Complaints Channel

The Whistleblower Channel is the mechanism that DELONIA SOFTWARE makes available to all its employees, suppliers, customers and third parties, so that they can communicate any information that may involve:

• A possible irregularity or act contrary to any applicable internal regulation.
• A possible irregularity related to accounting issues, audit issues and/or aspects related to internal control over financial reporting;
• A possible irregularity or act contrary to the law.

The channel is accessible through the following e-mail address: denuncias@delonia.com .

Reports can be made anonymously or by including contact details, bearing in mind that all information collected in the report will be treated securely and confidentially.

Delonia’s Compliance Committee area will process the complaints received diligently and promptly, promoting their verification and promoting the necessary measures for their resolution.

• The report must contain all the information necessary to initiate an investigation, an explanation of the facts, and the dates on which they occurred. If you wish, you may attach any documentation that may help to better explain the situation reported.
• Once the complaint has been filed, the interested party will be kept informed of its receipt and progress until it is fully resolved. The communication channel will be the e-mail address where the complaint was made. Among the information that will be provided to the complainant, it will indicate who is handling the matter and how they can get in touch if further collaboration is needed.
• The identities of the complainants will not be disclosed without their authorization. When the matter raised cannot be resolved without disclosing the identity of the complainant (e.g., if his or her testimony is required in court), a dialogue shall be initiated with the complainant to obtain his or her consent and, where appropriate, as to the manner and form of proceeding.

Confidentiality

DELONIA SOFTWARE will take all reasonable precautions to maintain the confidentiality of the identity of any person raising a concern, consistent with conducting a thorough, fair investigation, and in compliance with applicable laws. Access to any report shall only be granted to personnel who have a need to know.

False or malicious allegations

DELONIA SOFTWARE has a non-retaliation policy. In accordance with this policy and with the provisions of art. 36 of Law 2/20232/2023, whistleblowers who file complaints in good faith will not be subject to retaliation of any kind. If it is determined that a complainant has filed a complaint maliciously or knowing it to be false, it will be considered a violation of the company’s Code of Conduct Compliance, in which case, DELONIA SOFTWARE reserves the right to take appropriate legal action, and in case of being formulated by employees, the company’s labor disciplinary regime will apply by initiating a disciplinary procedure that could end even with the termination of the employment relationship, as established in the Article 54 of the Workers’ Statute as well as art. 24 of the State Collective Bargaining Agreement for Consulting, Information Technology and Market and Public Opinion Research Firms.