1. Introduction to the Whistleblowing Channel.
The prestige and reputation of LABORATORIOS PRADY NORMAPIEL, S.L are the result of many years of effort and work by each and every person who makes up the company. However, the truth is that inappropriate behavior by a single employee can damage its image. For this reason, LABORATORIOS PRADY NORMAPIEL, S.L actively works to prevent and avoid this possibility.

Thus, among other matters, all employees and collaborators acting in the name and/or on behalf of LABORATORIOS PRADY NORMAPIEL, S.L are required to act in compliance with current legislation and internal policies and procedures at all times. In this preventive effort, the cooperation of all employees is also of great importance in detecting possible irregular conduct.

In this regard, Law 2/2023, of February 20, regulating the protection of individuals who report regulatory infringements and combating corruption, reinforces the need for companies to have control systems and mechanisms that allow them to prevent, detect, and respond to the risk of crimes being committed within a company by any of its members. For the effectiveness of these prevention models, the Whistleblowing Channel plays a fundamental role, allowing members to report potential risks and breaches.

With the above in mind, this Policy describes all matters related to the operation of the Whistleblowing Channel of LABORATORIOS PRADY NORMAPIEL, S.L: who can file a report, against whom, in which situations, and, above all, what steps will be followed when a report is received. All of this, of course, subject to the strictest confidentiality.

All members of LABORATORIOS PRADY NORMAPIEL, S.L will be aware of this tool, undoubtedly of great value and usefulness for collectively preserving and protecting its image, prestige, and reputation.

2. Users of the Whistleblowing Channel

The Whistleblowing Channel is aimed at all professionals of LABORATORIOS PRADY NORMAPIEL, S.L who have or may have knowledge of an irregularity committed by any other professional.

2.1. Who must report through the Whistleblowing Channel?

All employees, managers, external collaborators (agents, subcontractors or other third parties acting under the authority of LABORATORIOS PRADY NORMAPIEL, S.L) and all clients and suppliers of LABORATORIOS PRADY NORMAPIEL, S.L must report, through the Whistleblowing Channel, any irregularity they are aware of that falls within its scope, without fear of dismissal or any other type of retaliation, and with the assurance that it will be handled with the strictest confidentiality.

2.2. Who can be reported through the Whistleblowing Channel?

All employees, managers, or external collaborators of LABORATORIOS PRADY NORMAPIEL, S.L under its authority who have committed any irregularity or conduct detailed in Annex I of this document may be reported. Likewise, any conduct contrary to the principles and rules of conduct established by LABORATORIOS PRADY NORMAPIEL, S.L may also be reported through this Channel.

3. Means for receiving reports

The Company Manager will appoint the Head of the Whistleblowing Channel. Both their appointment and dismissal will be notified to the Independent Authority for Whistleblower Protection, A.A.I., or, where appropriate, to the competent authorities or bodies of the autonomous communities within their respective jurisdictions, within ten working days, specifying, in the case of dismissal, the reasons justifying it. All reports must be submitted to the Head of the Whistleblowing Channel and may be made in writing or verbally, with the reporting party able to choose any of the available channels:

By email, at canal.denuncias@laboratoriosprady.com.
By post, addressed to the Head of the Whistleblowing Channel, P.O. Box 96, 30562, Ceutí (Murcia).
By phone, at 663987381.
For written reports, the reporting party will complete the report form (Annex II), which will be available on the corporate website (https://laboratoriosprady.com/).

In the case of verbal reports, the Head of the Whistleblowing Channel will transcribe the report verbatim or record it, with the prior authorization of the reporting party. Reporters may identify themselves when making the report or remain anonymous. However, throughout the procedure, confidentiality regarding the identity of the reporting party will be guaranteed, in compliance with the requirements established in data protection regulations. Privacy is one of the most relevant aspects in the operation of the Channel. For this reason, all individuals who may be involved at any point in a potential report will be subject to the strictest obligation of confidentiality and professional secrecy.

4. Protection measures for the reporting party

4.1. Prohibition of retaliation

Individuals who submit any type of report in accordance with this Policy and in good faith are protected against any type of retaliation, discrimination, or penalty as a result. A reporting party who believes that retaliation has been taken against them as a consequence of submitting a report may notify the competent authority. The prohibition of retaliation set out above will not prevent the adoption of appropriate disciplinary measures when the internal investigation determines that the report is false and that the person who submitted it was aware of its falsity and acted in bad faith.

4.2. Confidentiality of the reporting party’s identity

LABORATORIOS PRADY NORMAPIEL, S.L guarantees maximum confidentiality regarding the identity of the reporting party. As a measure to ensure such confidentiality, it is expressly stated that the exercise of the right of access by the reported party will not include access to data relating to the identity of the reporting party. Consequently, and unless judicially determined otherwise, LABORATORIOS PRADY NORMAPIEL, S.L will not disclose the identity of the reporting party to the reported party. This principle of confidentiality is one of the basic pillars of the Whistleblowing Channel, whose proper functioning depends on guaranteeing reporters that their identities will be protected, so as not to discourage reporting. Likewise, the Head of the Whistleblowing Channel is obliged to maintain professional secrecy regarding the identity of the reporting party. If, exceptionally, any external advisor or another member of LABORATORIOS PRADY NORMAPIEL, S.L participates in the investigation of the facts, they will be subject to the same obligation of confidentiality and professional secrecy.

4.3. Measures in situations of conflict of interest

If the reported facts fall within the scope of the duties of the Head of the Whistleblowing Channel, they must refrain from intervening in the report processing procedure, as a conflict of interest will be deemed to exist, potentially limiting their ability to handle and investigate reports with due objectivity, neutrality, and impartiality. This conflict may also arise when the facts affect a person with whom they have family ties or a business interest. As a result, if the reporting party suspects that the facts may involve a conflict of interest with the Head of the Whistleblowing Channel, they may submit the report directly to the Company Manager, who may temporarily appoint another person as Head of the Whistleblowing Channel.

5. Report processing procedure

5.1. Receipt of reports

All reports submitted will be received by the Head of the Whistleblowing Channel, who will carry out a preliminary analysis of the reported facts and their compliance with the established form. After this, they will decide whether to initiate the corresponding investigation or reject the report, in accordance with this Policy, within a maximum period of ten working days from receipt.

a) Rejection of the report: if the report does not meet the formal requirements established herein, or it is evident that the reported facts do not constitute an infringement, the Head of the Whistleblowing Channel will reject it.

b) Acceptance of the report and initiation of the investigation phase: when the report meets the formal requirements and the reported facts fall within the scope of the Whistleblowing Channel, with indications that they have occurred, the Head of the Whistleblowing Channel will decide to accept it.

After completing the above steps, the decision adopted by the Head of the Whistleblowing Channel at this stage will be communicated to the reporting party with acknowledgment of receipt within a maximum of seven working days.

5.2. Investigation of the reported facts

Once the report has been accepted, the Head of the Whistleblowing Channel will initiate the appropriate investigations to verify the accuracy of the reported facts. To this end, they may request any information and documentation deemed necessary to clarify the reported facts.

5.3. Proposed resolution

A response to the investigative actions will be provided within a maximum period of three months. Once the investigation is completed, two actions will be carried out:

• First, the Head of the Whistleblowing Channel will report the results to Management, submitting a proposed resolution.
• After this, and in light of the report, Management will adopt the decision it deems appropriate, ordering the closure of the report and the actions taken when the reported facts have not been sufficiently substantiated or do not constitute an infringement within the scope of the Whistleblowing Channel. Conversely, if it considers that the reported facts have been sufficiently proven and constitute an infringement within the scope of the Channel, it will issue a reasoned resolution indicating the legal measures to be adopted.

When the facts may constitute a criminal offense, the information will be immediately forwarded to the Public Prosecutor’s Office. If the facts affect the financial interests of the European Union, they will be forwarded to the European Public Prosecutor’s Office.

5.4. تنفيذ of the sanction

The Company Manager will be responsible for applying the agreed sanction or disciplinary measures.

6. External whistleblowing channel

Any employee of LABORATORIOS PRADY NORMAPIEL, S.L may report to the Independent Authority for Whistleblower Protection, A.A.I., or to the corresponding regional authorities or bodies, any actions or omissions included within the scope of Law 2/2023 of February 20. Reports may be made in writing, by post or through any electronic means enabled for this purpose directed to the external reporting channel of the Independent Authority for Whistleblower Protection, A.A.I., or verbally by telephone or voice messaging system. The reporting party may also request an in-person meeting within a maximum period of seven days. Once the A.A.I. is established and/or the corresponding regional authority is designated, the company will inform all staff of the specific external reporting channels: phone number, email, address…

7. Personal data protection

When designing this Channel, LABORATORIOS PRADY NORMAPIEL, S.L.U. fully complies with applicable data protection regulations. Personal data collected within the framework of the Whistleblowing Channel will be processed exclusively for the purpose of handling received reports and, where appropriate, investigating the accuracy of the reported facts. Data collected that lead to the opening of an investigation will be included in the “Whistleblowing Channel” file, duly declared to the Spanish Data Protection Agency. The controller of this file is LABORATORIOS PRADY NORMAPIEL, S.L

However, it is expressly stated that data contained in reports that are not admitted will not be incorporated into any file and will be immediately deleted. Both the reporting party and the reported party will be duly informed, in each case, of the specific persons and bodies to whom their data will be communicated, in accordance with this policy.

The personal data collected within the Whistleblowing Channel:

• ✓ will be limited to what is strictly and objectively necessary to process reports and, where appropriate, verify the reported facts;
• ✓ will be processed at all times in accordance with applicable data protection regulations, for legitimate and specific purposes related to any investigation arising from the report;
• ✓ will not be used for incompatible purposes;
• ✓ will be adequate and not excessive in relation to the stated purposes.

LABORATORIOS PRADY NORMAPIEL, S.L will ensure that all necessary technical and organizational measures are adopted to safeguard the security of the collected data, in order to protect them from unauthorized disclosure or access.