CERNAVAL, S.A.U.  a company dedicated to the REPAIR AND MAINTENANCE OF SHIPS ACCORDING TO OUR SCOPE DEFINED IN THE MANAGEMENT SYSTEM MANUAL, complying with the requirements established in Law 2/2023, of February 20, 2023, regulating the protection of people who report regulatory infractions and the fight against corruption, bases its WHISTLEBLOWING CHANNEL POLICY,  providing a frame of reference for the establishment of the objectives of the whistleblowing channel, in the following principles of action:

• Establishment of an Irregularity Reporting Channel in our service area, both within our organization and with the stakeholders defined in the Integrated Management Manual.
• Promotion of the continuous improvement of the implemented system through its periodic updating and review.
• Any harmful conduct in the organization is expressly prohibited.
• Trust, impartiality and protection of confidentiality throughout the whistleblowing process; ensuring such confidentiality in the reporting of irregularities throughout the reporting process.
• Two-way communication and ongoing collaboration are established, both within the organization and with stakeholders.
• The organization will provide guidance on how to submit the information and where to seek support or advice on the whistleblowing process;
• It is ensured that the whistleblowing channel manager will carry out his/her investigative and protection functions independently, confidentiality between those involved, the whistleblower, the whistleblower and the members of the investigation team, as well as correctness in all aspects of the whistleblowing channel process.
• Absolute respect for the presumption of innocence and the honour of the persons concerned.
• Any breach of our whistleblowing channel policy, such as deliberately false reports or conduct detrimental to the organisation, will result in disciplinary action assessed according to the classification of the offence in accordance with the sectoral agreement in the case of the organisation’s employees. In the case of other interested parties, it could lead to a complaint to the competent authorities.
• The competent authorities establish alternative reporting channels, such as the Andalusian Office against Fraud and Corruption (OAAF).
• The whistleblowing management system includes the receipt of the complaint, for its subsequent evaluation and, if it is deemed necessary, the complaint will be processed to finally issue a conclusion and resolution of the complaint.
• The possibility of establishing restrictions on the right to report, based on contractual obligations, such as disclosure agreements or clauses such as those relating to commercial confidentiality and employee confidentiality, among others, is totally excluded.
• Our data protection policy complies with the requirements established in Law 3/2018 on the Protection of Personal Data and Guarantee of Personal Rights.

In order for this Policy to be real and effective, it is available to customers, employees and other interested parties, integrated into the general management of the company.