First edition, September 2022.

In accordance with the policy of maintaining the highest standards of conduct and ethics, at GB we have implemented a Whistleblowing Policy, which will be known to all Grupo Binternational staff, employees, professionals or external collaborators, members of the management body and shareholders.

At GB we will investigate any suspicion of fraudulent, dishonest or improper use of the organisation’s resources or property by employees, consultants or external collaborators, members of the management body and shareholders.

We encourage all staff to report suspected fraudulent or dishonest behaviour (i.e. act as a “whistleblower”) in accordance with the procedures set out below.

Where the professional has any suspicions, he/she should report them to his/her supervisor. If, for any reason, it is difficult to report to a supervisor or staff member who oversees the employee’s work, he or she may report directly to the CEO.

A written report can be made in order to remain anonymous.

Procedure

Employees may report suspected violations of the Code of Ethics, Anti-Corruption Policy, applicable laws or other alleged irregularities through the communications channel: canalcomunicaciones@grupobinternational.com.

The report should provide as much information as possible to allow for a proper investigation, including where and when the incident occurred, names and titles of the persons involved, and as much other detail as you can provide.

Examples of concerns to report are listed below (this is a non-exhaustive list):

• Providing false or misleading information in Binternational Group financial or other public documents.
  Providing false information or withholding material information from Binternational Group’s management or auditors.
• Destroy, alter, mutilate, conceal, disguise, falsify or enter false information in any record that may be related to an official proceeding, in violation of national laws or regulations.
• Altering, destroying or concealing a document, or attempting to do so, with the intention of prejudicing the availability of the document for use in an official proceeding or obstructing, influencing or hindering any official proceeding, in violation of national law or regulations.
• Embezzle, receive benefits from Binternational Group (i.e. GB profits that benefit a member of the management body, member of senior management or administrative staff) and private benefits (i.e. Binternational Group assets used by any person in the organisation for personal gain or benefit).
• Paying for services or goods not rendered or delivered.
  The use of comments or actions of a sexual nature that are unwelcome and are likely to be seen as personally offensive.
• Using epithets, slurs, negative stereotypes and threatening, intimidating or hostile acts in relation to race, colour, religion, gender, nationality, age or disability.
• Circulating or posting written or graphic material in the workplace that denigrates or shows hostility or aversion towards an individual or group because of their race, colour, religion, gender, national origin, age or disability.
• Discriminate against an employee or potential employee because of race, colour, religion, sex, sexual orientation, national origin, age, physical or mental disability or veteran status.
• Facilitating or concealing any of the above or similar actions.

Individuals who recklessly make allegations may be subject to disciplinary action by the company and/or legal proceedings by those accused of such conduct.

Fraudulent or dishonest conduct is any deliberate action or inaction intended to obtain an unauthorised benefit. Examples of such conduct are listed below (this is an illustrative, non-exhaustive list):

• Forgery or alteration of documents.
• Unauthorised alteration or manipulation of digital files.
• Fraudulent financial information.
• Seeking a benefit or advantage in violation of GB’s conflict of interest policy.
• Misappropriation or misuse of GB resources, such as funds, supplies or other assets.
• Authorising or receiving compensation for goods not received or services not rendered.
• Authorising or receiving compensation for hours not worked.

A whistleblower is an employee, consultant or volunteer who reports to a supervisor or the Chief Executive Officer an activity related to the Binternational Group that he or she believes to be fraudulent or dishonest.

Obligations

Supervisors are obliged to report suspected fraudulent or dishonest conduct to the executive director or management body if they do not have an executive director in their department/area. Reasonable care should be taken in dealing with suspected misconduct to avoid:

• Unfounded allegations.
• Violations of a person’s rights under the law.

Due to the significant but sensitive nature of potential violations, effective professional follow-up is essential. Supervisors should not, under any circumstances, conduct investigations or follow-up actions on their own. Accordingly, a supervisor who discovers suspected misconduct:

• Should not contact the suspected person to investigate the matter further or demand restitution.
• Should not discuss the case with lawyers, the media or a third party other than the executive director.
• Do not report the case to the authorities without first discussing the case with the executive director or management body.
  Investigation

All relevant matters, including suspicious but unsubstantiated matters, will be reviewed and analysed.

Appropriate corrective action will be taken, where appropriate, and the results will be communicated to the complainant and his or her supervisor.

Investigations may warrant investigation by independent persons such as auditors and/or lawyers.

Whistleblower protection

GB will protect whistleblowers.

Whistleblowing will be handled with sensitivity, discretion and confidentiality to the extent permitted by circumstances and the law.

Whistleblower reports will only be shared with those who need to know so that GB can conduct an effective investigation, and in cases where required, involve the appropriate authorities.

In the event that disciplinary or legal action is taken against one or more individuals as a result of a whistleblowing report, those individuals may also be entitled to know the identity of the whistleblower.

Grupo Binternational employees, consultants and collaborators may not retaliate against a whistleblower for reporting to management an activity that that person believes to be fraudulent or dishonest.

Whistleblowers who believe they have been the victim of retaliation may file a written complaint with the chief executive officer or management body.

Any complaint of retaliation will be promptly investigated and appropriate corrective action will be taken if allegations of retaliation are substantiated.