Whistleblowing Channel Operating Rules

FIRST.- Basic principles of action for the formulation of internal complaints
Internal complaints must always be made in good faith, with scrupulous respect for the truth, with the conviction that they are acting correctly and only for the benefit of Axon Partners Group, the State and/or society in general. Axon Partners Group expressly prohibits making false complaints, as they are contrary to the law and the principles and values of the company.

SECOND.- Reportable facts
All those facts or acts that violate the Code of Ethics and the Bylaws of the Company, those contrary to the Law, as well as any other irregularity that may pose a high risk for Axon Partners Group , are liable to be denounced.

THIRD.- Who can file a complaint?
Any subject bound by the Axon Partners Group Code of Ethics, as defined in its 9.3 section, has the inexcusable obligation and legal duty to report internally any Reportable Fact of which they are aware. Notwithstanding the foregoing, any person who has knowledge of the commission of a Reportable Act may also file an internal complaint, without it being necessary for them to hold the status of Subject Person.

FOURTH.- What people are likely to be denounced?
All Persons Obligated by the Axon Partners Group Code of Ethics (employees and members of the Board of Directors and the Management Committee, without exception and whatever their position or responsibility; representatives, suppliers, customers and other stakeholders).

FIFTH.- Complaint processing procedure

Complaint
All internal complaints must contain, as a minimum, (i) the identifying data of the accused -name and surname- and (ii) the facts denounced, specifying, as far as possible, the offense allegedly committed.
The complaint must meet the following requirements:
-The whistleblowing channel through the web form is accessible to all members of the company, guarantees the confidentiality of the data, displays correct monitoring practices, allows anonymous communication and ensures independence and confidentiality since it is managed by an external advisor. In the same way, the whistleblowing channel enables the filing of a complaint through written or verbal communications, or both. The information may be made either in writing, through postal mail or through any electronic means enabled for this purpose, or verbally, by telephone or through a voice messaging system. At the request of the informant, it may also be presented through a face-to-face meeting within a maximum period of seven (7) days.
- The complainant is not required to identify himself.
- Probative material must be provided regarding the facts that are the object of the complaint.
- It must always be formulated in good faith, with scrupulous respect for the truth, acting correctly and solely for the benefit of AXON, the State and/or society in general. AXON expressly prohibits making false complaints, as they are contrary to the law and the principles and values ​​of the company.
The complaint will go directly to the Ombudsman, as an external lawyer, autonomous and independent of AXON, who will process it.
The parties involved in the complaint must be adequately informed about everything concerning the facts, always showing the utmost respect for the confidentiality of the system and guaranteeing the most absolute protection of the users who use it.
AXON is firmly committed to not retaliating against complainants and participants in the investigation process.

Principle of proof
Any person who makes a complaint must have rational evidence to support it, so their complaint must be accompanied by a principle of proof that proves the facts, at least indicatively.
Any evidentiary material permitted by law will be considered a valid principle of evidence, preferably in documentary support, although testimonial evidence -including the testimony of the complainant himself- and instruments for reproducing words, images and sounds will also be admissible.
In any case, any evidence must have been obtained by the complainant lawfully, that is, with respect for the law and constitutional rights and guarantees.

Admission to process
Complaints will only be admitted for processing in the event that they comply with the provisions of the Code of Ethics.

Rectification of defects
In the event that a rectifiable defect had been incurred when making the complaint, the person receiving the complaints will notify the complainant of the need to correct the defect(s) within a period of seven (7) business days to the complainant, which will begin to count the day after communication. The complainant will be warned that if they do not proceed with the rectification within the established period, the complaint can be filed.

Archive
If the complaint does not comply with the provisions of this regulation, for whatever reason, or if the defects noted in the complaint have not been rectified, it will be filed.

File opening
If the complaint is admitted for processing, the Ombudsman will notify AXON's Director of Regulatory Compliance of the opening of a file in which as many actions as may be appropriate may be carried out and the evidence deemed necessary for due clarification and determination of the facts may be carried out.
AXON informs its workers of the possibility of carrying out internal controls (computer and mobile devices, as well as email), in the event that the company receives a complaint with supporting evidence in violation of the ethical code and/or the law. Notwithstanding the foregoing, in any investigation carried out on a worker's devices and/or email, the latter must be present during the internal interference.
The term for the processing of the file will depend on the type of offense committed by the accused, without in any case exceeding three months from the date of its opening, and must comply at all times with labor legislation and in its criminal case.

Processing
The Ombudsman manages the Whistleblowing Channel (i) receiving internal complaints through it, (ii) instructing the files to which they give rise, (iii) making the decision on their admission and (iv) informing the Compliance Director about your result.

Notification to the person or persons denounced
The person or persons denounced will have the right to know that they have been denounced and must receive notification of the existence of the denouncement and a summary of the denounced facts as soon as possible and, in any case, within a maximum period of fifteen ( 15) days from the receipt of the complaint. The notification addressed to the person or persons denounced will not include the data of the denouncer, if they have been provided by the latter.

SIXTH.- Anonymous or, where appropriate, confidential complaints
Anonymous complaints are allowed. Notwithstanding the foregoing, if the complainant wishes to provide their data, the confidentiality of the complaint is guaranteed, not including any reference to the complainant in the data provided to the person(s) denounced.

SEVENTH.- Absence of reprisals
AXON acquires the firm commitment not to adopt reprisals against complainants and participants in the investigation process, who can go to the Ombudsman or Compliance officer at any time, in order to request guidance or report, where appropriate, situations of harassment.

EIGHTH.- Prohibition of false reports.
Internal complaints must always be made in good faith, with scrupulous respect for the truth, with the conviction that they are acting correctly and only for the benefit of AXON, the State and/or society in general. AXON expressly prohibits the formulation of false complaints, as they are contrary to the law and the principles and values of the company.
Notwithstanding the foregoing, if as a result of the investigation of a complaint it is evident that it is false or if the complainant has acted in bad faith or flagrantly infringing the rules of operation of the Whistleblowing Channel, regardless of the measures laws that AXON could adopt, in this regard, will lead to the opening by the Ombudsman of a file for violation of the Code of Ethics.
AXON will investigate each and every one of the complaints that are filed with disregard for the truth and acting in bad faith, considering these unacceptable and therefore will be sanctioned as a very serious offense.

NINTH.- Acceptance of the Rules and the Privacy Policy
The formulation of an internal complaint implies full and unreserved acceptance of any kind of these Operating Rules of the Whistleblowing Channel, as well as the corresponding Privacy Policy.

Frequently Asked Questions (FAQs)

What is a whistleblowing channel?
It constitutes the mechanism to facilitate the confidential and highly secure communication of all those facts or acts that threaten the Code of Ethics of AXON, as well as any other irregularity that may pose a high risk in the company. Said complaint will go directly to the Compliance Officer, as an external, autonomous and independent lawyer of AXON.

Can complaints be made anonymously?
Yes. The complainant is not required to identify themselves.

What requirements must the complaint meet?
1. The whistleblowing channel through the web form is accessible to all members of the company, guarantees the confidentiality of the data, displays correct monitoring practices, allows anonymous communication and ensures independence and confidentiality since it is managed by a external consultant. In the same way, the internal channel enables the filing of a complaint through written or verbal communications, or both. The information may be provided either in writing, through postal mail or through any electronic means enabled for this purpose, or verbally, by telephone from the external lawyer who processes complaints on the web form -Ombudsman-, whose telephone number is 0034629133082, or through voice messaging system. At the request of the informant, it may also be presented through a face-to-face meeting within a maximum period of seven (7) days.
2. It must always be formulated in good faith, with scrupulous respect for the truth, acting correctly and solely for the benefit of AXON, the State and/or society in general. False complaints are expressly prohibited as they are contrary to the Law, the Bylaws and the Company's own values.
3. The complaint must be accompanied by probative material that supports the facts denounced.

Can I report a fact without having proof?
No, in accordance with the provisions of Section 9.6 of the Code of Ethics, any complaint must be accompanied by a principle of proof that proves the facts, at least indicatively, considering any probative material permitted by law, preferably in documentary support, although it can also be considered valid. Witness evidence will be admissible ‒including the testimony of the complainant himself‒ and instruments for reproducing words, images and sounds. In any case, any evidence must have been obtained by the complainant in a lawful manner, that is, with respect for the law and the constitutional rights and principles.

Is the accused going to be informed that there is a complaint against him?
Yes, the person or persons denounced have the right to know that they have been denounced and must receive notification of the existence of the denouncement and a summary of the facts denounced as soon as possible and, in any case, within a maximum period of fifteen (15) days from the receipt of the complaint. However, the notification addressed to the person or persons reported will not include the data of the complainant, if they have been provided, in accordance with the provisions of section 9.11 of the Code of Ethics.

What consequences can an internal complaint have if it is verified that there are rational indications of the commission of an illegal act or one contrary to the Code of Ethics?
Failure to comply with the Code of Ethics by an Obliged Person, depending on the specific circumstances, will give rise to the reparation of the damages that such breach may cause to AXON, as well as the termination of the contractual relationship with the company or , in the event of an employment relationship, to the adoption of disciplinary measures, including dismissal.
Cases of non-compliance with the Code of Ethics will be considered, among others:
- Failure to comply with any of the obligations, duties and prohibitions imposed by the Code.
- Induce third parties to breach the Code.
- Cover up third parties who have breached, are breaching or are going to breach the provisions of the Code.
- Lack of cooperation in the investigation initiated by AXON or by any legal firm or external consultant hired for this purpose.
- Carry out reprisals against any Obligated Person who has denounced or informed, in good faith, about a breach of the law and/or the Code.

Privacy Policy

For the purposes of the provisions of the Personal Data Protection regulations, AXON PARTNERS GROUP (hereinafter “AXON”) informs the users of the Whistleblowing Channel (hereinafter, the “Users”) that the data they are provided to you through said Whistleblowing Channel and those generated as a result of the complaints made, will be treated with the exclusive purpose of managing complaints made for the alleged commission of acts contrary to the Law within the company or to the detriment of it and violations of AXON Code of ethics.

AXONAXON

Said treatment is carried out in the context of the organization and management model implemented by AXON based on the public interest of crime prevention as well as on the basis of its legitimate interest to adopt measures that facilitate compliance with the Code of Ethics and may prevent its non-observance.

Likewise, Users who file an internal complaint are informed that the data they provide through the Whistleblowing Channel as well as those resulting, where appropriate, from the investigation of the Reportable Facts, will be accessible to both the Ombudsman, Compliance Officer or the Board of Directors of AXON and may be shared, within the scope of said investigation, with other AXON companies or with other third parties that may be directly related to the Reported Facts.

Likewise, Users are informed of the possibility that their personal data may be communicated to the State Security Forces and Corps, to other bodies of the Public Administration with competences in the investigation of the Reported Facts, as well as to the Courts of Justice and other jurisdictional bodies.

AXON undertakes to respect the confidentiality of the data subject to treatment and its use in accordance with the purpose established herein, as well as to comply with its obligation to save it and adopt all measures to prevent unauthorized access, destruction, loss or accidental or illegal alteration in accordance with the provisions of current regulations. In particular, in accordance with the provisions of the Whistleblowing Channel Operating Rules, AXON will maintain the confidentiality of the data of Users who file internal complaints, preventing access to them by the people reported.

Notwithstanding the foregoing, in the event that a complaint turns out to be false, Users are informed that their data may be communicated to the person or persons denounced so that they can, if they deem it appropriate, initiate legal actions. to help them with the false accusation.

The data will be processed for the time necessary to decide on the appropriateness of initiating an investigation into the Reported Facts and, where appropriate, for its investigation in the case of a well-founded complaint. Otherwise, said data will not be kept, being deleted.

Users may exercise their rights of access, rectification, deletion, opposition or limitation of treatment, whenever it is pertinent by request by email addressed to privacidad@lessepslegal.com or by ordinary postal mail addressed to:

Christian Mesía Martinez
Compliance Officer, external legal consultant to AXON
C/ Principe de Vergara, 33
280001 – Madrid

Christian Mesía is an external legal consultant for AXON who holds the status of data processor relating to the Whistleblowing Channel and who is entrusted with attending, on behalf of AXON, requests for the exercise by Users of the aforementioned rights.

AXON