EXTERNAL INFORMATION CHANNELS

AZ Capital guarantees the dissemination, in a clear and accessible way, on external information channels and on external reporting procedures before the competent authorities and, where appropriate, before the institutions, bodies, offices or agencies of the European Union.

Employees and Third Parties may report infringements within the material scope of application of the Internal Reporting System to the competent authorities and, where appropriate, to the institutions, bodies, offices or agencies of the European Union, through the external channels established for this purpose.

• External channels enabled by the European Union

Whistleblowers have the following external channels for reporting breaches of European Union rules and interests:

1. European Anti-Fraud Office (OLAF)

OLAF has its own external channel for reporting fraud or other serious irregularities with potential negative repercussions for the European Union’s public funds (income, expenditure or assets of the European Union institutions).

Complaints can be made anonymously through the following means:

• Online, through the fraud reporting system:
  https://fns.olaf.europa.eu/main_es.htm
• By post:
  European Commission
  European Anti-Fraud Office (OLAF)
  1049 Brussels
  Belgium

2. European Public Prosecutor’s Office (EPPO):

The European Public Prosecutor’s Office is an independent body of the European Union responsible for investigating crimes against the EU’s financial interests and prosecuting the perpetrators, in particular with regard to fraud, corruption, money laundering and cross-border VAT fraud. Complaints can be made:

• Online, through the «Report a Crime» service:
  https://www.eppo.europa.eu/es/form/eppo-report-a-crime

The European Public Prosecutor’s Office does not receive anonymous reports, so the reporting of violations through this channel requires the prior identification of the whistleblower.

• External channels enabled at the national level

At the national level, informants have the following external channels enabled for the communication of infractions:

1. Independent Whistleblower Protection Authority (AIPI)

The AIPI is a public body whose main function is to protect people who report any type of irregularity, corrupt practice or similar within private companies or public administrations, thus guaranteeing that the fact of reporting does not imply any retaliation for them.

Complaints can be made:

• Online, through the specific online reporting channel set up for this purpose:
  www.proteccioninformante.gob.es/canales-de-presentacion-de-informaciones
• By e-mail, to the following address:
  canal.externo@proteccioninformante.es
• By post, to the following address:
  Independent Whistleblower Protection Authority
  Calle Luis Cabrera 9, 28002, Madrid

AIPI makes it possible to make anonymous reports in the modalities that are possible but recommends that the way of communicating information anonymously is done through the protected and specialized internal or external channel.

2. Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC)

SEPBLAC has a form enabled for the communication of irregularities in the field of services, products and financial markets and the prevention of money laundering and the financing of terrorism.

The form enabled is as follows:
https://app.bde.es/gnt_seg/es/contacto?a=awfgkq4895oni82n7KuioINOnlmi993s

3. Bank of Spain

The Banco de España has a whistleblowing channel to confidentially report any infringement of the regulations on organisation and discipline carried out by an institution under the supervision of the Banco de España, or in the event of carrying out activities without due authorisation or registration in the mandatory registers.

The form provided for this purpose can be found in the following online reporting channel:
https://bde-canalexterno.integrityline.com

4. Anonymous Competency Informant System (SICA)

The National Commission on Markets and Competition (CNMC) has two external channels to make any complaint of possible infringements in the field of antitrust, mainly the following two:

• The SICA, anonymous and confidential online form, enabled online at the following online reporting channel:
  https://edi.cnmc.es/buzones-anonimos/alta-colaboracion
• By telephone through the following telephone number:
  + 34 671 483 741

Note that the option to make the call anonymously including #31# before the indicated telephone number is provided.

5. National Securities Market Commission (CNMV)

The CNMV offers several channels enabled for the communication of possible infringements related to the rules of regulation and discipline of the securities markets, which are the following:

• By telephone, through the following telephone number:
  900 373 362
• By e-mail, at the address provided for this purpose:
  comunicaciondeinfracciones@cnmv.es
• By mail, to any of the following addresses:
  • Notification of Infringements – Investors Department – CNMV
    C/ Edison 4, 28006 Madrid
  • Notification of Infringements – Investors Department – CNMV
    C/ Bolivia 56, 4ª Planta, 08018 Barcelona
  • Notification of Infringements – Investors Department – CNMV
    C/ Heros 3, 48009 Bilbao
• Online, through the form provided for this purpose:
  Complaints form

6. National Anti-Fraud Coordination Service (SNCA)

The SNCA is the body responsible for coordinating actions aimed at protecting the European Union’s financial interests against fraud, in collaboration with the European Anti-Fraud Office (OLAF). Through the whistleblowing channel enabled, information can be reported on fraud or irregularities affecting European funds.

Complaints can be made online, through the Infofraud service:
https://www.igae.pap.hacienda.gob.es/sitios/igae/es-ES/Paginas/denan.aspx

The SNCA form does not allow anonymous reports, so the communication of violations through this channel requires prior identification of the informant.

In addition, the SNCA has set up an email through which doubts and questions can be raised:
consultasantifraude@igae.hacienda.gob.es

• External channels enabled at the regional level

For the communication of non-compliances that are limited to their territorial scope and that do not fall within the competence of the Independent Authority for the Protection of Whistleblowers, some Autonomous Communities have set up their own external information channels, which are detailed below.

1. Anti-Fraud Office of Catalonia (OAC)

The OAC’s external online reporting channel allows you to report any information included in the material scope of the Whistleblowing Channel and in Law 2/2023, of 23 February.

Complaints can be made through the following means:

• Online, and anonymously, through the following reports box:
  https://denunciesanonimes.antifrau.cat/#/?lang=es
• By email, by filling out a form and sending it to the following email address:
  https://www.antifrau.cat/sites/default/files/Documents/Denuncieu/formulario-asistente-persona-denunciante.pdf
  bustiaoac@antifrau.cat
• In person, by submitting a letter to the general registry of the OAC or to the registry of any public administration:
  Anti-Fraud Office of Catalonia
  Calle Ribes, 1-3
  08013 Barcelona

2. Andalusian Anti-Fraud Office (OAAF)

The OAAF enables an external whistleblowing channel to report facts that could constitute fraud, corruption, conflict of interest or any illegal activity that is detrimental to public or financial interests in the territorial area of Andalusia.

In general terms, the scope of action of the OAAF includes the entire Andalusian public sector, local administration, public universities and other dependent entities, as well as the activities of natural or legal persons who are contractors of the same, beneficiaries of subsidies or public aid, holders of authorizations or, in general, those who have had any type of economic relationship.  professional or financial with the public entities described above.

Complaints can be made anonymously through the following means:

• Online, through the reports box:
  https://buzon.antifraudeandalucia.es
• By email:
  antifraudeandalucia@antifraudeandalucia.es
• By post:
  Calle San Juan de Ribera, S/N
  Hospital of the Five Wounds
  41009 Seville
• In person (verbally or in writing) at the OAAF, at the postal address indicated above.
• By phone or video call, via the number (+34) 954 59 21 20.

3. Office for the Prevention and Fight against Corruption in the Balearic Islands (OAIB)

The OAIB offers an online reporting channel so that anyone can report a situation of fraud or corruption involving the Balearic public sector, its local administration, public universities and other dependent entities, as well as fraudulent situations involving natural or legal persons who are contractors of the same or beneficiaries of subsidies or public aid.

Complaints can be made online, anonymously or by identifying the whistleblower, through the following form:
https://denuncies.oaib.es/#/

4. Anti-Fraud Agency of the Valencian Community

The channel allows anyone to provide information on cases of fraud or corruption involving the public sector of the Valencian Community, as well as to natural or legal persons who are contractors, subcontractors, concessionaires of the same or financed or subsidized by them.

Specifically, the following may be reported: (i) cases of irregular use or destination of public funds and conduct contrary to integrity or contrary to the principles of objectivity, effectiveness and full submission to the law and the law; (ii) conduct by personnel in the service of public entities that involves the use or abuse, for private benefit, of information that they have by reason of their functions, or conduct that has or may result in the irregular use or destination of public funds or any other use contrary to the legal system; and (iii) acts or omissions that could constitute an administrative, disciplinary or criminal offense.

Complaints can be made online, anonymously or by identifying the whistleblower, through the following form:
https://bustiadenuncies.antifraucv.es/#/

5. Galician Authority for the Protection of Whistleblowers (AGPI)

The external channel enabled by the Community of Galicia allows citizens to be informed in a secure and confidential way about any irregularity of which they are aware.

Complaints can be made by various means, namely:

• Online, through the form provided in the following online reporting channel:
  https://canalexterno.apigalicia.gal/#/
• In writing, by post or by email:
  apigalicia@apigalicia.gal
• Verbally, by telephone or through a voice messaging system, through the following telephone number: +34 981 569 760
• In person, requesting a meeting at the AGPI headquarters through the telephone number indicated above.

6. Independent Authority on Corruption of Castilla y León (AICCyL)

The Community of Castilla y León has its own external information channel in order to manage information on breaches of European Union law and serious criminal and administrative offences, protecting whistleblowers.

Complaints can be made through the following form:
https://consejodecuentas.sedelectronica.es/complaints-channel.0

In addition, the possibility of going in person to the headquarters of the AICCyL or submitting the communication via postal mail is enabled.

7. Regional Council for Transparency and Good Governance of Castilla-La Mancha (CRT CLM)

The Community of Castilla-La Mancha has various external channels with respect to which to report any regulatory infringement of which citizens are aware.

Complaints may be made through the following channels:

• In writing, by post addressed to the External Channel of Castilla-La Mancha, at the following address:
  Bajada del Calvario s/n, 45002 Toledo
• Verbally, by telephone or by voice messaging.
• In person, by requesting a face-to-face meeting with the Council.
• Online, through the following form provided for this purpose:
  https://canalexterno.consejotransparenciaclm.es/#/

8. Transparency and Data Protection Council of the Community of Madrid (TCDC)

Through the TCDC, the Community of Madrid has its own external channel to report possible infringements. Such information may be communicated through the following means:

• In writing, by post to the following address:
  Calle Carrera de San Jerónimo 13, 28013 Madrid, Community of Madrid.
• By e-mail, at the following address:
  canalexternoinformantecm@madrid.org
• Verbally, by telephone or voice messaging.
• In person, requesting a meeting with the Council.
• Online, through the following form:
  Communication of Information | Community of Madrid

9. Office of Good Practices and Anti-Corruption of the Autonomous Community of Navarre (OANA)

The external channel enabled by the OANA allows you to report any action that could constitute fraud, corruption or conflict of interest, and that involves the Navarrese public sector or dependent bodies.

Complaints can be made anonymously through the following means:

• Online, through the reports box:
  https://oana.es/es/denuncia#
• In person, at the general registry of the OANA or any public administration:
  Office of Good Practices and Anti-Corruption
  Avenida de Bayona, 36, 1ºA
  31011 Pamplona (Navarra)

In any case, the following link on the AIPI website provides an updated update on the external communication channels:

Information on Other External Information Channels – proteccioninformante.es