SOUTH SUMMIT WATCHES OVER JUSTICE, PEACE AND STRONG INSTITUTIONS

The purpose of this Anti-Corruption Policy is to serve as a tool for the
prevention of those behaviors related to corruption or typified as a crime
related to corruption in both the public and private sectors, within SPAIN
STARTUP AND INVESTORS SERVICES S.L. (SOUTH SUMMIT) (hereinafter,
«the Organization»).

The Organization, through the adoption of this Policy and in conjunction with
the Code of Ethics, assumes the commitment to implement the culture of
regulatory compliance and to guarantee transparency and legality not only
within it, but in all its commercial transactions.
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SPAIN STARTUP AND INVESTOR SERVICES S.L. (SOUTH SUMMIT), has implemented an Internal Information Channel through the following link.

In this sense, all our stakeholders are informed of the existence of this means of communication through which suspicion of illicit or irregular conduct contrary to the legal system, current legislation or internal rules of the Organization can be reported, as well as acts that may go against the values and ethical principles that govern its activity.

In this way, suspicions of conduct related to economic crimes (fraud, corruption, against the Public Treasury, etc.), conduct of harassment at work, sexual or based on sex, crime of money laundering, unfair or discriminatory treatment, etc. may be reported through the Internal Information Channel. In case of doubt or query about any aspect related to the Internal Information Channel, interested parties may contact the members of the Compliance Committee..

In no case is it a means of communication to transmit complaints, since these must be transmitted by other means enabled for that purpose. Likewise, those complainants in bad faith who present false complaints or denunciations that have the sole purpose of undermining the reputation of the company or any of its professionals, will be subject to the corresponding disciplinary procedures and sanctions in accordance with the labor legislation in force at all times and the collective agreement that is applicable..

For these purposes, the Policy of Use and Operation of the Internal Information Channel is where the procedure for filing the complaint is exposed, as well as the processing, investigation and resolution of the same in order that all of them sign the Annex as they accept and undertake to comply with what is stipulated therein.
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