MERLIN Properties SOCIMI, S.A. (“MERLIN”) aspires that both its conduct, that of its subsidiaries (the “Affiliates” and, together with Merlin, the “Group” or the “MERLIN Group”) as well as that of its employees, managers and administrators within the MERLIN Group (the “Professionals”) respond and adapt, in addition to current legislation and its corporate governance system, to generally accepted ethical and social responsibility principles.

The Ethical Channel of MERLIN and its dependent companies is a tool whose objective is to provide a secure, anonymous and confidential means for anyone to report any irregularity or non-compliance related to bad practices within the organization, committed in relation to the requirements that emanate both from the Code of Conduct, the responsibilities of the Company's Criminal Risk Prevention Model, the values and principles of its Code of Conduct, the responsibilities of the Company's Criminal Risk Prevention Model, the values and principles of its Code of Conduct. Conduct and current legislation in the area of Criminal Liability of Legal Entities as well as in the field of workplace harassment.

Any third party that relates to MERLIN and who has reasonable indications of any Irregularity (a “Reporting Person”) may report it to MERLIN through this Ethical Channel. MERLIN Professionals will, in any case, be obliged to report any reasonable indication of any Irregularity.

The Reporting Person who in good faith report the alleged commission of conduct falling within the scope of application of the Ethical Channel will be protected from any type of retaliation, discrimination and penalization for reasons of the communications made.

Access to the data collected by the Ethics Channel will be limited exclusively to the Coordinating Counsel, the Director of Internal Audit and the members of the different Commissions of the Merlin Council, who are responsible for the functions of control and supervision. Only when disciplinary measures can be taken against a Professional can be taken, such access will staff with human resources management and control functions be allowed

Communications presented through this Channel can be anonymous, and their confidentiality is also guaranteed.

The Ethical Channel is understood as the channel established by MERLIN under the governance system to allow the communication of irregularities that are noticed within the Group, but in no case does it replace, nor can it be used as an alternative mechanism, to or from other legal or judicial channels that apply or for purposes other than those for which it is intended.