WHISTLEBLOWER PROTECTION POLICY

1. Introduction

At WellWo, we foster a culture of integrity, transparency, and social responsibility, and we expect employees, clients, and suppliers to act in accordance with the ethical and legal principles governing our activities. Likewise, we recognize the value of complaints as a tool to prevent and detect behaviors contrary to legality, ethics, or company values, and to improve the work environment and corporate reputation.
Therefore, at WellWo, we are committed to ensuring that employees and other collaborators feel free and safe to express their concerns or doubts without fear of retaliation of any kind.
WellWo is committed to protecting the rights and privacy of individuals who file complaints or reports. The complaint processes are designed to be handled confidentially, ensuring a safe and retaliation-free environment for whistleblowers. Any identified retaliation will result in disciplinary consequences. The company guarantees the necessary support for the fair follow-up and resolution of complaints, always protecting the privacy and well-being of whistleblowers.
 

2. Objective

This Policy is approved in compliance with Law 2/2023, specifically to establish guarantees for the protection of whistleblowers. The Policy is accessible to all stakeholders, whether individuals or legal entities.
The objective of this Policy is to establish the general principles regarding whistleblowing and whistleblower protection, as well as to detail key elements of this process (rights, information protection, and prohibition of retaliation).
 

3. Principles

The principles governing WellWo’s actions to ensure the protection of whistleblowers and the prohibition of retaliation are as follows:

1. This Policy aims to guarantee the protection of whistleblowers so that they do not suffer any actions or omissions that result in unfavorable or discriminatory treatment due to their status as whistleblowers, or that cause or may cause unjustified harm to their professional career, working conditions, remuneration, business relationship, health, or personal integrity. For this reason, we are committed to respecting and protecting the rights and dignity of whistleblowers.
2. At WellWo, we recognize the value of individuals’ collaboration in complying with the law and ensuring the proper functioning of public and private institutions, and we respect the right of whistleblowers to report regulatory breaches they become aware of through the Complaint Submission Mechanism or the company’s Whistleblowing Channel.
3. We guarantee the anonymity of whistleblowers who request it unless there is a legal obligation to disclose their identity. We take necessary measures to protect their personal data and prevent any leaks or unauthorized access to the information provided. WellWo also provides appropriate channels to ensure complaints can be filed securely, guaranteeing the confidentiality of communications and respecting the presumption of innocence of those affected, as well as their honor, personal, and family privacy.
4. WellWo has an internal procedure for processing received communications to verify their accuracy. This procedure guarantees the right to be heard and the defense of the persons involved. Similarly, we are committed to investigating complaints diligently, impartially, and transparently and to taking corrective or disciplinary actions if reported irregularities or breaches are confirmed.

4. Whistleblower Rights

Individuals who, as whistleblowers, comply with the principles and guidelines established in this Policy and submit communications on the matters mentioned herein are entitled to the following rights:

• Right to confidentiality and identity protection: Those who submit a communication or make a public disclosure have the right to ensure that their identity is not disclosed to third parties, except for legally provided exceptions.
  The person responsible for managing complaints at WellWo will act to preserve the whistleblower’s identity and guarantee the confidentiality of data related to the affected individuals and any third parties mentioned in the information provided, especially the whistleblower’s identity if disclosed.
• Right to information: The whistleblower will be notified of the receipt of their complaint within 72 working hours. Within a maximum of 10 working days, the team will review the complaint to determine its validity and request additional information if necessary. From this point on, they will be kept informed about the process and any required actions.
• Protection measures: Individuals who report or disclose violations covered by this Policy are entitled to protection, provided the following conditions are met:
  • They have reasonable grounds to believe that the information provided is accurate at the time of reporting or disclosure, even if conclusive evidence is not provided, and that the information falls within the scope of this Policy.
  • The communication or disclosure is made in accordance with the established requirements.

5. Prohibition of Retaliation

WellWo explicitly prohibits any form of retaliation (including threats and attempts of retaliation) against individuals who file a complaint through the Complaint Submission Mechanism or Whistleblowing Channel in accordance with Law 2/2023, internal regulations, and this Policy.
Retaliation refers to any actions or omissions prohibited by applicable law or any unfavorable treatment that places the affected individuals at a particular disadvantage in the workplace or professional context solely due to their status as whistleblowers or for making a public disclosure. Examples include, but are not limited to:

• Dismissal or suspension of employment contracts.
• Early termination of temporary employment contracts after the probationary period.
• Disciplinary measures, demotions, or denial of promotions that are unjustified or unrelated to the whistleblowing process.
• Denial of training that would have been granted otherwise.
• Premature termination of business or service contracts without proper justification.
• Intimidation, harassment, or ostracism.
• Reputational damage or financial losses.
• Unjustified negative performance evaluations.
• Blacklisting or dissemination of harmful information affecting employability.

Protection measures also apply to colleagues, family members, or any individuals closely connected to the whistleblower, provided they meet eligibility criteria.
 

6. Personal Data Processing

Personal data obtained within the context of a complaint will be processed in compliance with applicable laws. Its sole purpose is effective management of complaints based on consent and legal authorizations. Any unnecessary data will be deleted immediately.
Interested parties may exercise their rights or request additional information in writing.

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WellWo is committed to protecting the rights and privacy of individuals who file complaints or reports. The complaint processes are designed to be handled confidentially, ensuring a safe environment and protection from retaliation for whistleblowers. Any identified retaliation will have disciplinary consequences.

The company guarantees the necessary support for the fair follow-up and resolution of complaints, always protecting the privacy and well-being of the whistleblowers.