.

Functions:

  1. Receive communications made through the Internal Information Channel.
  2. Analyze the communications and determine whether they are admissible to initiate an investigation process.
  3. Keep records in the Register Book.
  4. Develop proposed measures to address and resolve the issue, and present them to the Head of the SII.
  5. Send communications within the same Channel to respond to the informant.
  6. Prepare an annual report that must include:
    • Number of communications received
    • Number of communications resolved
    • Number of inadmissible communications
    • Types of communications received
      This report will be presented to the Company’s Management on December 1st each year.
  7. In the event of a conflict of interest, the Head of the SII will designate another Instructor to conduct the procedure objectively.

3. Sending Communications through the Internal Information Channel

Communications to Convertia’s Internal Information Channel can be made:

  1. Using the Internal Information Channel application, available on Convertia’s website https://www.convertia.com/en. Communications can be made in writing or verbally.
  2. At the informant’s request, the communication can be presented in a face-to-face meeting, with the understanding that:
    • They will be recorded in a secure and durable format.
    • The Instructor will make an exact transcription of what the informant communicated, and both parties must sign this document.
    • This will be done within a maximum period of five business days.

The Informant will decide whether to remain anonymous using any of the aforementioned methods or may choose to provide their name, phone number, and email address. However, they must indicate that they wish to be notified through any of these telematic means; otherwise, all communications will be managed within the Internal Information Channel itself.

4. Acknowledgment of Receipt and Registration

Written communications must be integrated into the Internal Information Channel once they are known to the Instructor. Upon receiving the communication through any of the means mentioned in Section 3, the Instructor must issue an acknowledgment of receipt within a maximum of five business days, with the following exceptions:

  1. If the confidentiality of the communication is compromised.
  2. If the communication is anonymous and not made within the SII.
  3. If the informant has explicitly renounced receiving notifications related to the investigation process.

Within the aforementioned period, the Instructor must add the communication to the Communications Register Book.

5. Admission of Communication

  1. The Instructor of the Internal Information Channel must verify whether the communication is admissible by conducting an objective analysis. This must be done within a maximum period of ten business days, counted from the date the acknowledgment of receipt is issued, excluding communications made anonymously and/or when the informant has renounced their right to be notified.
  2. The inadmissibility of the communication will adhere to the criteria established in the SII Policy.The Instructor of the Internal Information Channel will notify the resolution of inadmissibility within a maximum of ten business days from the date the acknowledgment of receipt is issued, explaining the reasons for the decision, excluding communications made anonymously and/or when the informant has renounced their right to be notified.
  3. Circumstances for the Instructor Not to Rule:
    1. If the Instructor has a conflict of interest regarding the received communication, the Head of the SII will have five days to designate a new Instructor to conduct the investigation of the communication.
    2. If the Instructor is uncertain about the admissibility of the communication, they may extend the response period to the Informant by five business days, with the obligation to provide a coherent response and clarify the points communicated by the Informant.

6. Instruction

Once the communication is admitted, the Instructor will begin the investigation process in accordance with the guidelines and principles established in the SII Policy.

The principle of hearing all involved parties and witnesses will be applied. The Instructor will carry out all necessary diligences deemed necessary. All employees and executives of Convertia are obligated to collaborate truthfully and confidentially during the investigation process.

The Instructor will have a maximum period of thirty business days from the admission communication to the Informant to issue a resolution. This period may be extended when there are justified circumstances based on the complexity or the number of diligences to be conducted.

In no communication will the identity of the Informant be disclosed to the involved parties, nor will access be given to the received communication. The affected person, in order to guarantee their right to defense, may submit written statements and may have access to the created file without revealing information that could identify the Informant.

Human Resources will provide support when disciplinary measures need to be adopted in accordance with Convertia’s internal regulations.

7. Resolution

The Instructor will have 15 business days to present the resolution proposal to the Head of the SII. This proposal must include:

  1. Details of the actions taken to verify the truthfulness of the communication.
  2. Conclusions based on the diligences and existing evidence.
  3. The Head of the SII will have a maximum period of ten business days to issue the resolution to the Informant and must add it to the file. If judicial authority intervention is necessary, the resolution will be reported to the Board of Directors to initiate the necessary pertinent actions.
    • If the resolution demonstrates falsehood in the communication made by the Informant, it will indicate the administrative sanction to be adopted, which must be notified to the Human Resources department for implementation.
    • If the resolution affects a shareholder or a member of the Board of Directors, the resolution must be communicated to the Board of Directors, adding the applicable sanctions in accordance with Convertia’s Code of Ethics and Conduct, which must be applied immediately.

Even if the Informant decides to communicate anonymously, the communication will be made within the Internal Information Channel within the established deadlines. The communication should not exceed a period of three months from the date the acknowledgment of receipt was issued. The exception to extend this period will be the complexity of the matter, and it may be extended by another three months, provided that written authorization from the Head of the SII is obtained.

8. Personal Data Protection

In accordance with the provisions of the personal data protection regulations, all interested parties are informed that the data collected in the SII will be processed by INTELLIGENT CUSTOMER ACQUISITION SLU acting as the data controller.

The purpose of the processing is outlined in this document. Users may exercise their rights of access, rectification, deletion, opposition, and limitation of processing regarding their personal data at any time by communicating via email to info@convertia.com indicating their intention to exercise these rights. The personal data to be processed may have been provided by the interested party or third parties.

The Head of the SII will ensure:

  1. The informant’s information will be kept confidential at all times unless requested by a competent judicial authority.
  2. No additional data will be obtained beyond what is necessary for the SII.
  3. The personal data collected by the SII will not be used for purposes other than those outlined in this document.
  4. Data will be processed for the duration specified in the applicable legislation within the European Union.
  5. Necessary security measures will be established to protect the information from unauthorized processing by the Informant, as well as to maintain confidentiality.

It is informed that the only third party outside the SII who may access personal data will be the Human Resources department when disciplinary measures need to be applied.

Preparation Date: November 30, 2023

Implementation Date: December 4, 2023