The ethical channel is a confidential and, if you so decide, anonymous means of communication so that you can inform us about breaches of the rules established in Clikalia, as well as about those behaviors contrary to the legality or the applicable regulations in force.

It is a channel open to all those people in good faith who want to communicate facts that may contravene our internal rules or criminal law, that is, customers, suppliers, advisors / consultants, employees, ex-employees, or any other person related to Clikalia.

Through the channel you can report the following behaviors:

• Prevention of money laundering

• Consumer protection

• Equality

• Failure to comply with current legislation

• Non-compliance with internal regulations

• Harassment

• Discrimination

• Other

If you want to report other types of situations for which there is a specific complaint procedure, please use the channel established for this purpose.

The Ethics Channel is managed by the Compliance Department who is responsible for receiving complaints and to decide on the appropriateness of opening an internal investigation file. The Clikalia Ethics Committee is responsible for carrying out the corresponding investigations and the resolution of the file.

Once your communication is received, it will be studied by those responsible for the management of the Channel confidentially (in case you decide to identify yourself) or anonymously (if you have selected it) and you will be informed of the decision taken.

The Ethics Committee will communicate the acceptance of the complaint/consultation within a maximum period of 7 days. The period for resolving queries will be a maximum of 90 days, unless the complexity of the case requires a longer period in a justified manner.

It is strictly forbidden to adopt retaliation or sanctioning measures against any person who, in good faith, denounces through the Ethical Channel the breaches of which they are aware.

The protection and confidentiality of the identity of the informant, as well as of any third party mentioned in the communication, is guaranteed. The identity of the reporting person may not be disclosed without his or her express consent to any person other than a miembro authorized by the competent personnel to receive or follow up on complaints.

Yes, Clikalia has a Code of Ethics approved by the Management Body in July 2022.

In the reporting process you can decide whether to report your personal data or not. If you choose not to do so, the report will be anonymous, so the channel will not store your personal data or contact information. To be able to access the Channel and You can only follow up on your report using the report code provided by the Channel and the access code provided during the reporting process.

Some tips to achieve maximum anonymity, in addition to informing that the report is anonymous:

• Make sure that the description of the communication or the documents you provide do not include information with which it is easy to identify yourself.

• Do not report from a computer connected to the company network, including a mobile phone connected to the corporate Wi-Fi.

Clikalia does not record information, but before reaching our systems it must go through the control systems themselves such as proxies or firewalls and there may be configurations that allow us to know which services it connects to.

You can use the open-source TOR browser, which anonymizes the IP address.

For security reasons, only the informant knows his access code and password. If you lose any of them, you will not be able to track the communication, that does not mean that the communication does not follow its course, simply that you will not be able to see how it progresses, nor provide more information if the company requires it. Please save your password and code in a secure place.

The personal data that you provide us as a user of the Channel or that you provide to us from third parties (for example, witnesses) will be treated in accordance with the Privacy Policy that you will find in the complaint process. All those who access this channel and participate in the management of communications are subject to the duty of secrecy and confidentiality.