The fundamental function of the SH GROUP Ethical Channel is the receipt of good faith communications based on reasonable indications about circumstances, facts, or behaviors that may constitute the materialization of infringements, irregularities, breaches, or weaknesses of the QMS, any of its policies and procedures and/or the regulations it seeks to cover, as well as those that may constitute a breach of regulations within the entity.

A communication is considered to be in good faith when the communicator has reasonable grounds, based on the information available at the time of the report, to believe that the communicated facts are true.

Information that is completely available to the public, rumors, and unconfirmed gossip will not be considered infractions or irregularities suitable for communication through the Ethical Channel.

Interpersonal complaints affecting only the reporting person, such as interpersonal conflicts between the whistleblower and other members of the organization, as well as any other doubts, complaints, or queries about their employment situation, will not be considered infractions or irregularities suitable for communication through the Ethical Channel and should be directed through the appropriate procedures separate from the Ethical Channel.

Communications made in bad faith, false, or malicious may lead to corresponding sanctions, without prejudice to civil and even criminal liabilities that may arise according to current and applicable regulations.

SH GROUP ensures the absence of retaliation against whistleblowers who have in good faith reported through the Ethical Channel any infringement or irregularity.

The data of the person making the communication and of the individuals involved in the reported incidents will be processed in accordance with current and applicable data protection regulations.

Access to data contained in the Ethical Channel management system will be limited exclusively to those performing internal control and compliance functions, or to data processors eventually designated for this purpose. However, access by other persons, or even communication to third parties, will be lawful when necessary for the adoption of disciplinary measures or for the processing of judicial procedures that may apply.

Personal data will be retained in the system only for the time necessary to decide on the need to initiate an investigation into the reported incidents.

SH GROUP has established the following means to implement the aforementioned communications:

• Specific email: lembun@shbarcelona.com

SH GROUP allows communications regarding potential regulatory and QMS infringements and its measures, policies, and procedures to be made anonymously or confidentially. Therefore, the following measures are established to implement anonymous communications:

• Sending the communication by postal mail addressed to the Compliance Officer (LAIA EMBUN) at the organization's address (CALLE CASANOVA 99 GROUND FLOOR, 08011 BARCELONA (BARCELONA)).

In case the Model of communication of indication or suspicion of non-compliance is not used, the minimum information to be provided is as follows:

• Date of the day the communication is submitted.
• Organization recipient of the information.
• Incidents subject to complaint:
• Data of the person or persons involved in the incidents.
• Date of the reported incidents.
• Description of the incidents to be reported.

In any case, whether the communication is made anonymously or confidentially, at the time of making the communication, evidence must be provided to substantiate the reported incidents.

SH GROUP guarantees the confidentiality or anonymity, as appropriate, of persons using the Ethical Channel, as well as the management of all personal data of the individuals involved in the procedure in accordance with current and applicable data protection regulations.

Likewise, the organization prohibits any type of retaliation against individuals who make good faith communications based on reasonable indications through the Ethical Channel.

In accordance with current and applicable personal data protection regulations, we inform you that your data will be incorporated into the processing system owned by Grupo Sh with headquarters located at CALLE CASANOVA 99 GROUND FLOOR, 08011 BARCELONA (BARCELONA)

• Purpose: Manage the filed complaint..
• Retention period: When the reason for the same ends, Grupo Sh. will keep your personal data blocked for the legal prescription periods or claims. After the legal prescription periods, we will destroy your data.
• Legitimate basis: Consent of the data subject and legitimate interest.
• Transfers: No data will be transferred to third parties, except legal obligation.

In accordance with the rights conferred by current and applicable personal data protection regulations, you may exercise the rights of access, rectification, limitation of processing, deletion (“right to be forgotten”), portability, and opposition to the processing of your personal data as well as revoke the consent given for the processing thereof, by directing your request to the postal address indicated above or to the email info@shbarcelona.com. You may address the competent Control Authority to submit the claim you consider appropriate.