Whistleblowing Channel

Use our Whistleblowing Channel to report, anonymously or personally, any alleged irregularity or act contrary to the law or internal rules of which you are aware.

The criteria governing our whistleblowing channel are explained below.

1. What is the channel and what kind of situations can be reported?

It is a channel accessible to employees and third parties outside GT Motive that offers the possibility of reporting anonymously or personally, any alleged irregularity or act contrary to the law or internal rules of which they are aware.

2. Access and functioning of the channel

The channel will be accessible by:

• E-mail: through the e-mail box speakup@gtmotive.com
• Postal mail: for the attention of the Compliance Manager and sent to C/ Teide, 3 – 1ª Planta – Parque Empresarial La Marina, 28703 San Sebastián de los Reyes (Madrid).

All reports will be treated with the utmost confidentiality, privacy, and security, and may be made anonymously.

3. Recording and analysis of the reported facts

Upon receipt of a complaint, the Compliance Manager will acknowledge receipt within 3 days and will create an individual file for each case, which will be suitably numbered for the purpose of better identification. In the event that different complaints are received regarding the same or related facts, the different files may be accumulated.

The Compliance Manager will carry out a preliminary analysis of the information received before initiating an investigation file. The analysis will consist of verifying the information, its sufficiency and plausibility, the credibility of the complainant and the relevance of the facts reported, determining whether they constitute a legal infringement or a breach of internal regulations, as well as whether they constitute an ethical dilemma or conduct dilemma at GT Motive.

When the information received is manifestly relevant and plausible, the complaint will be admitted, and the investigation phase will start. However, if the information received is irrelevant, insufficient, implausible or the informant lacks credibility, the complaint will be admitted, and the file will be closed.

In the event that the facts reported do not constitute a breach of law or internal regulations, or an ethical or conduct dilemma at GT Motive, the complaint will be rejected, and the case will be closed.

4. Investigation

Depending on the scope, extent and persons allegedly involved in the incident in question, the Compliance Manager will choose the investigation strategy to be followed.

The investigation procedure shall be duly documented, and the investigation shall include all measures needed to clarify the facts, the persons responsible and the corrective measures to be adopted, if any. Once the final investigation report has been drawn up, the investigator shall submit it to the GT Motive Integrity Committee.

5. Resolution

The Integrity Committee is the competent body to respond to the incidents that occur at GT Motive, resolving the proposals made by the investigator.

6. Whistleblower protection

GT Motive does not tolerate retaliation against any whistleblower and will not accept reports that are not made in good faith, that provide false information or that are made in a manner that is harmful to the company, its employees or third parties.

Anonymous reporting of incidents is permitted, although, to assist investigations, whistleblowers are encouraged to disclose their identity. Such communications will be treated with the highest degree of confidentiality.