KYRYA GROUP, composed of BUJIOL SL., CROWE INVERSIONES SL, SOLID SURFACE INDUSTRIES SL., SAKYDU SL., hereinafter KYRYA GROUP, informs you of the existence of a complaints channel in compliance with the provisions of Art. 31. Bis of the Criminal Code.

This article regulates both the criminal liability of legal persons and the need for an organisation and management model to be implemented that includes appropriate monitoring and control measures to prevent crimes, in order to ensure that there is an exemption from their criminal liability.

In Art. 31.bis. Article 5 of the Criminal Code establishes the requirements that these management models must meet. One of them, provided for in point 4, is the existence of a means to report possible violations:

• “They will impose the obligation to report potential risks and non-compliance to the body responsible for monitoring the operation and observance of the prevention model.”

Therefore, this tool may be used by any KYRYA GROUP employee, or any other third party who may be aware of conduct that is unethical, fraudulent or illegal within our Organization.

In any case, this reporting channel complies with the provisions of the doctrine derived from the Prosecutor’s Circular 1/2016, of January 22 , and the provisions of DIRECTIVE (EU) 2019/1937 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of October 23, 2019 on the protection of persons who report violations of Union law pending transposition by Spanish legislation.

When the channel is used, the message will be transmitted to a qualified trusted provider that complies with the specifications provided for in Regulation (EU) No 910/2014 of the European Parliament and of the Council of July 23, 2014 on electronic identification and trust services for electronic transactions in the internal market and Law 6/2020, of November 11, regulating certain aspects of electronic trust services.

Said provider will comply with the instructions established by KYRYA GROUP and always in accordance with current legislation on data protection, guaranteeing compliance with the obligations provided for in Art. 28 of the GDPR.

This reporting channel is not the appropriate channel for issues relating to your employment conditions or disciplinary matters. In that case you must follow the procedures established in your organization.

The person responsible for data processing is KYRYA GROUP which, in compliance with a legal obligation provided for in Art. 31.bis.5 of the Criminal Code, will process the information for the purpose of managing complaints received through the channel, guaranteeing the confidentiality of the complainant’s data by keeping them anonymous unless their identification constitutes a necessary and proportionate obligation imposed by EU or national law in the context of an investigation carried out by national authorities or within the framework of judicial proceedings, in which case it must be communicated to the authorities competent in the matter.

Your data will be kept for a maximum period of 3 months from the date of entry into the channel, after which it will be destroyed and may remain blocked when necessary to demonstrate the operation of the crime prevention model.

For more information about the processing of your data or how to exercise your rights, please consult our Privacy Policy .