Whistleblower channel

ETHICAL AND TRANSPARENCY COMMITMENT

Distributions Túnel (formerly, Wineries Túnel) and all its corporate structure (hereinafter, “TÚNEL GROUP” or “Túnel and its companies”), through what was agreed by its Board of Directors, promoted in 2018 the approval of a Crime Prevention model with which it intends to remain at the forefront of Good Corporate Governance and take a further step in the Corporation's commitment to continuous improvement to position itself, at all times, at the highest standards in terms of integrity and professionalism in the performance of its activity.

This Channel ensures anonymous communication of complaints filed.

The purpose of this Channel is to enable any person or organisation to report and/or communicate any possible irregular, unethical or inappropriate conduct by any person who is employed, represents or participates in any way with the TÚNEL GROUP. In this regard, it encourages its employees, clients, users, suppliers or any person who has contact with our services to communicate with us and send us their suggestions, complaints or any indication that may be useful to us.

We would appreciate it if you could provide us with any details you may have (dates, names, places, etc.) that could help us in a possible internal investigation process, in order to obtain the maximum credible evidence.

CONTACT DETAILS

Complaints may be made anonymously. However, in order to carry out appropriate follow-up, contact information will be requested from the reporting person, and it is up to the person to decide whether to provide it or to make the report anonymously.

Communication form

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Category

Type

Fact reported

Full name

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Acceptance of Privacy Policies

I agree that my data will be processed in accordance with Spanish regulations on the protection of personal data. Privacy Policy)

CONFIDENTIALITY

The professionals of Túnel and their companies that, by virtue of receiving, managing, and processing the complaint, have access to the complainant's data and/or any other information, will maintain the utmost confidentiality and confidentiality regarding the identity of the complainant and any other type of evidence and/or documents provided throughout the process.

Likewise, all persons who make a complaint in good faith are guaranteed that GRUPO TÚNEL will not be able, either during the investigation or once it has been completed, to adopt any measure that may be detrimental to their professional career or that may lead to the termination of their employment or professional relationship with the company, if applicable. In any case, the protection of the person who makes a complaint will not exempt them from any liability that they may have incurred for acts other than those that constitute the subject of the complaint.

Complainants who file complaints in bad faith, knowing that they are false or with the sole intention of undermining the reputation or prestige of GRUPO TÚNEL or any of its professionals, will be subject to the sanctions provided for in the Company's disciplinary regime, which includes the dismissal of the employee, if applicable, without prejudice to any sanctions that may have been incurred by law.

WHAT CAN I REPORT THROUGH THIS CHANNEL?

In general, you can report the possible commission of a crime or any breach that goes against the Code of Ethics or internal regulations of the organization. For example, and by way of example but not exhaustive:
Actions related to suppliers: Non-compliance with market procedures related to supplier selection.
Harassment: Abusive, hostile or offensive behavior.
Discrimination: Discriminatory practices based on culture, political ideas, religious beliefs, race or other reasons.
Restriction of freedom of expression, trade union association or collective bargaining.
Misappropriation and misappropriation of resources.
Fraudulent appropriation of Company property for personal use or with the intention of making a profit.
Accounting aspects: Recording commercial and/or financial transactions in a manner contrary to generally accepted accounting practices.
Conflict of interest: Putting one's own interest before that of the Company through incorrect actions in the exercise of professional obligations.
Unethical Conduct: Unethical or dishonest conduct by any employee, at any level of the organization.
Commitments to third parties (clients/suppliers): Non-compliance with agreements signed with third parties.
Falsification of documents: Modifying contracts, reports or documents for personal benefit or with the aim of causing harm to the organization.
Information security: Unauthorized use of the Company's, its clients' or suppliers' information.

PRIVACY POLICY

The design and development of the Whistleblowing Channel has been carried out taking into account the Spanish regulations on the protection of personal data, as well as the reports of the data protection authorities in Spain and the European Union. In particular, legal report 0128/2007 of the Spanish Data Protection Agency (hereinafter, AEPD) entitled “Creation of Internal Whistleblowing Systems in Companies (Whistleblowing Mechanisms)”.

In accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, and with Organic Law 3/2018, of 5 December, on the protection of personal data and the guarantee of digital rights, we inform you that by "Sending" any information through the forms of the Complaints Channel, you will be providing, by an explicit act, your consent for your data to be processed by GRUPO TÚNEL for the sole and exclusive purpose of processing and managing the corresponding complaint.

We also inform you that you can exercise your rights of access, rectification, cancellation, opposition and limitation of processing or portability by sending a request to the address of GRUPO TÚNEL, specifying that it is for the attention of the "Data Protection Officer of the Whistleblowing Channel", attaching a copy of your ID or passport.

Personal data obtained in the context of an internal investigation will be deleted when they are no longer necessary and relevant and, in any case, within a maximum period of three (3) months from the date the complaint is registered, unless the investigation is still ongoing. Personal data relating to complaints that are not the subject of an investigation will be deleted without delay.

You also declare that you have been informed of your right to file a claim with the Control Authority, the AEPD. Prior to any possible claim with the AEPD, you may contact our Data Protection Department and we will satisfy your claim.