Internal System Information

I.- CODE OF ETHICS AND CRIME PREVENTION PLAN

TÉCNICAS MECÁNICAS ILERDENSES, S.L. (hereinafter “TMI” or “the company”) is a business that abides by ethical codes and principles, as well as all current legislation. The regulations in place for individuals and businesses evolve and are each time more complex. Unfortunately, in business, as in society, conducts categorised as crimes can happen accidentally or on purpose. Within the framework of social responsibility that characterises the company and with the will to prevent and avoid criminal conducts at TMI, the corporation has developed and implemented an internal crime prevention plan. In this context, TMI has approved a Code of Ethics or Business Conduct Code that specifies the Corporative Business Principles that must regulate the company’s activities and those of its members. It establishes non-negotiable conduct rules.

List of TMI’s Corporative Business Principles:

• Compliance with laws, rules, and internal conduct protocols.
• Respect for the integrity of individuals, security, and health at work.
• Commitment against corruption and bribery conducts.
• Commitment of the company in the fight against money laundering and fraud prevention.
• Commitment to tax compliance, social security, and requirements set by obtaining and applying for grants or public funding.
• Protection of confidential information of the company, workers, and third parties.
• Respect for intellectual and industrial property rights.
• Commitment to compliance with environmental protection rules and efficient use of resources.
• Commitment to quality.
• Avoidance of conflicts of interest.

II.- INTERNAL INFORMATION SYSTEM

In compliance with Spanish Law 2/2023 of 20 February, regulating the protection of the individuals who inform on rule breaking and fight against corruption, TÉCNICAS MECÁNICAS ILERDENSES, SL (TMI) states that it relies on an Internal Information System and its administration board is responsible for the processing of personal data according to current legislation in this field.

To strengthen TMI's information culture and dignity infrastructures, and to promote the culture of communication as a mechanism for preventing activities or omissions that may constitute criminal, serious or very serious administrative or occupational health and safety offences, the company has appointed the person Responsible for Criminal Compliance (RCP) as the person Responsible for the Internal Information System (RSII) and has activated, by various means, an Ethics Channel (in the relevant Internal Information Channel). To contact this service:

• At the email address: canaletic@tmipal.com
• Postal address: Calle Alcarràs, 66, P.I. Camino de los Frailes, 25190 Lleida (to the attention of the Responsible for Criminal Compliance and the Internal Information System)
• Through writing delivered to the Responsible for Criminal Compliance and the Internal Information System.

At the informant’s request, the communication may be submitted in a meeting with the RCP/RSII, within seven days.

III.- PROCESSING OF PERSONAL DATA

Under Law 2/2023, TMI will process personal data included in received communications to manage it and if necessary, start the pertinent investigation procedure. The legal basis of the processing will be compliance with a legal requirement stemming from the reference Law. If the communication contains data of a special nature, the legal basis will be the essential public interest and other provisions set in the second section of Article 9.2 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data. info@tmipal.com. In case of nonconformity with the processing of your data, you can file a claim to the Spanish Agency of Data Protection, the supervisory authority in these matters, located at C/ Jorge Juan, 6 (28001) Madrid (www.aepd.es).

IV.- NO REPRISAL

TMI expressly commits to not carry out reprisal acts, including threats or reprisal attempts, against the individuals who file a communication that complies with the provisions of Law 2/2023 and will apply protective measures for the informant during this process.

(*) The Internal Information Channel enables individuals to send anonymous communications.

(**) Although the Internal Information Channel is preferred, communications can also be sent to the Independent Authority for the Protection of the Informant or to the pertinent authorities or regional organisms (currently in Catalonia this would be the Anti-Fraud Office), the Public Prosecutor Office, or the European Public Prosecutor Office.