Ethics and Legal compliance » ITE Integración Tecnológica Empresarial

Letter from Our CEO to the ITE Group

Dear Collaborators,

Thank you for taking the time to read our Code of Ethics and Business Conduct. In this document, we express the effort and dedication we put in every day to be a benchmark Group in the sector.

The growth of our Group has been possible thanks to our values, which establish a culture that fosters transparency and empowers employees with the necessary tools to prevent, detect, and respond to all ethics-related issues.

Our Code of Ethics and Business Conduct defines who we are, how we behave, and what we believe in.

At the Group, we guarantee safety, focus on our clients, pursue excellence, and act with integrity.

We are all responsible for adhering to the Code and have the duty to report in good faith any ethical concerns. Remember, you are the voice of our values. Take the time to read and understand the Code, and encourage your colleagues to do the same.

Additionally, we invite you to ask questions or report any misconduct you may observe. Our policy is not to take any retaliatory action against anyone who reports in good faith.

I am confident that together we will achieve our goal of building a company for the future, based on these values that provide us with added value and make us proud of our brand.

I count on you.

Best regards,
Oven Martin Acedo
CEO, ITE Group

1. Our Values

Our values provide us with security and keep us on track. They represent how we conduct business, how we express ourselves as a Group, and how we interact with stakeholders, inspiring their trust.

We Are Reliable

This is what our clients tell us through the trust they place in us. Our actions always demonstrate respect toward our clients.

We Are Committed

To our clients and their needs, continuously improving the services we offer. Our purpose is to serve our clients and help them optimize their costs.

We Are Professionals

We understand that our service must always be agile and efficient, providing solutions to our clients’ needs.

We Are Happy People

For our company, this is one of the most important values. Happiness fosters creativity and initiative. People are the driving force of the company and help uphold the three previous values.

2. What We Expect from Our Managers

Our managers have additional responsibilities under our Code. They are responsible for fostering a culture of compliance and integrity and for ensuring a positive work environment where people are treated with dignity and respect.

As managers, we must achieve this goal by:

Leading by example and always adhering to the rules of our Code.
Helping those under our supervision understand and comply with the rules outlined in our Code, our policies, and our operational procedures, as well as encouraging their participation in relevant training and certifications.
Supporting and protecting individuals who, in good faith, raise concerns or report unethical behavior or violations—even if doing so requires them to step outside the chain of command. This includes never retaliating against anyone who raises a concern in good faith.
Following up when we become aware of or suspect possible misconduct and never ignoring any suspicious behavior.

3. Scope of Applicable Regulations

The Code applies to all companies within the ITE Group and is binding on all personnel, regardless of their position or role.

The application of the Code, in whole or in part, may be extended to any individual or legal entity associated with the Group when necessary for fulfilling its purpose and when permitted by the nature of the relationship.

The Code will be personally communicated to all executives and any person representing the company when required by the nature of their relationship. These individuals must formally commit in writing to comply with it. Furthermore, adherence to the Code will be explicitly included in employees’ employment contracts, and they will receive a copy upon joining the company, along with the Welcome Manual.

4. Mutual Respect in the Workplace

One of our company’s core values is its people. Therefore, ITE Group is committed to fostering a healthy and productive work environment that nurtures the potential and creativity of each of us while promoting collaboration and teamwork. We all have the right to work in an environment where fundamental human rights are respected.

Company personnel must contribute to the strict compliance with applicable labor regulations and support the prevention, detection, and eradication of any irregularities in this area.

All employees are required to act in their professional relationships with colleagues based on respect, dignity, and fairness, considering each individual’s cultural sensitivity and not allowing any form of:

Violence: The use of physical force that causes or could cause injury, or any actions, behaviors, or comments that could reasonably be perceived as a threat to a person’s safety or physical integrity.
Harassment or workplace abuse, whether sexual, psychological, or otherwise, occurs when behavior toward another person is offensive or shocking, affects their dignity or psychological/physical well-being, and creates a harmful work environment.
Discrimination based on race, religion, age, nationality, gender, or any other personal or social condition unrelated to merit and ability. Special consideration should be given to the care and inclusion of individuals with disabilities.

All employees are responsible for strictly complying with health and safety regulations in the workplace and ensuring both their own safety and that of others affected by their activities.

The consumption of substances that could impair the proper fulfillment of professional duties is strictly prohibited.

5. Customer Relations and Negotiation Terms

The purpose of the ITE Group is to be the best choice for its customers. That is why we treat them with professionalism and integrity while providing high-quality products and services on time and under the conditions agreed upon in our offers.

To ensure a long-lasting relationship with our customers, we strive to anticipate their needs, exceed their expectations, and build a relationship of trust that results in mutual benefits.

All employees must act in their interactions with customers based on consideration, respect, and dignity, taking into account different cultural sensitivities and ensuring no discrimination in treatment based on race, religion, age, nationality, gender, or any other personal or social condition prohibited by law. Special attention should be given to the care and inclusion of individuals with disabilities.

In carrying out their commercial activities, ITE Group employees must promote the company’s products and services without misrepresenting their conditions or characteristics.

All personnel are responsible for safeguarding the security of the company’s payment systems to ensure proper functioning, traceability of billing and collection procedures, customer data protection, and fraud prevention.

6. Relations with Authorities and Officials

Employees who interact with public administrations must document the decisions made and provide evidence of compliance with applicable internal and external regulations. This ensures that third parties and the company’s control bodies can review regulatory compliance in this area.

It is the responsibility of each employee to be aware of and properly assess practices when dealing with Ministries, always considering the company’s interests and good reputation. In case of doubt, employees must consult the Group’s management.

Group employees must refrain from making facilitation or expediting payments, which involve giving money or other items of value—regardless of the amount—in exchange for securing or speeding up any type of procedure or action before any judicial body, public administration, or official organization.

Employees must avoid obtaining improper tax advantages for any company within the Group and ensure that the information declared to the authorities in this regard is truthful and accurately reflects the company’s reality.

They must also ensure that any aid requested or received from public administrations is used appropriately, that its application process is transparent, and that conditions are not falsified to obtain it, nor is it used for any purpose other than that for which it was granted.

7. Relationship with Suppliers

The development of trust-based and mutually beneficial relationships with suppliers has contributed to the success of Grupo ITE.

The selection of suppliers will be governed by criteria of objectivity and transparency, balancing the company’s interest in obtaining the best conditions with the importance of maintaining stable relationships with ethical and responsible suppliers.

All suppliers working with Grupo ITE must commit to respecting the human and labor rights of all contracted employees. Any violation of these principles will not be accepted by the Group under any circumstances.

Procurement and supply activities must be carried out in strict compliance with the company’s current regulations and procedures. All decisions made in this area must be documented, ensuring they are justifiable, verifiable, and auditable in the event of a Quality Audit or a review by any executive seeking to trace a project’s process.

All purchasing and procurement processes must adhere to fair competition principles. Any exceptions to this rule must be clearly justified.

Our personnel are obligated to protect commercially sensitive information regarding the conditions established by the company in relation to its suppliers.

No Group employee may offer, grant, request, or accept—directly or indirectly—gifts, favors, or compensation, whether in cash or in-kind, of any nature.

Any gift or favor received in violation of this Code must be immediately returned, and the incident must be reported to the company’s management.

In particular, no employee may offer, grant, request, or accept gifts or favors from any individual or entity with which any company in the Group has any form of relationship that, whether individually or cumulatively within one year, exceeds a value of 100 euros.

Cash gifts are expressly prohibited.

Remember: A buyer must not only be honest but also appear to be honest.

The ethical principles of a buyer are:

Always maintain loyalty to the company.
Uphold an impeccable level of integrity in all business relationships, both within and outside the company.
Optimize the use of resources for which they are responsible to provide maximum benefit to the company.
Promote the highest professional standards and uphold the prestige of the procurement profession.
Refrain from any personal business dealings that may conflict with or appear to conflict with the company’s interests.
Handle confidential company and supplier information with due caution and respect.
Foster mutually beneficial relationships with suppliers through courtesy and impartiality in all phases of the purchasing cycle.
Do not accept personal gifts that are not considered business courtesy gifts, such as pens, calendars, etc. Likewise, do not accept entertainment at the supplier’s expense that could compromise or appear to compromise negotiation capabilities and impartiality.
Always demonstrate impartiality and objectivity in procurement decisions.

The main advantage of implementing an ethical procurement code is that it provides employees in these departments with clear guidelines on what is and isn’t permissible.

8. Use of Company Assets and Services

The proper use and respect for company assets are fundamental elements that contribute to achieving our Mission.

Assets include all tangible and intangible goods owned by the organization, such as buildings, machinery and equipment, inventories, cash, accounts receivable, stocks, and securities. These assets have economic value for the company.

Each of us is responsible for the custody and protection of the assets under our control. Under no circumstances should we engage in, influence, or allow situations or actions related to theft, misuse, lending, unauthorized rights, or the unauthorized sale of assets without the approval of the Group’s management.

Additionally, it is the responsibility of the personnel involved in each area to keep these assets in good condition, ensure that maintenance is carried out, and implement risk prevention programs. All of this is aimed at preventing accidents and extending the lifespan of our assets.

9. Electronic Resources

All electronic communications related to work activities must be conducted through the corporate email address. The use of non-corporate email addresses to send or receive work-related communications is strictly prohibited.

The electronic resources provided by the Group are the exclusive property of the company and must be used responsibly, appropriately, and ethically. Company electronic resources must never be used for the exchange, storage, or processing of content that: is prohibited by law (such as the illegal downloading of material protected by intellectual property laws); promotes or incites harassment; could be perceived as racist, defamatory, discriminatory, violent, harmful, sexist, or pornographic; or could damage the reputation of the Group.

In any case, when using electronic resources, we must take the necessary precautions to avoid compromising the integrity of the company’s equipment or systems, or disclosing private or confidential information.

Grupo ITE may exercise its rights to monitor the use of its electronic resources and reserves the right to control and review the content sent, stored, and processed through the company’s electronic resources, as permitted by law. It is understood that, during the course of our duties and activities within the Group and to the extent permitted by law, we waive any right to privacy regarding any information sent, stored, or processed using the company’s electronic resources.

10. Confidential or Privileged Information

(INFORMATION CLASSIFICATION STANDARD: NR-A.8.2 INFORMATION CLASSIFICATION Annex I)

Employees of the Group are obligated to protect the information and knowledge generated within the organization, whether owned by or entrusted to it.

Confidential information is understood as any non-publicly disclosed information related to the company, its executives, stakeholders, operations, activities, plans, investments, and strategies.

Confidential information may only be handled by individuals who need to access it to make appropriate decisions.

Employees must refrain from using any data, information, or documents obtained during their professional activities for personal gain. They must not disclose information to third parties, except when required by applicable regulations, company policies, or when expressly authorized. Likewise, they must not use confidential data, information, or documents from third-party companies without written authorization.

Additionally, employees must not duplicate, reproduce, or use confidential information beyond what is necessary for their tasks, nor store it on non-company-owned information systems, except when expressly authorized for specific purposes.

The obligation of confidentiality remains in effect even after leaving any company within the Group and includes the requirement to return any company-related materials in the employee’s possession upon termination of their relationship with the organization.

The following is a non-exhaustive list of confidential or privileged information:

Accounting information and financial projections.
Mergers, acquisitions, partnerships, expansion plans, and business plans.
Securities transactions and financing operations.
Business and operational policies and practices.
Judicial or administrative disputes.
Organizational changes.
Research and development of new products.
Personal information of employees across all Grupo ITE companies.
Intellectual and industrial property, such as trade secrets, trademarks, patents, and copyrights.
Client and supplier lists, pricing structures, and policies.

11. Protection of Intellectual and Industrial Property

(Regulatory Compliance Standard: NR-18 COMPLIANCE Annex II)

Employees of the Group must take the necessary measures to protect intellectual and industrial property, ensuring that processes and decisions in this area are traceable, meaning they must be documented, justified, and verifiable.

This is particularly important through the proper titling of works, creations, or distinctive signs, as well as the application of contractual clauses that guarantee both the originality of the work and the lawful use of third-party assets.

12. Record-Keeping of Transactions

All economically significant transactions carried out by the company must be clearly and accurately recorded in appropriate accounting records that faithfully represent the executed transactions. These records will be made available to both internal and external auditors.

Employees must enter financial information into the company’s systems in a complete, clear, and precise manner, ensuring that it correctly reflects the company’s rights and obligations as of the corresponding date, in accordance with applicable regulations. Additionally, financial information that must be disclosed to the market will be handled with rigor and integrity in compliance with current regulations.

The use of company funds or assets for any illicit or improper purpose is strictly prohibited. This includes false or misleading entries, unregistered bank accounts, and improper or unusual financial agreements with third parties, such as overbilling or underbilling in sales, purchases, or other activities. The company’s management and accounting record-keeping personnel must remain vigilant not only to enforce this prohibition but also to ensure the proper use of the Group’s assets.

The company is committed to implementing and maintaining an adequate internal control system over financial reporting, ensuring its effectiveness through regular monitoring. Accounting records will always be available to both internal and external auditors. To this end, the Group is committed to providing its employees with necessary training, ensuring that they understand and comply with the company’s internal control obligations regarding financial information.

13. Environmental Commitment

Grupo ITE considers its commitment to the environment a top priority within its Corporate Social Responsibility strategy.

Employees of Grupo ITE will conduct their activities in a manner that promotes the company’s social and environmental sustainability, ensuring the responsible creation of value for all stakeholders.

Our business model is inseparably linked to our social and environmental commitment, ensuring that our activities benefit both people and the planet.

How Grupo ITE Contributes to Environmental Responsibility:

Encouraging employees to actively participate in building a sustainable environment.
Reducing energy consumption by improving the energy efficiency of our buildings and facilities.
Implementing selective waste collection and recycling, with a particular focus on paper.
Minimizing paper usage by replacing it with digital systems whenever possible.

14. Media Relations

(Welcome Package – Annex III)

All relations with the media will be managed through the Corporate Communications Department (or any future department that assumes these responsibilities).

Grupo ITE’s financial and economic information, particularly its annual accounts, must faithfully reflect its true economic, financial, and asset situation, following generally accepted accounting principles and applicable international financial reporting standards.

To this end, no employee shall conceal or distort information in the Group’s records or financial reports, ensuring that all information provided is complete, accurate, and truthful.

A lack of honesty in communication—whether internally (with employees, subsidiaries, departments, internal committees, or governing bodies) or externally (with auditors, shareholders, investors, regulatory agencies, and the media)—violates the company’s Code of Ethics.

Additionally, it is considered dishonest to provide incorrect information, present data in a misleading way, or attempt to confuse those receiving the information.

Legal Compliance

Index

1. Introduction
2. Scope of Application and General Provisions
3. Principles and Guarantees of the Whistleblowing Channel
4. Operation of the Whistleblowing Channel
4.1 Access and Functioning of the Channel
4.2 Registration and Classification of Reports
4.3 Preliminary Analysis of Reported Facts
4.4 Verification of Reported Facts
4.5 Resolution of the Report
4.6 Information Retention
4.7 Reports from External Personnel to ITE
5. Whistleblower Protection
6. Disclosure

Annex

1. Introduction

The Whistleblowing Channel is a communication tool for companies that allows employees, clients, or suppliers to report unethical or irregular behavior via the Internet.

On February 21, 2023, Spain’s Official State Gazette (BOE) published the Whistleblower Protection Law, transposing Directive (EU) 2019/1937, also known as the Whistleblowing Directive.

This system is securely designed, established, and managed to ensure the confidentiality and anonymity of the whistleblower’s identity, as well as any other individuals mentioned in the report. It also guarantees the confidentiality of any actions taken in the handling and processing of the report, along with data protection measures that prevent unauthorized personnel from accessing the information.

INTEGRACIÓN TECNOLÓGICA EMPRESARIAL S.L. (hereinafter, ITE) strictly prohibits any form of retaliation against whistleblowers who, in good faith, report incidents through this channel that may constitute regulatory violations by its professionals, in accordance with applicable laws.

Furthermore, any whistleblower aware of irregular conduct, non-compliance, or violations of regulations may also report them to the relevant authorities and, where applicable, to the institutions, bodies, or agencies of the European Union.

In Spain, reports may be submitted, for example, to the following organizations, depending on the nature of the irregularity:

AII (Autoridad Independiente del Informante) once established
AEPD (Agencia Española de Protección de Datos) – www.aepd.es
CNMC (Comisión Nacional de los Mercados y la Competencia) – www.cnmc.es
CNMV (Comisión Nacional del Mercado de Valores) – www.cnmv.es

2. Scope of Application and General Provisions

The objectives of ITE’s corporate policy for the Whistleblowing Channel are:

To prevent and detect improper behavior by the company and its personnel.
To encourage ITE staff to report suspected misconduct as soon as possible.
To provide ITE personnel with guidance on how to report concerns.
To assure ITE personnel that they can raise concerns in good faith without fear of retaliation, even if their reports turn out to be incorrect.

This corporate policy does not form part of any employee’s employment contract and may be modified at any time. Likewise, the Whistleblowing Channel is available to ITE’s stakeholders, suppliers, vendors, and business partners, provided that the reported misconduct involves ITE personnel.

This Policy applies to all branches and divisions of the company.

ITE’s governing body is responsible for establishing the foundations for appropriate and efficient coordination among all branches and divisions, in accordance with the company’s corporate interests.

Therefore, it is responsible for approving this Policy, thereby fulfilling its role of setting the framework, defining the necessary tools, and designing the mechanisms required for effective coordination in whistleblowing management activities.

Responsibilities of the Head of the Legal Department

Receiving Reports: Will receive reports related to accounting matters, audit issues, internal controls over financial information, and any cases of fraud—whether material or not—that affect Management, as well as any findings arising from the audit of such cases.
Periodic Reporting: Will periodically inform management about the activities related to the Whistleblowing Channel.
Case Registration and Processing: Will handle the registration and processing of reports concerning the company. Once a report is formally recognized as a complaint, the necessary verification and review of the alleged facts will be conducted. After this review, the case file will be forwarded to the relevant departments for further action.
Access to Information: Will ensure that the relevant departments have full access to the content of the Whistleblowing Channel and receive all reports generated from the review of reported incidents.
Action Plan Development and Monitoring: The affected departments will participate in designing and monitoring action plans. To mitigate the consequences of a potential violation, if the reported incidents impact their area of responsibility, they may request to be involved in the design and follow-up of the corresponding action plans.

3. Principles and Guarantees of the Whistleblowing Channel

Regulatory Compliance: Legality and corporate ethics are integral pillars of the Channel. Reports will be handled with integrity and professionalism, in compliance with applicable laws and regulations, including data protection regulations, as well as internal policies and procedures.
Independence and Impartiality: This Policy ensures that all individuals affected by a whistleblowing report are treated fairly and impartially. All parties involved in the investigation of a report will act in good faith in the pursuit of truth and clarification of the facts.
Transparency and Accessibility: Information about the Channel and its management procedures will be communicated clearly and comprehensibly. The Channel is available on the website https://www.ite-es.com to maximize accessibility.
Traceability and Security: This Policy incorporates all necessary measures to guarantee the integrity, monitoring, and security of the information.
Confidentiality and Anonymity: The Policy ensures, to the maximum extent possible, the anonymity of the whistleblower (if requested and legally permitted) and the confidentiality of the information reported, as well as the proceedings carried out during its management and processing. The Channel also allows for anonymous reports.
Discretion: The Policy promotes the utmost discretion among those involved in processing and investigating reports, ensuring confidentiality regarding the facts they learn in their role.
Diligence and Promptness: This Policy guarantees that the investigation and resolution of reported facts will be handled professionally, diligently, and without undue delays, ensuring the process is completed as swiftly as possible while respecting the necessary guarantees.
Good Faith: The Policy ensures that reported information is honest and truthful, recognizing that the whistleblower may unintentionally include inaccuracies or omissions. Reports should be as complete as possible while maintaining confidentiality, anonymity, and due process.
Respect and Protection of Individuals: Measures will be taken to safeguard, to the greatest extent possible, the dignity and privacy of affected persons.
Respect for Fundamental Rights: The Policy guarantees the right to information while upholding confidentiality and anonymity principles, the right to defense, the right to be heard, the presumption of innocence, and the right to honor for all individuals involved in the process.
Protection Against Retaliation: Whistleblowers acting in good faith will be protected against retaliation to the fullest extent possible.

Data Protection Compliance in the Whistleblowing Channel:

— All areas must implement the necessary security measures for personal data according to the risk level established for the Whistleblowing Channel or, where applicable, the mandatory measures required by law and internal regulations. The security level must be at least equivalent to that set for sensitive or special category data, in accordance with applicable data protection laws.

— Proper compliance with the processing of personal data must be ensured, particularly concerning data subjects’ rights to be informed about the handling of their information, in full accordance with the applicable national legislation.

4. Operation of the Whistleblowing Channel

4.1. Access and Functioning of the Channel

The Whistleblowing Channel will be accessible through the following means:

Dedicated email address for the whistleblowing channel: webmaster@ite-es.com
Postal mail: Complaints or reports can also be submitted via letter addressed to the attention of the Head of the Legal Department.

To ensure anonymity, if the whistleblower wishes, it is recommended to create a dedicated email account for submitting the report and maintain it throughout the process until its resolution.

Employees submitting a report should provide as much detail and information as possible to assist the investigation. The company’s policy is to handle reports seriously and promptly. Reports must include at least the following information:

Identification of the person(s) reported.
Dates and locations of the events.
Personnel who may corroborate the alleged misconduct, if applicable.
Description of the alleged infraction or offense.
A means of communication with the whistleblower, even if submitted anonymously, to request additional information if needed.

Without the mentioned information, it may not be possible to investigate the reported conduct, which could lead to the inability to resolve the complaint. Additionally, if the complaint is anonymous and further details are required but the whistleblower cannot be contacted, the investigation may not be feasible.

The Whistleblowing Channel is centralized and applies to all company branches and departments. Whistleblowers who wish to remain anonymous may do so with full guarantees as established in this Policy.

Any action taken to prevent an employee from submitting a report through the Whistleblowing Channel will be subject to disciplinary action in accordance with the applicable labor and disciplinary framework.

The registration, processing, verification, and resolution of reports will be carried out as swiftly as possible, taking into account the nature of the allegations and any relevant circumstances.

4.2. Registration and Classification of Reports

All reports received will be analyzed independently by the Head of the Legal Department, ensuring confidentiality of both the whistleblower’s and the reported party’s identity.

Once a report is received, it will be assigned a correlative identification code and recorded in a database, where its classification and processing status will be tracked. The database will be updated throughout the different phases of the procedure.

Report Registration Details

The registration document will include at least the following information:

Total number of reports received through the Whistleblowing Channel.
Status of the reports.
Nature of the reports.
Number of reports not processed and reasons.
Time required to complete investigations (if necessary) and reach a conclusion.
Measures taken in response to confirmed violations, as well as preventive measures for the future.

The whistleblower will receive written confirmation of the submission and registration of their report to acknowledge compliance with the general duty of cooperation mentioned in Section 1 of this Policy.

Report Classification

Reports will be classified based on their level of importance, using a scale from 1 to 5:

1 – Most critical reports.

5 – Least critical reports.

Factors for Higher Priority (Rating 1 Reports)

Situations that could result in criminal liability for the company or its executives, including (but not limited to) those potentially classified as corruption in the public sector.
Situations where there is a risk of violating current legislation.
Situations that, if publicly disclosed, could harm the company’s reputation.
Situations that threaten business continuity.
High financial impact associated with the founded report.
Number of people or departments affected by the reported issue.

Reports involving corruption will automatically receive a Rating 1 classification.

This classification determines the priority level for reviewing the report and allocating resources. After a preliminary assessment, a provisional rating will be assigned.

If new information emerges that justifies modifying the initial rating, the priority level will be reassessed and properly documented.

Categorization of Reports

Reports received will be categorized according to their nature, following the classifications detailed in the Annex.

The classification system may be updated as needed to align with evolving informational requirements. It must always differentiate and specifically address reports related to:

Accounting irregularities.
Internal controls over financial reporting.
Audit-related matters.

Additionally, reports concerning discrimination, workplace harassment (mobbing), sexual harassment, or gender-based harassment will be handled in accordance with specific procedures established by the company for such cases.

Data Retention Policy

All data recorded in the Report Register and Investigation Files will be retained only as long as necessary and in accordance with national legal requirements. Once this period expires, the responsible party must ensure its secure deletion.

4.3. Preliminary Analysis of Reported Facts

Once a report is received, the Head of the Legal Department will determine whether to proceed with the case based on the minimum requirements established.

If the report is manifestly unfounded or, in the case of an anonymous report, lacks sufficient information to verify the reported facts, it will not be processed.
This decision will be documented accordingly.

4.4. Verification of Reported Facts

If the preliminary analysis deems it necessary, the Head of the Legal Department will conduct a verification and analysis of the reported facts.

Other company departments or external parties may be involved in the investigation if required.
Throughout the process, the presumption of innocence of all involved parties will be ensured.

4.5. Resolution of the Report (Resolution timeframe: 3 months from acknowledgment of receipt)

After completing the investigation, the Head of the Legal Department will formulate conclusions and communicate them to the relevant departments.

These conclusions may be formalized in a report in accordance with this Policy.
Compliance with data protection legislation will be ensured, particularly regarding the rights of data subjects.

a) If no violation is confirmed: Case Dismissal

If no irregularity, unlawful act, or internal policy breach is confirmed, the case will be closed and archived.
This decision will be documented accordingly.

⚠ False or Malicious Reports: If a report is found to be false, made in bad faith, or filed for personal gain, the whistleblower may face disciplinary measures.

b) If a violation is confirmed

If an irregularity, unlawful act, or internal policy breach is confirmed, the matter will be escalated to:
- The head of the affected department.
- The Human Resources department for appropriate disciplinary action.
The company’s management will have full and permanent access to the Whistleblowing Channel and will be periodically updated on investigation progress.
Management will also have formal access to all resolution reports issued.

4.6. Data Retention

All information will be stored and retained in compliance with applicable legal requirements.

The processing of personal data will adhere to relevant data protection laws.
Requests from public administrations, courts, or tribunals will be considered within the limits of the law.
Data will only be retained for the legally required period, considering the statute of limitations for any potential legal actions.

4.7. Reports from External Parties

If an external third party submits a report to an ITE employee, the employee must forward it to the Head of the Legal Department.

⚠ Failure to process or escalate a report will be considered a violation, subject to legal consequences as defined by applicable regulations.

5. Protection of the Whistleblower

The Whistleblower Channel is based on principles of confidentiality, respect, and substantiation.

Any person who reports in good faith will receive appropriate protection under applicable regulations.
Employees reporting accounting irregularities, audit concerns, or internal financial reporting issues—whether anonymously or not—will be protected.
The system ensures full anonymity if the whistleblower chooses to remain unidentified.

Confidentiality and Anonymity

If the whistleblower chooses to disclose their identity, efforts will be made not to reference their name in the final report.
If the whistleblower’s identity becomes public, the Human Resources Department will monitor their work environment and may offer a job transfer if necessary.

Protection Against Retaliation

Any act of threat, discrimination, or retaliation against a whistleblower will be considered a labor law violation.
Employees who obstruct investigations or fail to cooperate will face disciplinary action.
Those who threaten or retaliate against whistleblowers will also be subject to disciplinary measures.

Enforcement and Compliance

Compliance with this policy is mandatory.
If a violation is confirmed, it will be reported to Human Resources, which will implement appropriate disciplinary actions based on the severity of the offense.
ITE reserves the right to take action against business partners who fail to comply with this policy.

6. Publicity

While employees are obligated to be familiar with and act in accordance with Internal Regulations in their professional duties, the company will ensure the proper dissemination of this Policy and the existence of the Whistleblower Channel.

Annex: Categories of Reports for the Whistleblower Channel

Workplace Conflict — Mobbing / Harassment

Definition: Systematic, recurring behavior in the workplace that undermines an employee’s dignity, aiming to emotionally or psychologically weaken them, hinder their professional growth, or force them out.
Exclusions: Isolated interpersonal conflicts occurring in a specific moment, which do not intend to professionally or personally destroy the involved parties.

Sexual Harassment

Definition: Any unwanted sexual behavior that causes offense, humiliation, or an intimidating work environment.
Forms: Can be a pattern or a single incident.
Distinction: Different from gender-based harassment, which is discrimination based on sex or gender identity.

Discrimination

Definition: Unjust or arbitrary differential treatment based on:
- Race, sex, religion, nationality, ethnicity, sexual orientation, disability, age, language, social background, or any other social condition.
Impact: Can affect a single person or a group in a similar situation.

Inappropriate Behavior / Other Workplace Conflicts

Definition: Abuses of power, mistreatment, or workplace bullying, regardless of hierarchy.

Work Conditions

Examples:

Payroll errors (wages, overtime, bonuses) not related to fraud.
Unsafe working conditions (e.g., fire hazards, unsanitary environments).

Privacy / Information Security

Examples:

Unauthorized use of company, client, employee, shareholder, or supplier data.
Breaches of confidentiality, integrity, or data security policies.

Corporate Integrity Violations / Conflict of Interest

Definition: Personal interests influencing professional decisions, potentially conflicting with the company’s interests.

Examples:

Conflicts due to family ties, business ownership, or influential positions in external entities.