COMMITMENT Aliseda Servicios de Gestión Inmobiliaria, S.L.

At Aliseda Servicios de Gestión Inmobiliaria, S.L.U., we firmly believe that the Company must be guided by the values that define how we work and relate to the environment. To do so, we rely on values such as excellence, teamwork, a focus on results and transparency, as well as zero tolerance for any behaviour that does not fall within the law and is guided by the highest ethical standards.

Our commitment is based on the following principles:

I. Establishing and integrating the set of actions necessary to prevent, detect and react to any possible commission of illicit acts.

II. Generating a culture of compliance and transparency.

III. Maintaining and improving channels to favour the communication of possible irregularities, queries or suggestions.

IV. Imposing the obligation to inform of anything that constitutes a possible illicit, criminal, fraudulent or irregular incident through the Reporting Channel.

V. Driving a culture of ethics and compliance: (i) by seeking responsible behaviour (ii) by promoting aware-raising and the establishment of protocols and committee for a proper training of the company's will, such that all the members of the organisation govern their actions and decision-making according to internal and external rules, (iii) to implement training, information and awareness programmes.

VI. To investigate all reports of an allegedly criminal incident, fraudulent act or irregularities according to what is set out in the Code of Conduct.

To that end, Aliseda has implemented and maintains a criminal risk management system focused on complying with the commitments taken on and on minimising the company's risk, moreover adopting a commitment to continuous improvement. To that end, a body has been established that is entrusted with the management of the system endowed with sufficient authority and independence to perform its task (Code of Conduct Committee).

In those cases, in which the company has evidence that an employee is infringing the above-mentioned commitments, it will act in accordance with the sanctioning regime set out in the Code of Conduct, adopting the measures that are considered appropriate, and if it were necessary, imposing the relevant sanction and/or bringing the relevant legal actions, according to the rules applicable in each case.

EXTERNAL REPORTING CHANNEL

To comply with all of the foregoing, we make available to every employee, customer, supplier, collaborator, partner, shareholder, or anybody who defends a legitimate interest, this Reporting channel, effectively to report all irregular, illicit or criminal behaviour that may be occurring, that has occurred or which is going to occur at Aliseda. Irregular, illicit or criminal behaviour is understood to mean any type of infringement of the law, violation of the Code of Conduct or inappropriate behaviour or behaviours contrary to the good practices of the market.

Communication to Aliseda SGI Reporting Channel shall be done:

The reports received must contained the details necessary to be able to carry out the analysis of the reported incident, that is:

  • If the report is made in writing and to be able to analyse the reported incident we need you to give us as much detail as possible.
  • Describe the incident in a simple but detailed way.
  • Identify the people or companies involved, as well as the area of the company to which they belong, if you know it.
  • Tell us when the incident occurred or is going to occur.
  • If you have documentation that supports the report or helps to resolve it, send us it.
  • Give us any other information you consider to be of interest.
  • Tell us your contact details, except in the case of anonymous reports.

When the report is received, it will be analysed by the Code of Conduct Committee. If there are indications of inappropriate behaviour, it will begin the investigation phase; if not, the inquiry will be shelved.

In compliance with what is set out in the personal data protection rules, Aliseda expressly states that the personal data included in the report and the file processed as a consequence thereof will be processed under the responsibility of Aliseda and their use will be limited to the processing and investigation of the report submitted, which provides its legitimate grounds.

The rights of access, rectification, opposition, erasure, portability, limitation of the processing, and any other rights that may be applicable that may be exercised by writing to the Data Protection Practitioner, Paseo de la Castellana, 290, 28046, Madrid, or by sending an email to dpo@alisedainmobiliaria.com.The personal data will be processed while the inquiry is being processed, and after that, they will remain duly blocked for a period of 3 years as from the end of the inquiry or of the legal actions to which it may have given rise.

Any complaint or request related to protection of personal data may be exercised before the Spanish Data Protection Agency.