What is the Whistleblowing Policy?

This policy sets out the framework by which individuals can report, in conditions of confidentiality or anonymity, breaches of the law, internal rules or ethical standards within MARYMANTES SPEED SRL. The policy is aligned with Law no. 361/2022, which transposes Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.

The policy applies to all employees, former and future employees, temporary workers, contractors, suppliers, business partners, persons working under the supervision of contractors or suppliers, third parties and legal entities connected to the reporting person.

Why do we use the reporting mechanism?

The company encourages the early reporting of irregularities to protect the integrity, safety, compliance and reputation of the organisation, and to ensure the prompt remediation of non-compliant situations.

The objectives are: to encourage good-faith reporting, to establish a clear process for submitting and managing reports, to protect reporting persons against retaliation and to ensure confidentiality.

What situations can be reported?

• Bribery, corruption, conflict of interest, anti-competitive practices, harassment and discrimination
• Accounting, auditing or public reporting issues
• Violations of human rights or competition law
• Conduct that damages the company’s reputation
• Breaches of health and safety at work
• Environmental damage
• Money laundering or breach of sanctions
• Non-compliance with product safety and conformity
• Privacy, data protection or IT systems and network security violations
• Consumer protection law breaches
• Any other criminal activity or breach of legal obligations

Customer complaints about the quality of services or products are managed by the relevant departments and are not covered by this policy.

Reporting channels

Reports can be submitted confidentially or anonymously through the following internal channels:

• Web platform: https://marymantesgroup.whistleblowup.com
• Email: conformitate@marymantesgroup.com
• In person, verbally or in writing, to a member of the Designated Team: HR Director, Legal Manager, Internal Audit Manager

If a verbal report is made to a designated person, a written record will be prepared on a durable medium with the reporter’s consent. Without consent for transcription/recording, the report must be submitted in writing, electronically, to the above-mentioned email address.

Minimum content of a report

• Name, contact details and professional context in which the information was obtained (if not anonymous)
• Name of the person(s) concerned, if known
• Detailed description and documentation of the facts, sequence of events and how they became known
• Date, place and people involved, as well as witnesses or others who may provide further information
• Supporting documents or references that can verify the facts

Reports may also be submitted anonymously in writing, electronically, to the dedicated email address.

Managing reports and deadlines

Acknowledgement of receipt will be sent within 7 days. Feedback on the status of resolution will be communicated within 3 months from the acknowledgement or, if no acknowledgement was sent, within 3 months after the 7-day deadline following submission. If the necessary measures are still being determined, this will be communicated to the reporting person.

Exception: feedback may be delayed if informing the reporter could jeopardise the resolution process.

Confidentiality and anonymity

Only the Designated Team has access to reports. The identity of the reporting person and any identifying information will remain confidential throughout the process, within the limits of the law. A unique report identification code may be allocated to allow follow-up communication and status updates.

No retaliation

Any form of retaliation against those who report in good faith or cooperate in investigations is strictly prohibited. Breaches of this prohibition will result in disciplinary measures, which may lead to termination of employment. Protection also extends to family members and entities linked to the reporting person.

Good faith and responsibility in reporting

The reporting person must have reasonable grounds to believe that the information is true and falls under this policy. Reports made in bad faith or containing deliberately false information will be treated as a serious offence and may result in disciplinary or legal consequences.

Investigation

All reports will be investigated promptly, objectively and with confidentiality. Where employees are involved, the HR Department will participate in the investigation. At the end, a summary report with conclusions and an action plan will be prepared and shared with the management of relevant departments.

Closing internal reports

• The report does not contain the minimum required information, a 15-day completion request was made and not fulfilled
• An anonymous report does not contain sufficient information for review, a 15-day completion request was made and not fulfilled
• Multiple reports on the same matter are consolidated; without additional relevant information, subsequent reports are closed
• The designated person may close the procedure in cases of clearly minor breaches, respecting confidentiality and informing obligations

Record keeping

All information related to a report will be kept for 5 years from the date of the solution communication, in a register maintained in accordance with the law, with appropriate IT security and access control measures. After this period, the data will be destroyed regardless of medium.

Step-by-step reporting

• Assess if the issue can be resolved with your direct manager or HR; otherwise use the reporting channels
• Select the channel: web platform, email or in person
• Include the minimum required information for verification
• Keep the identification code (if assigned) for follow-up communication
• Receive acknowledgement within 7 days and feedback within 3 months

Revisions and entry into force

The policy is approved by the General Director and published on the website, on internal communication channels and displayed at company headquarters in a visible and accessible place. Any revisions will be communicated in the same way.

Effective date: 01.09.2025.

WHAT ARE COOKIES?

Cookies are files that contain small amounts of information that are downloaded to the user’s device when visiting a website, associating only with an anonymous user and their computer and do not provide evidence that allows access to the user’s personal data.

You can also view our website without cookies. Internet browsers are regularly set to accept cookies. To prevent the use of cookies in your Internet browser, you can disable the use of cookies through your Internet browser settings and delete already set cookies. The help functions of your Internet browser indicate how to disable and delete cookies from your browser. Please note that disabling/deleting cookies may cause individual functions of our website to stop working as expected. Additionally, disabling/deleting cookies only affects the Internet browser you are using at that time. For other Internet browsers, disabling/deleting cookies must be done again. Cookies, which may be necessary for certain functions of our website, are listed below.

WHY DO WE USE COOKIES?

We use cookies not only for our interest but also to improve the operation of our website and to provide you with the best browsing experience.

Specifically, the Owner is using Cookies for the purposes set out below. If in the future the Owner were to use other Cookies for the purpose of providing more and better services, the user will be informed of this. The installation of these cookies on the user’s device will always occur after obtaining consent and/or configuring them.

Types of cookies used

Cookies according to the time they remain active

Session Cookies

• For the proper functioning of our websites, we use session cookies that we store on your device when you visit our website – regardless of whether you accept cookies in the banner or not – and that are always automatically deleted when you close the Internet browser (i.e., when you close the program). This allows us to offer you various functions on our website using cookie information.

Persistent Cookies

• Persistent cookies are cookies that remain stored on your device even after you have closed your Internet browser. We use the information contained in these cookies to provide you with convenient functions on our website (e.g., to save certain user preferences or for search or language settings), but also to collect your usage behavior on our website and use this information to improve it (e.g., to detect errors) and personalize the advertising we show you.

Cookies according to the entity that manages them

Own Cookies

Third-party Cookies

Cookies by purpose

Technical Cookies

Preference or Customization Cookies

Analysis or Measurement Cookies

Behavioural Advertising Cookies

Below, we explain in detail which technologies and providers we use to analyse your user behaviour:

How to avoid cookies?

Users are provided with information that allows them to configure their Internet browser(s) to maintain their privacy and security in relation to Cookies. Therefore, information and links to the official support sites of the main browsers are provided so that each user can decide whether or not to accept the use of Cookies.

Thus, it is possible to block Cookies through the browser configuration tools, or each user can configure their browser to notify them when a server wants to save a Cookie:

• If you use Microsoft Internet Explorer, you will find the option in the Tools > Internet Options > Privacy > Settings menu. To learn more, visit this link: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-Cookies and http://windows.microsoft.com/en-us/windows7/how-to-manage-Cookies-in-internet-explorer-9.
• If you use Firefox, you will find the option in the Tools > Options > Privacy > Cookies menu. To learn more, visit this link: http://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences.
• If you use Chrome, in the Options > Advanced Options > Privacy section. To learn more, visit this link: https://support.google.com/accounts/answer/61416?hl=en.
• If you use Opera, in the Security and Privacy option, you can configure the browser. To learn more, visit: this link: http://help.opera.com/Windows/11.50/en/cookies.html
• If you use Safari, you will find the option in the Preferences/Privacy menu. To learn more, visit this link: http://support.apple.com/kb/HT1677?viewlocale=en_US

Can modifications to the Cookie Policy occur?

This Cookie Policy could be modified depending on legislative, regulatory requirements, or with the purpose of adapting said policy to the instructions issued by the Spanish Data Protection Agency; therefore, users are advised to visit it periodically. When significant changes are made to this Cookie Policy, they will be communicated to users either through this website or via email.