Ethics Channel

Corporate Integrity Policy and Internal Information System

EMPRESAS MASET
Web Document – 02/28/2022

1. Declaration of the Corporate Integrity Policy

Applies to:

AGRUPACIÓ VITICULTORS ARTESANALS, SL

VINOS ARTESANALES DE CALIDAD, SL

TELEMARKETING MASET, SL

CANA 99, SL

Maset Companies (hereinafter, “the Company”) are committed to a culture of regulatory compliance, good governance, and ethical and responsible management. This culture permeates both the internal sphere and relationships with clients, suppliers, competitors, partners, public authorities, and society at large.

By adopting this Corporate Integrity Policy and the Ethics Channel, a system is established to communicate, prevent, and, if necessary, manage potential perceived or actual irregularities, breaches, or criminal, administrative, or labor law offenses.

2. Internal channels for reporting irregularities or breaches

External interested parties (clients, suppliers, third-party companies) are encouraged to first use the direct communication channels with the Company. If these prove ineffective, the Ethics Channel may be used following the established procedure.

3. Internal Information System and Ethics Channel

This system complies with current regulations and provides a mechanism so that any interested person (section 5) can report irregularities, with a guarantee of confidentiality and protection from retaliation. The system manager will act independently and will be appointed by the administration body.

4. Definition of irregularity, breach, and offense

4.A. Irregularity / Breach:
Unethical conduct such as:

breach of internal protocols, codes of conduct, or confidentiality commitments,

violations regarding data protection or harassment prevention,

administrative, technical, or accounting errors.

4.B. Offense:

Actions or omissions that violate current administrative or criminal legislation.

Violations of European Union Law, included in the annex of the corresponding Directive.

Attempts to hide any of the aforementioned behaviors.

5. Ethics Channel users

A) Internal scope:
Employees or self-employed individuals providing services to the Company.

B) External scope:
Clients, suppliers, subcontractors, or external persons not part of the company.

6. Submission of communications

Communications must be in writing and contain as much information as possible. Anonymous communications are also accepted, provided they are sufficiently detailed.

Guideline information to include:

Company and job title

First and last name of the informant

Address or email address

Date and status of the facts

Involved persons

Available evidence

Whether it has been previously reported internally or to external authorities

Other relevant data

Communication channels:

Postal mail: For the attention of the Ethics Channel Manager at each company’s address.

Email: canaletico@maset.com

A face-to-face meeting may also be requested (which will be recorded), to be held within a maximum of 7 days.

7. Guarantees and protection measures

The procedure will guarantee:

Confidentiality

Data protection

Prohibition of retaliation

Right to be heard

Presumption of innocence and other rights of those affected

8. Management procedure for received communications

The manager will acknowledge receipt within a maximum of 7 calendar days (unless it jeopardizes confidentiality).

The communication will be evaluated within 1 month to be accepted or rejected with justification.

The investigation must conclude within a maximum of 3 months, extendable to 6 months in complex cases.

Approval: This policy, the information system, the Ethics Channel, and the management procedure were approved on June 12, 2023, by the administration body of each of the companies.