POLICY OF OPERATION OF THE ETHICAL MAILBOX

SURUS INVERSA S.L., in line with its business strategy, has developed a Compliance and Anti-bribery Management System.

The Ethics Mailbox of SURUS INVERSA S.L. was created with the aim of preventing the commission of any illicit act or eradicating any non-compliance in matters of compliance that may be occurring within the company.

Should you become aware of any situation or conduct contrary to our Code of Ethics and Conduct or internal regulations, please inform us through this channel so that we can continue to improve.

For complaints and suggestions, SURUS INVERSA, S.L. has set up other channels of communication: buzoncompliance@surusin.com

I.- OPERATION OF THE ETHICS MAILBOX.

What communications should be made through the Ethics Mailbox?

All information on breaches or non-compliance in a broad sense, that is to say, reasonable suspicions, real or potential breaches, which have occurred or are likely to occur in SURUS INVERSA, S.L., must be communicated through the established channels.

When is it necessary to inform?

You must report when you have reasonable grounds to believe that the information you indicate is true and susceptible to be considered as a breach or non-compliance. The report must always be made in good faith.

What channels has the Company set up?

• Telematically through the Ethics Mailbox enabled on the Surus Inversa and Escrapalia website. 
• By means of written or verbal communication to any person who is part of the Compliance Body.
• By post to the following address: Camino de las Huertas 18, 2ºpiso, Pozuelo de Alarcón 20223, Madrid, Spain.

What information should be provided at the time of communication?

As far as possible, please provide information that is as complete, detailed and truthful as possible. Therefore, if you make a communication, please provide all the information and evidence available to you. This will enable the process to be managed as efficiently as possible.

Can the communication be made anonymously?

The SURUS INVERSA, S.L. Ethics Mailbox allows you to make communications anonymously. 

This channel will not obtain data that allow your identification, in the event that you wish to communicate anonymously.

Likewise, the appropriate technical and organisational measures will be taken to preserve your identity, if applicable, and to guarantee the confidentiality of the data corresponding to the persons concerned and any third party mentioned in the information provided.

In case of providing documentation attached to your communication, please note that the documents contain traces of the device where they have been generated. We therefore recommend that you generate the files on devices not linked to any person or delete the metadata of the documents.

SURUS INVERSA, S.L. expressly prohibits reprisals against persons who submit a communication in accordance with the provisions of this Policy.

II.- MANAGEMENT PROCEDURE.

In summary, the management procedure will be as follows:

1. Communication by the reporting person through the Ethics Mailbox.
2. Receipt and analysis of the communication received by the Compliance Officer. Admission or rejection for processing.
3. Communication, where appropriate, to the persons under investigation.
4. Development of the investigation procedure.
5. Final report.
6. Resolution of the procedure.
7. Hearing.
8. Adoption, where appropriate, of measures depending on the relationship with the person complained of.

III.- DATA PROTECTION .

The processing of personal data arising from the use of the Ethics Mailbox shall be governed by the provisions of the data protection regulations in force. Personal data will not be collected if it is not manifestly relevant to the processing of specific information or, if collected by accident, will be deleted without undue delay.

For further information, please refer to the data protection section of the Ethics Mailbox form.

Madrid, 01st june 2023

Surus Inversa S.L.