Whistleblowing Channel

The internal information system comprises the different internal information channels, including the Whistleblower Channel as the main way to report actions and omissions that could constitute infringements of European Union law and/or a serious or very serious criminal or administrative offence, as set out in the Corporate Internal Information System Policy.

The Whistleblower Channel is also the appropriate way to communicate any cases of workplace or sexual harassment against workers. The potential severity of these actions and the importance the Group places on managing them means that VidaCaixa has a specialised Committee for processing them.

Remember that regulatory compliance is the responsibility of each and every person in the organisation. As a result, and in keeping with the Code of Ethics, we have a duty to report any action of which we are aware that could constitute a crime, fraud or improper behaviour.

Reports can be made on a named basis, that is, with the identification of the reporting party, or anonymously. This channel allows reports to be made in writing through:

• The Whistleblower channel application: https://silkpro.service-now.com/canal_denuncias

• Email: canaldenuncias.grupocaixabank@caixabank.com.

• Postal address: Av. Diagonal, 621-629, Z.I. - 08028, Barcelona (F.A.O. Department of Compliance - Regulatory and Group Risk Management).

Reports can also be made verbally through in-person meetings, at the request of the reporting party. In these cases, the request should be made through the written communication channels listed above. These meetings will be held in an environment which guarantees confidentiality.

This Channel offers a series of guarantees, the main ones including confidentiality and protection of the identity of the reporting party, protection measures and a prohibition on reprisals, anonymity and non-traceability, as well as the rights of the people involved.

The framework for managing reports is set out in the Information Management Procedure. Reports made are subject to an eligibility analysis. The following reports are excluded from the scope of the internal information system:

1. Those relating to facts/behaviours that do not involve irregularities that may beach European Union law, do not constitute a serious or very serious criminal or administrative offence and do not contravene internal regulations.

2. Those that are made by or refer to groups other than those covered by the channel: employees, managers and directors, interns, temporary employment agency workers, mediators, suppliers and people who work for them or under their supervision, shareholders, former employees and job candidates.

3. Those based on reports previously deemed inadmissible through any internal information channels.

4. Those relating to public facts (public information).

5. Those based on personal conflicts or that only affect the reporting party and the people named in the report.

6. Those based on mere rumours rather than concrete or specific suspicions or indications.

7. Those specifically relating to the contents of a file/document to which the entity does not have access and where the documentation is not provided.

8. Those reporting facts/behaviours being dealt with through a police, administrative, inspection and/or court process.

External information channel

Without prejudice to the above, and at any moment, both the reporting party and the party being reported can contact the Spanish Independent Whistleblower Protection Authority (A.A.I. for its Spanish initials) or the corresponding regional authorities or bodies.

Related documentation

• Corporate Internal Information System Policy

• Information Management Procedure

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