Conducts that can be reported through the Whistleblowing Channel

The conduct that can be reported through Xeridia’s Whistleblower Channel includes any breach of the principles and rules of conduct established in its Code of Good Practices and other policies included in the scope of the Integral Management Systems, which are available to all Xeridia professionals in the Confluence tool.

Likewise, those conducts typified in the Criminal Code and the offences envisaged in other special laws, which may generate criminal liability for the Group, such as:

• Bribery: Offering or giving to officials, authorities, bodies and public administrations a gift, financial or of any nature, with the intention of obtaining a benefit for Xeridia, whether licit or illicit. Xeridia, whether lawful or unlawful.
• Influence peddling: To also influence, taking advantage of any situation arising from a personal relationship, in order to obtain a decision that may directly or indirectly generate an economic benefit for Xeridia.

• Corruption in business dealings: That an officer, director, employee or collaborator of Xeridia, either personally or through an intermediary, receives, requests or accepts an unjustified benefit or advantage of any kind, for himself or for a third party, as consideration for unduly favouring another in the acquisition or sale of goods, or in the contracting of services or in commercial relations. Conversely, the promise or giving of a benefit to a third party for the acquisition or sale of goods in commercial relations.
• Corruption in international transactions: Offering or giving an undue advantage or benefit to public officials to obtain favourable treatment in the conduct of international economic activities.
• Fraud: Deceiving another person, for profit, so that they carry out an act of disposition that harms themselves or a third party.
• Misleading advertising: Making offers or advertising of products or services, where false allegations are made or uncertain characteristics are stated about them, in such a way as to cause serious and manifest harm to consumers.
• Discovery and disclosure of company secrets: Taking possession by any means of data, documents, whether written or electronic, computer media or other objects that constitute confidential information of another company, entity, etc., for their use, dissemination, disclosure or transfer.

• Subsidy fraud: Obtaining subsidies or aid from the Public Administrations in an amount or for a value of more than 120,000 euros by falsifying the conditions required for their concession, concealing those that would have prevented it.

• Fraud against the Public Treasury: Defrauding the Public Treasury (state, regional, foral or local) in an amount exceeding 120,000 euros; evading the payment of taxes, amounts withheld or that should have been withheld or payments on account of remuneration in kind, unduly obtaining refunds or enjoying tax benefits in the same way.

• Social Security fraud: Avoiding the payment of Social Security contributions by unduly obtaining refunds or unduly taking advantage of deductions.

• Breach and falsification of accounting obligations: Serious breach of the obligation to keep business accounts and accounting books and/or records. It represents a type of offence that is often combined with other fraudulent conducts, as these are usually carried out by means of double bookkeeping and false accounting entries.

• Offences against natural resources and the environment: Directly or indirectly causing or carrying out emissions, discharges, radiations, extractions, excavations, groundings, landings, noises, vibrations, injections or deposits, in the atmosphere, soil, subsoil or terrestrial, underground or maritime waters; establishing deposits or dumps of solid or liquid waste or residues that are toxic or dangerous and may seriously damage the balance of natural systems or the health of people.

• Frustration of execution: Carrying out any act of disposition of assets or generating obligations that hinders or prevents a seizure or a procedure for claiming an amount from being carried out. Concealing assets in judicial or administrative enforcement proceedings. Making unauthorised use of assets seized by the authorities without the authorisation of the depositary.

• Punishable insolvencies: In the event that the company is in insolvency proceedings, this offence would occur when an act of disposal of assets is carried out to unduly reduce the assets that are a guarantee for the fulfilment of obligations, or to make it difficult or impossible for the creditor to know the true economic situation of the debtor.

• Offences against Intellectual Property: Reproducing, plagiarising or publicly communicating, in whole or in part, a literary (book), artistic (painting or photograph) or scientific (specific theory, applications or computer programmes) work, or its transformation, transformation, plagiarisation or public communication. software), or its transformation, interpretation or artistic performance fixed on any medium or communicated by any means, without the authorisation of the rightholders. For example, this offence is applicable to cases in which computer applications or programmes are used without the corresponding licence for use.

• Industrial Property Offences: Industrial Property Offences: Reproducing, imitating, etc. a distinctive sign without the consent of the owner, in such a way as to obtain another sign identical or confusingly similar to it, to distinguish the same or similar products, services, activities or establishments.
• Computer damage: Deleting, damaging, deteriorating, deleting or making inaccessible, data, computer programmes or electronic documents of others, without authorisation and when the result produced would be serious. Impeding or hindering the operation of other people’s computer systems.
• Counterfeiting currency and stamped money: Altering or manufacturing counterfeit currency. Bringing into the country or exporting counterfeit or altered currency. Transporting, selling or distributing counterfeit or altered currency with knowledge of its falsity.
• Offences against personal and family privacy: Seizing, using or modifying, without authorisation and to the detriment of a third party, reserved data of a personal or family nature of another person that is recorded in computer, electronic or telematic files or media or in any other public or private file or register. Unlawfully accessing a computer system in order to seize personal data contained therein.
• Against the rights of foreign citizens: Promoting, favouring or facilitating illegal trafficking or clandestine immigration.
• Money laundering: Accepting funds, deposits, etc. that have their origin in the commission of a crime, or carrying out any other act to conceal said illicit origin, or to help the person who has participated in the offence. It can be committed recklessly if it is done without due diligence, i.e. it is not necessary for the perpetrator to want and know that the offence is going to be committed.
• Terrorist financing: Providing, collecting or accepting funds with the intention that they be used to commit crimes related to terrorist organisations and groups.
• Offence against public health: Offering on the market products that are harmful to health, and/or that do not comply with the shelf life or composition requirements established by laws or regulations. Also manufacturing, dispensing, supplying or trading in substances harmful to health.
• Against workers’ rights: Putting the life, health and safety of workers at serious risk due to the infringement of occupational risk prevention regulations. This offence can be committed recklessly. Using deception or abuse of a situation of necessity to impose working or Social Security conditions on workers that prejudice, suppress or restrict their rights. Imposing inadequate working conditions or conditions contrary to occupational health and safety; treating workers in conditions of inequality and discrimination; preventing or limiting the right to freedom of association.
• Stock exchange offence: UUsing or supplying any information relevant to the quotation of any kind of financial instruments. Spreading news or rumours about persons or companies, knowing them to be false, with the aim of altering or preserving the price of the quotation of a security or financial instrument. Misrepresenting the economic and financial information contained in financial reports.
• Handling of toxic, corrosive and other substances: Contravening the safety regulations established in the manufacture, handling, transport, possession or marketing of explosives, flammable or corrosive substances, toxic and asphyxiating substances, putting the life, physical integrity or health of people or the environment in concrete danger.
• Refusal of inspection activity: Refusal to cooperate with the inspection authorities in relation to companies subject to or operating in markets subject to administrative supervision.
• Illegal financing of political parties: Giving donations or contributions to a political party, federation, coalition or grouping of voters illegally.
• Fraudulent invoicing: Altering or manipulating the automatic devices that measure the cost of products sold or services offered (meters, taximeters, etc.) with the aim of invoicing higher amounts, causing harm to the consumer.
• Smuggling: Importing or exporting lawfully traded goods in an irregular manner, provided that the value of the goods, merchandise, goods or effects is equal to or greater than 150,000 euros. Failure to comply with customs regulations in any other way.
• Alteration of prices in public tenders and auctions: To request any benefit in order not to take part in a public tender or auction, to try to keep bidders away from it by means of threats, gifts, promises or any other artifice, to concert with another bidder with the aim of altering the price of the auction, or to fraudulently abandon an auction after having been awarded the contract.
• Price fixing: Altering the prices that would result from the free competition of products or services.
• Offences against sexual freedom, sexual harassment and harassment on grounds of sex: Any conduct of an unwanted sexual nature that may be perceived or cause offence or humiliation to a person. When such conduct interferes with work, or creates an intimidating, hostile or offensive working environment. While it usually involves a pattern of behaviour, it can also take the form of a single incident. Sexual harassment” should be distinguished from “harassment based on sex” as the latter constitutes a type of discriminatory harassment on Effective Equality between Women and Men as “any behaviour carried out on the basis of a person’s sex or gender identity, with the purpose or effect of violating their dignity and creating an intimidating, degrading or offensive environment”.