Welcome and scope of the Law

We welcome you to our internal reporting system for the communication of information obtained in an employment or professional context with Micro Segur, S.L., (hereinafter, MICROSEGUR). Through this system, you can report breaches of European Union Law, as well as actions or omissions that may constitute a serious or very serious criminal or administrative offence, according to Law 2/2023 of 20 February (Spanish legislation), regulating the protection of persons who report regulatory breaches and the fight against corruption.

How the notifier may act

MICROSEGUR’s internal channel allows you to submit information in writing, verbally, or both. As a notifier, you can choose to communicate through the following channels:

• Web application (external management): https://canaldenunciascms.com/microsegur/
• Telephone (external management): +34 91 091 74 04 (Code: 29534)
• In person or by post: with the Responsible of the SII at the request of the informant, at the address: Calle del Portal, 12, 28119 Algete, Madrid.

Your communication should contain as much information as possible. You should not send any personal data that is not relevant to the information.

When you submit information through any of the available channels, you will receive an acknowledgement of receipt of your complaint within 7 calendar days of receipt, unless this may jeopardize the confidentiality of the communication. We inform you that in case you make your communication by telephone from a fixed telephone number, it will be necessary to provide your e-mail address or cell phone number in order to receive the acknowledgement of receipt. Otherwise, it will be impossible for us to send you the receipt.

How your notification is handled

In the processing of communications submitted through this internal information system, the confidentiality of the data provided and the protection of the informants and third parties involved is guaranteed at all times, in accordance with the provisions of Law 2/2023 of February 20 (Spanish legislation).

Each communication will be automatically assigned a unique case number and the informant will receive an acknowledgement of receipt confirming the sending.

In the case of communications made anonymously, the system will show the acknowledgement of receipt on the screen at that moment and will provide a password that must be saved, since only with this password you will be able to access your communication, follow up on the case, maintain communication with the person in charge of its management, provide additional information or respond to possible requests for information.

Once the communication is received, the person in charge of handling it will perform a preliminary analysis to determine whether it is within the scope of the SII and whether an investigation should be initiated.

Within a period of 3 months, extendable for another 3 months in cases where it is necessary due to its special complexity, you will receive information on the management carried out and, where appropriate, the outcome of the investigation.

Data protection

We inform you that the personal data you provide in your communication will be treated as specified in the Privacy Policy.

Anonymity

You can communicate completely anonymously through the web application. It is not mandatory to provide any personal information.

External information channels

It is also possible to report, either directly or after communication through the corresponding internal channel of the company, about infringements of European Union Law, and also about actions or omissions that may constitute a serious or very serious criminal or administrative infringement, included in the material scope of application of Law 2/2023, to the Independent Authority for Whistleblower Protection (AIPI), to the corresponding regional authorities or bodies, and, where appropriate, to EU institutions, bodies or agencies.

Links to external channels:

• Independent Authority for Whistleblower Protection (AIPI) (To be established)
• Municipal Anti-Fraud and Corruption Office: https://www.madrid.es/portales/munimadrid/es/Inicio/El-Ayuntamiento/Oficina-Municipal-contra-el-Fraude-y-la-Corrupcion/?vgnextfmt=default&vgnextoid=00369bbb53158610VgnVCM1000001d4a900aRCRD&vgnextchannel=ce069e242ab26010VgnVCM100000dc0ca8c0RCRD
• National Anti-Fraud Coordination Service, for fraud or irregularities involving European funds.: https://www.igae.pap.hacienda.gob.es/sitios/igae/es-ES/snca/Paginas/inicio.aspx
• European Anti-Fraud Office: https://anti-fraud.ec.europa.eu/index_es
• Independent Fiscal Accountability Authority: https://www.airef.es/es/
• External communications channel of the Competition Directorate of the National Commission for Markets and Competition.: https://www.cnmc.es/
• State Agency of Tax Administration: https://sede.agenciatributaria.gob.es/
• State Data Protection Agency: https://www.aepd.es/es
• Public Prosecutor’s Office: https://www.fiscal.es/
• European Public Prosecutor’s Office, for crimes against the financial interests of the European Union: https://www.consilium.europa.eu/es/policies/eppo/