Ethics Line

TESET CAPITAL, SGEIC, S.A. (hereinafter “TESET CAPITAL”), through its governing body, has approved this Internal Information System Policy (the “Policy”) with the purpose of establishing an ethics channel through which any interested party may report irregularities. This is in accordance with Law 2/2023 of 20 February on the protection of individuals who report regulatory breaches and on the fight against corruption (hereinafter, the “Whistleblower Protection Law”).

This Policy defines the core principles and general guidelines of the internal information system, as established by the Whistleblower Protection Law:

• Implementing a structured procedure for managing received disclosures.
• Enabling whistleblowers to report information through secure and easily accessible channels.
• Guaranteeing the confidentiality of the identity of the whistleblower, any third parties named in the disclosure, and any proceedings related to the report and its handling.
• Safeguarding the rights of the person concerned, including the right to be informed of the allegations, the right to be heard at any time, the presumption of innocence, and the right to honour.
• Allowing disclosures to be submitted in writing (via email or postal mail) or through in-person meetings.
• Permitting anonymous reporting.
• Providing information on external reporting channels to the competent authorities and, where applicable, to European Union institutions, bodies, or agencies.
• Appointing a designated System Manager responsible for the operation of the internal channel.
• Establishing guarantees to protect whistleblowers.
• Forwarding information without delay to the Public Prosecutor or the European Public Prosecutor’s Office if the facts disclosed may constitute a criminal offence.
• Ensuring the processing of personal data in compliance with applicable data protection regulations.

To ensure the effective implementation of this Policy, a Protocol of Action has been developed. This protocol sets out the internal procedure for handling and managing disclosures and defines the human and material resources required for its application. See the PROTOCOL, which outlines the available internal channels, summarised as follows:

• By email, sent to canaletico@tesetcapital.com, which is the preferred internal channel for receiving reports.
• By postal mail, addressed to the attention of the System Manager at TESET CAPITAL’s offices located at C/ Monte Esquinza 35, 1st floor, 28010 Madrid.
• By in-person appearance before the System Manager, to be held within a maximum of seven days from the request for a face-to-face meeting, submitted via email or postal mail. The meeting will be recorded—with the informant’s prior consent—or fully transcribed, subject to review and formal acceptance by the informant through signature.

This internal information system is thus made available to individuals who act as whistleblowers within TESET CAPITAL, enabling them to report any irregular practices of which they may become aware, while ensuring full compliance with the rights and legal protections established by law.
This Policy and the corresponding Protocol governing the disclosure handling procedure will be periodically reviewed, updated, approved, and disseminated, and revised whenever a modification is required.