Whistleblowing Policy

WHISTLEBLOWING POLICY

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1. Purpose & Commitment

Fides Group is committed to the highest standards of integrity, transparency, and ethical conduct in all our operations. This Whistleblowing Policy establishes a confidential channel for reporting genuine concerns about illegal, unethical, or improper conduct within our organization, in accordance with EU Directive 2019/1937 and Spanish Law 2/2023.

 

2. Scope

This policy applies to all employees, contractors, investors, business partners, and any third parties who have a legitimate concern regarding:

• Financial misconduct or fraud

• Accounting or auditing irregularities

• Violation of securities laws or regulations

• Breach of fiduciary duties

• Insider trading or market manipulation

• Money laundering or terrorist financing

• Health and safety violations

• Environmental violations

• Discrimination or harassment

• Retaliation against whistleblowers

• Any other illegal or unethical conduct

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3. Reporting Channels

3.1 Primary Reporting Method

Whistleblowing Officer:
[Name of Whistleblowing Officer]
Email: whistleblowing@fidesgroup.com
Secure Phone: [+34 XXX XXX XXX]

 

3.2 Alternative Reporting Method

Independent Third-Party Service Provider:
[Name of External Service Provider]
Online Portal: [Secure URL]
Phone: [Dedicated Hotline Number]

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3.3 Anonymous Reporting

Anonymous reports are accepted through our secure third-party portal. However, providing contact information may facilitate investigation and follow-up.

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4. Protection of Whistleblowers

4.1 Confidentiality

All reports will be treated with strict confidentiality. The identity of the whistleblower will not be disclosed without their consent, except as required by law.

 

4.2 Non-Retaliation

Fides Group prohibits any form of retaliation against individuals who report concerns in good faith. Retaliation includes:

• Termination or demotion

• Harassment or intimidation

• Unfair treatment

• Any adverse employment action

 

4.3 Legal Protection

Whistleblowers are protected under:

• EU Directive 2019/1937 on whistleblower protection

• Spanish Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements

• Applicable national laws in all jurisdictions where we operate

 

5. Investigation Process

1. Acknowledgment: Receipt of report acknowledged within 7 days

2. Assessment: Preliminary assessment within 14 days

3. Investigation: Thorough investigation by independent party

4. Findings: Conclusion and determination of appropriate action

5. Feedback: Whistleblower informed of outcome (where appropriate)

 

6. False Reports

Reports made maliciously or with knowledge of their falsehood may result in disciplinary action or legal proceedings.