Ethical Channel

Industrial de Transformados, S.A. reserves the right to modify when required, the Ethical Canal, due to changes in the Corporate Social Responsibility Policy of its property. In such a case, you expect the supplier to agree to such reasonable changes.

The supplier and sub-supplier hereby declare a series of general principles. They stand out among them:

1. Legal compliance

• Comply with the law of the applicable legal systems.

2. Prohibition of corruption and Bribery

• Do not tolerate in any way or be directly or indirectly involved in any act of corruption or bribery and not give, offer or promise anything of value to any person in the public or private sector to influence action and obtain a competitive advantage.

3. Fair Competition, Antitrust Laws and Intellectual Property Rights

• Act in accordance with national and international competition laws and not participate in price fixing, market or customer allocation, market sharing or bid rigging with competitors.
• Respect the intellectual property rights of third parties.

4. Conflicts of interest

• Avoid all conflicts of interest that may negatively influence business relationships.

5. Respect for the basic human rights of employees

• Promote equal opportunities and treatment of its employees regardless of skin color, race, nationality, social status, disability, sexual orientation, political or religious convictions, sex or age.
• Respect the personal dignity, privacy and rights of each individual.
• Refusing to employ or make someone work against their will.
• Refuse to tolerate any unacceptable treatment of employees, such as mental cruelty, sexual harassment, or discrimination.
• Prohibit behavior, including gestures, language, and physical contact, that is sexual, coercive, threatening, abusive, or exploitative.
• Provide fair remuneration and guarantee the applicable national legal minimum wage.
• Comply with the maximum number of working hours established in the applicable laws.
• Recognize, to the extent legally possible, the right of free association of workers and not favor or discriminate against members of workers’ organizations or unions.

6. Prohibition of child labor

• Do not employ workers under 16 years of age (those under 18 years of age cannot perform night work or other limitations according to regulations).

7. Employee health and safety

• Take responsibility for the health and safety of your employees.
• Control risks and take the best preventive measures reasonably possible against accidents and occupational diseases.
• Provide training and ensure employees are educated on health and safety issues.
• Establish or use a reasonable occupational health and safety management system.

8. Environmental protection

• Act in accordance with the legal and international standards applicable to the protection of the environment.
• Carry out its activities in such a way as to minimize negative environmental impacts and comply with the standards established in the applicable environmental regulations. In addition to actively contributing to raising awareness about the effects of climate change.

9. Supply chain

• Make reasonable efforts to promote compliance with this Code of Conduct among its suppliers.
• Comply with the principles of non-discrimination in the selection and treatment of suppliers.

POLICY ON THE INTERNAL INFORMATION SYSTEM AND MANAGEMENT OF THE ETHICS CHANNEL

 

1. Introduction and Purpose

The Internal Information System and Ethics Channel Management Policy demonstrates the commitment of Industrial de Transformados, S.A. to ethical conduct, based on our Code of Ethics and Responsible Practices as defined in our Corporate Social Responsibility (CSR) Policy, as well as the applicable internal and external regulations.

The Internal Information System is a tool designed to promote a culture of communication and transparency for the prevention, detection, and correction of threats to the public interest and regulatory non-compliance.

We encourage all our stakeholders, both internal and external, to report any concerns regarding unethical conduct and/or breaches of applicable regulations (internal and/or external) within the scope of our professional activities, while guaranteeing the protection of whistleblowers against any form of retaliation.

This Policy is governed by the following applicable regulations:

1. Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.
2. Spanish Law 2/2023 of 20 February on the protection of persons reporting regulatory infringements and on combating corruption.

The previous whistleblowing communication channel already existing within the company has been adapted to comply with the provisions of Law 2/2023 and has been renamed the Ethics Channel.

In compliance with Law 2/2023, Industrial de Transformados, S.A. has implemented an Internal Information System consisting of:

1. The Ethics Channel, established as the formal mechanism for reporting irregularities and infringements.
2. The appointed Internal Information System and Ethics Channel Manager.
3. This Internal Information System and Ethics Channel Management Policy.
4. The Internal Information System and Ethics Channel Management Procedure, which develops and implements this Policy.

2. Scope of Application

This Policy applies to Industrial de Transformados, S.A.

Reports, complaints, and information submitted by individuals working in either the private or public sector, who have obtained information within a work-related or professional context, shall be received, processed, and monitored in accordance with Article 3 of Law 2/2023. These individuals include:

a) Public employees and employees under an employment contract.
b) Self-employed individuals.
c) Shareholders, stakeholders, and members of the administrative, management, or supervisory bodies of a company, including non-executive members.
d) Any person working for or under the supervision and direction of contractors, subcontractors, and suppliers.

Through the different channels integrated into the Internal Information System, employees are required, and third parties are encouraged, to report knowledge or reasonable suspicions of irregular conduct, unethical behaviour, and/or serious or very serious breaches of applicable legislation, our Code of Ethics and Responsible Practices, and/or any other internal company regulations.

The following matters may be reported:

a) Any serious or very serious infringement of the principles established in our Code of Ethics and Responsible Practices.

b) Breaches of the Compliance Management System of Industrial de Transformados, S.A., or any internal regulation relating to ethics and compliance.

c) Facts or conduct that may have criminal implications.

d) Serious or very serious administrative infringements.

e) Breaches of labour legislation concerning occupational health and safety.

f) Breaches of European Union law falling within the material scope of Directive (EU) 2019/1937 and the corresponding Spanish implementing legislation.

g) Any other serious or very serious irregularity that could entail liability for Industrial de Transformados, S.A.

The Internal Information System constitutes the preferred channel for reporting such conduct. It is not intended for use by customers.

3. Reporting Channels

We provide various communication channels for our stakeholders in order to promote dialogue and active listening, in line with our culture of open and transparent communication, which forms the foundation of our Internal Information System:

a) Email: canaletico@itsa.es
Any report concerning irregularities may be submitted through this address.

b) In-Person Meeting:
Individuals may communicate concerns verbally by requesting a meeting with the Internal Information System and Ethics Channel Manager.

c) Ethics Channel Mailbox:
A paper-based mailbox is available for both anonymous and identified communications. Correspondence must be submitted in a sealed envelope addressed to the Internal Information System Manager.

The reporting form IMP-160 ETHICS CHANNEL REPORT is available as guidance for whistleblowers when preparing and submitting a report.

d) Postal Mail:

Industrial de Transformados, S.A.
Pol. Ind. “Les Planes Baixes”
C/ de la Vinya s/n
43717 La Bisbal del Penedès (Tarragona), Spain

For the attention of the Internal Information System and Ethics Channel Manager.

e) Harassment Reporting Channel:
rrhh@itsa.es

This channel is established under the Protocol for the Prevention of and Action against Workplace Harassment.

Without prejudice to the use of the internal reporting channels described above and at any time, any natural person belonging to one of the groups entitled to access the Internal Information System may also report directly to the Independent Whistleblower Protection Authority (Autoridad Independiente de Protección del Informante, A.A.I.) or to the corresponding regional authorities.

In Catalonia, the competent authority is the Catalan Anti-Fraud Office (Oficina Antifrau de Catalunya).

The Ethics Channel must not be used to report interpersonal conflicts that exclusively affect the whistleblower and the individuals mentioned in the report, nor for reporting information that is publicly available or based solely on rumours.

4. Principles and Guarantees of the Internal Information System

The Internal Information System is based on the following key principles and commitments:

a) Regulatory Compliance
Legality and corporate ethics are fundamental pillars of the System. Its management shall comply with applicable legislation, this Policy, and the Internal Information System and Ethics Channel Management Procedure.

b) Independence and Impartiality
All actions shall be carried out independently, impartially, and with full respect for applicable legislation and the internal regulations of Industrial de Transformados, S.A. All persons involved in the process shall act in good faith in the pursuit of truth and clarification of the facts.

c) Management of Conflicts of Interest
Industrial de Transformados, S.A. shall ensure the proper management of any conflicts of interest that could affect the integrity of an investigation.

d) Transparency and Accessibility
Information regarding the System and its governance shall be communicated clearly and comprehensively and shall remain publicly accessible.

e) Traceability and Security
The System shall incorporate all measures necessary to ensure the integrity, traceability, monitoring, and security of information.

f) Confidentiality and Anonymity
The System shall guarantee anonymity whenever requested and, in all cases, the strict confidentiality of the whistleblower’s identity, the information reported, and any actions undertaken as part of the handling and investigation process. Anonymous reports shall be accepted.

g) Confidential Handling of Information
Individuals involved in the handling and investigation of reports shall maintain the highest level of discretion regarding any information obtained through their position or role.

h) Respect and Protection of Individuals and Prohibition of Retaliation
The System shall ensure appropriate measures to protect individuals against retaliation and safeguard the dignity and privacy of all persons affected.

i) Data Protection
All investigations and case handling processes shall comply with applicable data protection legislation and respect the rights of all individuals involved.

j) Good Faith
All information provided must be truthful and submitted in good faith. Information that is false, misleading, or knowingly inaccurate may result in disciplinary measures.

k) Respect for Fundamental Rights
The System guarantees the right to information, the right of defence, the right to be heard, the presumption of innocence, and the protection of personal honour for all individuals involved in the process.

The person concerned has the right to be informed of the acts or omissions attributed to them and to be heard at any stage of the proceedings, in a manner that does not jeopardise the effectiveness of the investigation.

5. Internal Information System Manager

The Sole Director shall appoint the Internal Information System and Ethics Channel Manager of Industrial de Transformados, S.A.

The Internal Information System and Ethics Channel Manager shall perform their duties with full autonomy and independence from any other corporate body of Industrial de Transformados, S.A., shall not receive instructions of any kind regarding the performance of their functions, and shall be provided with all necessary human and material resources.

The Manager shall report annually, and whenever required, to the Company’s Management Committee on the activities of the Internal Information System and the Ethics Channel, while always preserving confidentiality, anonymity, information security, and all other guarantees and rights established by this Policy and Law 2/2023.

6. Publication and Communication

This Policy was approved by the Sole Director on 30 November 2023 and entered into force on the same date.

In accordance with international standards and transparency best practices, this Policy shall be made available to all stakeholders through the website of Industrial de Transformados, S.A.

Likewise, the Policy shall be communicated and disseminated internally through existing communication tools to ensure its understanding and application by all persons acting on behalf of Industrial de Transformados, S.A.

This Policy shall be reviewed, updated, approved, and communicated periodically, and whenever necessary to incorporate any amendments.