Grupo Diagonal Plaza (Spring Hoteles, Intercontinental Barcelona y Maarlab Rethinking) Whistleblower System | Considerations in the use of the Ethical Channel

Without prejudice to the guarantees and rights described in the Ethical Channel Use Policy, it is important to highlight the following points about the use of the Ethical Channel:

The Ethics Channel is managed by the Head of the Ethics Channel.

They will have access to the communications received through the Ethics Channel: (i) the Responsible for the Ethics Channel and whoever manages it directly; (ii) the members of the Compliance Committee; (iii) if they have to sanction, the Human Resources Manager or the person or body competent to adopt disciplinary measures; (iv) if they have to adopt legal measures, the person in charge of the Legal Area; (v) where appropriate, those in charge of treatment who may be designated as, for example, advisors or managers, internal or external; and (vi) ) where appropriate, the data protection officer.

Misuse of the Ethical Channel may be sanctioned. For example, in case of reporting false facts or in bad faith.

All members of GRUPO DIAGONAL PLAZA have the obligation to report breaches of the Compliance System or applicable legislation of which they have become aware.