• INTRODUCTION AND PURPOSE
  ACMI is committed to preventing any illicit or non-compliance with applicable regulations and internal policies, by promoting upright behavior on the part of all its members and professionally linked third parties.
  To guarantee compliance with this commitment and, in accordance with the provisions of Law 2/2023, of February 20, regulating the protection of people who report regulatory infractions and the fight against corruption, ACMI has implemented a System Internal Information Channel, which integrates an internal complaints channel, whose main purpose is the registration and management, in a secure environment, of information on possible risks and non-compliance that may be communicated.
  The purpose of this Policy is to formalize the principles and guarantees of ACMI’s internal Information System, in order to preserve and protect the rights of the informants and the people, where applicable, affected by the communications made through of the internal channel.

AREA OF APPLICATION
AIM:
The following actions or omissions may be communicated through the internal channel, in the terms set forth in Law 2/2023:

• Violations of EU law provided they fall within the acts listed in the annex to the Directive (acts affecting public procurement, services, products and financial markets, prevention of money laundering and financing of terrorism, security of products, transport safety, environmental protection, radiation protection, food safety, animal health, public health, consumer protection, protection of privacy and personal data and security in networks and information systems ) or affect the financial interests of the EU or have an impact on the internal market.
• Serious or very serious criminal or administrative infractions, including in any case those that imply economic loss for the Public Treasury and Social Security.
• Violations regarding health and safety at work, without prejudice to the provisions of its specific regulations.

SUBJECTIVE:
Those who have obtained information about violations in a work or professional context may access the internal information system, including in any case:

• ACMI employees.
• Shareholders, participants and persons belonging to the management or supervision (including non-executive members) of ACMI.
• Any person working for or under the supervision and direction of ACMI contractors, subcontractors and suppliers.

Also applies to:
(i) informants who communicate or reveal information about violations obtained within the framework of a relationship that has already ended, volunteers, interns, workers in training periods, regardless of whether they receive remuneration or not;
(ii) those whose employment relationship has not begun due to information they have received during the selection or pre-contractual negotiation process.

The protection measures will apply to the legal representatives of the workers in the exercise of their functions of advice and support to the informant, to the natural persons who assist the informant in the process or those who are related to him and may suffer retaliation, as well as as well as the legal entities for which he works or in which he holds a significant participation.

INTERNAL INFORMATION SYSTEM
The internal information system is made up of the internal communication channel itself, the person responsible for the system and the procedure for processing and managing communications or complaints received.
The internal channel will be the preferred channel to report on the actions or omissions provided for in the previous section, provided that they can be treated effectively and if the complainant considers that there is no risk of retaliation, governed by the principles contained in this policy.
In any case, the filing of a communication in the internal channel does not prevent the filing of communication (external channels) before the pertinent national authorities, including the Independent Authority for the Protection of Informants or the competent counterpart authorities or bodies of the autonomous communities, as well as, where appropriate, before the institutions, bodies or agencies of the European Union.
The person responsible for the internal information system will be the natural person designated by the ACMI Administrator.

GENERAL PRINCIPLES
This Policy has the objective of introducing the necessary elements aimed at strengthening the adequate configuration of an internal information system at ACMI, as well as establishing its operating mechanisms, in order to ensure and certify that any communication that may be received is properly processed, analyzed and managed, in accordance with the rights and guarantees of the people involved in a communication. Specifically, these essential guarantees are the following:

• Anonymity: informants have the possibility of making communications, if they wish, anonymously.
• Confidentiality and data protection: the different participants in the management, control and/or supervision of the internal information system, as well as anyone who participates in the different phases of the investigation, have the duty of confidentiality with respect to all information to which they are disclosed. who may have access or knowledge due to the exercise of their functions. The most absolute confidentiality of the informant and the other participants is guaranteed during the procedure. For this reason, the identity of the informant will only be known by the person responsible for the Internal Information System and by those third parties who are necessary depending on the circumstances of each case. All of them will be obliged to maintain the strictest duty of confidentiality. Likewise, the reporting person has the duty to maintain secrecy regarding the communication made, as well as the identity of the person or persons affected and the facts and documentation that are the subject of the communication. The processing of personal data included in the channel will comply with what is regulated in the current personal data protection regulations as well as what is established in Title VI of Law 2/2023, of February 20.
• Independence and absence of conflict of interest: the System Manager will act independently at all times in the exercise of his or her functions.
• Good faith: the use of the channel must comply with the requirements of good faith and must be used rigorously and in a serious and responsible manner. It cannot be used for illegitimate, personal or contrary to good faith mobile phones. No employee and/or third party may be sanctioned for communicating facts or conduct as long as their communication and actions are protected by ethical behavior and under the conviction that they acted correctly and within the framework of good faith.
• Absence of retaliation: ACMI will ensure to avoid any retaliation that could arise towards any person involved in the investigation files, and specifically, towards the reporting person. No worker or third party may be sanctioned for communicating facts or conduct, as long as they act in good faith.
• Proportionality: only actions appropriate to the nature and circumstances of the facts being investigated will be carried out, and only those data that are strictly necessary will be collected in view of the purpose for which they are requested.
• Effectiveness and efficiency in the use of resources: trying to obtain the objectives pursued for the successful completion of the investigation.
• Respect for the presumption of innocence and the honor of the affected persons: ACMI will preserve these rights of the persons affected by a communication, and especially, in cases of unfounded, false or bad faith communications, against which it will be adopted. , if applicable, the corresponding disciplinary measures.
• Right of defense of the affected person: to be informed of the actions or omissions attributed to them and to be heard at any time; Said communication will take place in the time and manner considered appropriate to guarantee the successful completion of the investigation.
• Right of access to the file: the reporting person and the person affected by a communication may exercise the right of access to the file before the person responsible for the internal information system, safeguarding, in any case, the right to anonymity and confidentiality of the people involved. in the same.
• Transparency: ACMI’s internal Information System Policy will be public, accessible on the Company’s communication board in its offices.
• Accessibility: the preferred internal information channel will be via email through the address:

canalinformacion@acmi-solutions.com.

However, communications can also be made using the following channels:
Telephone: +34 682666873
Postal mail: ACMI SOLUTIONS SL
Attn. Responsible for the Internal Information System
C/ Castrobarto 10, 3rd floor, Office 16
28042 Madrid

Through any of the above means, the communication can be sent or a face-to-face meeting may be requested with the person responsible for the Internal Information System.

• Traceability: the information channel will allow the formulation of communications/queries that will be recorded, regardless of the route used and processed in accordance with the essential principles and with the guarantees established in this Policy.

APPROVAL, ENTRY INTO FORCE AND REVIEW OF THE DOCUMENT
This policy is approved today by the sole Administrator of ACMI and comes into force on this same day, being reviewed when circumstances require it.