Compliance

Criminal Compliance Management System of PERSONA SERVICE RRHH ETT, S.L.

PERSONA SERVICE RRHH ETT, S.L. (hereinafter also referred to as PERSONA SERVICE) with the design, planning, adoption and effective implementation of its corporate Criminal Compliance Management System (CCMS), perfectly adapted to its specific risks and activities, aims to take a further step in its commitment to continuous improvement in order to position itself at all times at the highest standards in terms of integrity, ethics, professionalism, social responsibility and good governance.it has adopted, within the framework of the CCMS, the Code of Ethics and Conduct and the Criminal Compliance Policy as common standards of behavior required throughout the organization and published.

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As a result, it is also committed to zero tolerance of criminal risks, as well as their effective prevention, detection and early management.

PERSONA SERVICE thus demonstrates its absolute opposition to benefiting in any way from unethical behavior, and even less so from behavior that could constitute a criminal offense.

Within this framework, the purpose of the SGCP is to promote the corporate culture of ethics and integrity, to strengthen the Organization's compliance system, and to establish a system of prevention, detection and response to criminal risks that is adapted to the requirements established in the Spanish Criminal Code and other applicable regulations.

In this way, PERSONA SERVICE's SGCP is an effective mechanism capable of assisting all Members of the Organization, its Business Partners (customers, suppliers, collaborators, consultants, etc.), and other interested parties related to PERSONA SERVICE, in the prevention of criminal risks, providing a mechanism capable of identifying and, where appropriate, reporting criminal conduct and procedures that may occur in the exercise of social activities.

The Code of Ethics and Conduct sets out the values and philosophy of PERSONA SERVICE and the general principles of action that the Organization applies in the development of its activities, as well as its commitment to compliance with the law. its commitment to compliance with the Law and the ethical values it upholds, rules of conduct, as well as the sanctioning regime applicable in the event of non-compliance.

The Code of Ethics and Conduct is a very important milestone, because the general values that inspired the founding of PERSONA SERVICE were, and continue to be in force and strengthened, the effort to develop a focused project, as key values that govern our actions:

Aware that any action we develop has an impact on society, our Code of Ethics and Conduct also implies our commitment to ethics, integrity, compliance with laws and professionalism.

The Code of Ethics and Conduct will be applicable to all levels of the Members of the Organization and will be extended to the Business Partners to whom it is required related to the activity of the Organization.

All the people who make up PERSONA SERVICE are key elements on which these principles and values are based and developed, and they are also the ones who promote them among all the Members of the Organization, Business Partners (customers, suppliers, collaborators, etc.) and other stakeholders.

It is vital that each person in our Organization acts in accordance with the rules of this Code, that the decisions taken in daily work are in accordance with its principles, values and guidelines for conduct, and actively defends them, in order to preserve and enhance the reputation of PERSONA SERVICE.

The Criminal Compliance Policy develops what is established in PERSONA SERVICE' s Code of Ethics and Conduct, mainly its sections 5 and 6, and, consequently, is linked to its ethical values, ratifying PERSONA SERVICE's firm will to maintain a conduct that respects both the rules of ethics and the rules of conduct. conduct respectful of both the rules and ethical standards and, to this end, establishing its framework of principles and rules of conduct of mandatory compliance in criminal matters, aligned with PERSONA SERVICE's determination not to tolerate any conduct that may constitute a crime.

The Criminal Compliance Policy is intended to strengthen the compliance system, promoting a corporate culture of ethics and integrity, and zero tolerance of criminal risks, and is part of the regulatory body of PERSONA SERVICE, aimed at preventing, detecting and responding to any criminal conduct that may involve criminal liability for the legal entity, as well as economic and / or reputational damage.

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De conformidad con el compromiso de PERSONA SERVICE con una verdadera cultura ética y de cumplimiento, así como con la ejecución eficaz del Código Ético y de Conducta, de la Polícompliance Policy, the Protocol for the Prevention, Detection and Action against Sexual Harassment and Harassment based on Sex, and other related internal regulations, and in accordance with the provisions of art. 31 bis 5.4 of the Spanish Criminal Code and Law 2/2023, of February 20, 23, regulating the protection of persons who report regulatory infringements and the fight against corruption, the Organization has implemented an Internal System for Information and Protection of Whistleblowers and Affected Persons - Ethics Channel (hereinafter also "Internal Information System", "Ethics Channel" or "the System").

All this within the framework of our Compliance System, and the protection of our image and reputation, responding to our commitment to regulatory compliance and the strengthening of the culture of participation and internal communication as a mechanism to prevent and detect irregular conduct, as well as to guarantee the protection of whistleblowers against possible retaliation.

Consequently, the management body of PERSONA SERVICE RRHH ETT, S.L. has approved the creation and implementation of the Internal Whistleblower Information and Protection System in accordance with the provisions of the aforementioned Law 2/2023, and in accordance with the principles and requirements set forth in the aforementioned regulation.

Within this framework, PERSONA SERVICE has set up internal channels for reporting breaches ("Internal System for Information and Protection of Whistleblowers and Affected Persons") as a nominal and confidential or anonymous communication procedure in order to be able to report or inform, in good faith and on the basis of reasonable indications, possible risks, breaches or irregularities included in the scope of the aforementioned Internal System, as well as to send queries or any suggestion for improvement of the system of compliance and respect for the law and other regulations of the Organization.

This is an appropriate and effective way to facilitate the detection, discovery and sanctioning, through the collaboration of all, of possible irregularities or non-compliance.

It is also intended to provide adequate protection against reprisals that may be suffered by individuals who report any of the actions or omissions that may constitute violations referred to in the aforementioned Law 2/2023.

PERSONA SERVICE has chosen to establish a specialized external management system (reception of communications), with the aim of providing it with greater professionalism and autonomy, and offering adequate guarantees of respect for independence, confidentiality, data protection and secrecy of communications.

It is a System that provides the preferred channel for bringing to the attention of PERSONA SERVICE information on actions or omissions that may constitute infringements, obtained (i) in an employment or professional context (ii) within the framework of an employment or statutory relationship already terminated (iii) volunteers (iv) trainees (v) employees in training periods (vi) employees in training periods, irrespective of whether they receive or not (vii) employees in training periods (viii) employees in training periods, irrespective of whether they receive or not (viii) employees in training periods (viii) employees in training periods, irrespective of whether they receive or not.(vi) persons whose employment relationship has not yet begun in cases where information on violations has been obtained during the selection process or pre-contractual negotiation.

The complete regulation of the Internal Reporting and Whistleblower Protection System can be found in the General Policy of the Internal Reporting and Whistleblower Protection System and the Procedure for the Management of Information Received and Internal Investigations.

You can access the full text of the document in the link provided below. Some of its contents are summarized below as a guide to facilitate the use of the information channels established to report breaches or make queries.

The general principles and requirements of the System (developed in detail in the aforementioned document containing the General Policy and Management Procedure) are: Regulatory compliance, accessibility, good faith, whistle-blower protection and non-retaliation principle, confidentiality and anonymity, secrecy, objectivity and impartiality, transparency, compliance with the principles inspiring the legal system, traceability and security, data protection, possibility of prior knowledge by the Organization itself, integration in the System of the information channels established for reporting violations or making queries.the system must be integrated into the different internal information channels of the Organization, the person in charge of the system and diligence, implementation by agreement or decision of the Administrative Body, independent and differentiated from other entities and free from reprisals.

1. Employees (employees) of PERSONA SERVICE.
2. Shareholders and persons belonging to the administrative, management or supervisory body of PERSONA SERVICE, including non-executive members, as well as volunteers, interns and trainees, regardless of whether or not they receive remuneration.
3. In general, all Members of the Organization according to the definition established in the Policy.
4. Business Partners (customers, suppliers, collaborators, etc.) as defined in the Policy, including freelancers and anyone working under the supervision and direction of contractors, subcontractors and suppliers.
5. Reporting persons who no longer have a relationship with PERSONA SERVICE, due to the expiration of the latter, who communicate or publicly disclose information on breaches obtained in the framework of an employment or statutory relationship that has already ended.
6. Informants whose employment relationship has not yet begun, if the infringement is obtained during the selection process or pre-contractual negotiation.
7. Any person working under the supervision and direction of contractors, subcontractors and suppliers.
8. All those who directly or indirectly intervene in the procedure and may be retaliated against for it (whistleblower's advisors, representatives, etc.).

In relation to the whistleblower protection measures, they shall also apply, where appropriate, to:

• Natural persons who, within the framework of the organization in which the whistleblower provides services, assist the whistleblower in the process.
• Natural persons who are related to the whistleblower and who may suffer retaliation, such as co-workers or relatives of the whistleblower.
• Legal persons, for whom he/she works or with whom he/she maintains any other type of relationship in a work context or in which he/she holds a significant participation. For these purposes, it is understood that the participation in the capital or in the voting rights corresponding to shares or participations is significant when, due to its proportion, it allows the person who holds it to have the capacity to influence the participated legal entity.
• Where applicable, specifically to the legal representatives of the employees in the exercise of their functions of advising and supporting the reporting person.

Without prejudice to the persons who have the duty to report, additionally, it is encouraged that any person, natural or legal, who has had, has or may have a relationship with the Organization ("third parties") also use the Internal Reporting System in the cases regulated in the aforementioned Policy, as a formal mechanism for communicating any infringement, irregularity or non-compliance of which they are aware that are included in its objective scope, regardless of other means of communication made available to third parties.

A.- There are four types of communications that can be sent through the Internal Information System of the Organization:

1.- Communications on actions or omissions referred to in Article 2 of Law 2/2023:

1.1 Any actions or omissions that may constitute breaches of European Union Law provided that:

1. Fall within the scope of the acts of the European Union listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law, irrespective of their qualification under the domestic legal system.
2. Affect the financial interests of the European Union as referred to in Article 325 of the Treaty on the Functioning of the European Union (TFEU); or
3. Affect the internal market, as referred to in Article 26(2) TFEU, including infringements of European Union competition rules and aid granted by States, as well as infringements relating to the internal market in connection with acts that infringe the internal market, as referred to in Article 26(3) TFEU, including infringements of European Union competition rules and aid granted by States, as well as infringements relating to the internal market in connection with acts that infringe the internal market, as referred to in Article 26(3) TFEU.in addition, the Commission shall not be liable for any acts that infringe the corporate income tax rules or practices aimed at obtaining a tax advantage that distorts the object or purpose of the corporate income tax legislation.

1.2 Actions or omissions that may constitute a serious or very serious criminal or administrative offense. In any case, all those criminal or serious or very serious administrative or criminal offenses that imply economic loss for the Public Treasury and for the Social Security will be understood to be included.

1.3 Infringements of labor law in matters of occupational health and safety, without prejudice to the protection established in its specific regulations.

2.- Communications referring to:

1. Conduct (actions or omissions) typified in the SpanishCriminal Code , which may constitute a criminal offense, and the offenses provided for in other special laws detailed in Annex I of the General Policy of the Internal Information System, which apply to the Organization at any given time.
2. All those breaches or conduct contrary to the principles, values and rules of conduct established in the Organization' s Code of Ethics and Conduct and/or Criminal Compliance Policy, and in general to the Organization's Code of Ethics and Conduct and/or Criminal Compliance Policy, and in general to the Organization's Code of Ethics and Conduct.of the Organization, and in general to the Criminal Compliance Management System (SGCP) -policy of prevention, detection, management and reaction to criminal risks-.
3. All breaches or conduct contrary to the Organization's policies, protocols, procedures, manuals, standards or internal controls in relation to criminal risks and/or breaches of the Code of Ethics and Conduct.
4. And, in general, any situations or events that require the attention of the Organization's Ethics and Compliance Committee .

3. Communications regarding any type of harassment in accordance with the PERSONA SERVICE Protocol for the prevention, detection and action against sexual and gender-based harassment.

4. likewise, the Internal Information System is a channel for raising concerns, doubts, queries or suggestions for improvement related to the Code of Ethics andConduct , the Code of Conduct, the Code of Conduct and the Code ofEthics, the Code of Conduct and the Code of Ethics.the Internal Information System is also a channel for raising concerns, doubts, queries or suggestions for improvement related tothe Codeof Ethics and Conduct, the Criminal Compliance Policy and, in general, the Criminal Compliance Management System, or to the Organization's own activities that may give rise to fears of non-compliance.

B.- Regardless of the possibility of receiving other reports, complaints and/or claims from other regulatory areas, only and exclusively those communications set forth in article 2 of Law 2/2023 will be covered by the protection measures established therein.

C.- The internal management of the information to be provided through the Internal Information System and which is the object of the Protocol for the prevention, detection and action in the face of harassment behaviors will only be covered by the protection measures established in Law 2/2023.c.- The internal managementof information that will be made through the Internal Information System and are subject to the Protocol for the prevention, detection and actionagainst sexual harassment and harassment based on sex will be processed in accordance with the provisions thereof, which in any case will have the guarantees provided for in Law 2/2023. Those other conducts that have a specific procedure established for this purpose shall be governed by the same. In all matters not provided for in the Procedure, Law 2/2023 shall apply.

The corresponding competent unit shall be responsible for its resolution, which shall inform the body Responsible for the Information System, and shall carry out the relevant communications.

PERSONA SERVICE expressly prohibits acts constituting retaliation, including threats of retaliation and attempts of retaliation against persons who submit a communication in accordance with the provisions of the General Policy of the Internal Reporting and Whistleblower Defense System and the Procedure for the Management of Information Received and Internal Investigations and applicable regulations.

The use of the Ethical Channel (Internal Information System) makes it necessary to remember that the prohibition of retaliation provided for in the preceding paragraph shall not prevent and may result in criminal or civil liabilities and/or disciplinary measures, as appropriate, under the terms contemplated in the applicable legislation.the prohibition of retaliation provided for in the preceding paragraph shall not prevent and may result in criminal or civil liability and/or disciplinary action, as appropriate, under the terms of the law in force and the Organization's disciplinary system when the internal investigation determines that the communication is false and that the person has made it with knowledge of its falsity or with reckless disregard for the truth, and the requirements of confidentiality shall also be waived.

A.- The communication, complaint or consultation must be made in writing:

As the main channels for receiving information, PERSONA SERVICE makes available to complainants, in order to facilitate their mandatory accessibility on the corporate website, access to a platform (via app or web) provided by a specialized technology company, which provides a platform that allows them to send their complaints and queries in writing.provided by a specialized technology company, which has appropriate technical measures to ensure the confidentiality and security of the information, as well as anonymity when opting for this mode of communication.

There are the following two options (via the Co-Resol app or via web page), which allow the communication to be made both nominally and confidentially and anonymously, and in the first case the identity of the informant is reserved:

OPTION 1: Send a notification via mobile APP (co-resol):

1. Download the co-resol app, accepting the notifications. It is free and available on the App Store and Google Play.
2. Press the "Click" button and then enter the following code: P-SERVICE
3. Select the channel button.
4. Write your message being as specific as possible. You can attach both images and documentation.
5. Identify yourself or select the anonymity option. In either case, you must accept the Privacy Policy.
6. Once you have completed these steps, you will receive a message as acknowledgement of receipt of your click.
7. The communication to track the click will be done through a secure chat (you can access it from the chat button on the home screen of the app) until the click is closed.

OPTION 2: Send a notification through a web page:

You can access it through this link:

https://co-resol.bcnresol.com/webclick

1. Click on the "Click" button and then enter the following code: P-SERVICE
2. Select the channel button.
3. Write your message being as specific as possible. You can attach both images and documentation.
4. Identify yourself or select the anonymity option. In either case, you must accept the Privacy Policy.
5. In this case, you will receive a unique identifier code and password that you must keep in order to maintain communication, through a secure chat, about the status of your click.
6. Whenever you want to know if you have a new message in the chat or want to provide more information, to ensure confidentiality, you must enter this code and password on the home page, in the "Access a previous click" button.

Aspects on the use and management of the channel

• We inform you that the channel allows both first-time communications and access to previous communications in order to follow up on them.
• CO-RESOL (web) is a platform available 24 hours a day, 365 days a year.
• The Channel (CO-RESOL) provides automatic acknowledgement of receipt and makes it possible to incorporate all types of files (including audio). It incorporates end-to-end encryption and encryption of personal data in databases.
• It strictly complies with Law 2/2023 on the protection of the informant and the regulations on the protection of personal data.

B.- In person, at the following address of PERSONA SERVICE, Passeig de Gràcia 60, 1º B - 08007 - Barcelona, at the request of the informant, within a maximum period of seven days, before any member of the Ethics and Compliance Committee. Verbal communications made through a face-to-face meeting shall be documented in the manner provided for in the General Policy of the Internal Information and Whistleblower Defense System and the Procedure for the Management of Information Received and Internal Investigations.

External reporting channel

Any individual may report to the Independent Authority for Whistleblower Protection, A.A.I., or to the corresponding regional authorities or bodies, of the commission of any actions or omissions included in the scope of application of Law 2/2023, of February 20, 23, regulating the protection of persons who report on the information of the Company's employees.the Company shall not be liable for any actions or omissions that are included in the scope of application of Law 2/2023, of February 20, regulating the protection of persons reporting regulatory violations and the fight against corruption, either directly or after prior communication through PERSONA SERVICE's Internal Information System.