El Círculo de Bellas Artes It provides employees and third parties with an Ethics Channel to securely and confidentially report possible violations or breaches of the Code of Conduct.

Who can use it

The channel is available to anyone linked to el Círculo de Bellas Artes in a work or professional context, including but not limited to: (i) Shareholders, members of the board of directors or management, partners; (ii) any employee, including volunteers, interns and workers in training periods, (iii) any person working for contractors, subcontractors and suppliers and (iv) any third parties related to el Círculo.

What can be communicated

The Ethics Channel will accept reports of actions or omissions that may constitute:

· Infringements of European Union law within the legally provided scope.

· Serious or very serious criminal or administrative offenses, in accordance with applicable regulations.

• Violations of the Code of Conduct and other internal policiesel Círculo de Bellas Artes.

Communications relating exclusively to breaches of the Code of Conduct and other internal policies will not be covered by the protection regime established in Law 2/2023, unless the reported facts could constitute one of the infringements included in its material scope of application.

How to present a communication

Communications can be made in writing or verbally. An in-person meeting is also possible upon request.

Available channels:

• Web channel (secure form): https://circulodebellasartes.factorial.es/complaints • Email: canaletico@circulobellasartes.com

· Postal mail: Att. Ethical channel. Círculo de Bellas ArtesCalle Alcalá, 42. 28014 Madrid.

• Face-to-face meeting (at the informant's request): coordination via the web channel or the verbal channel.

Anonymous communications

The Ethics Hotline accepts anonymous communications. In these cases, a secure two-way communication channel (mailbox/identifier) ​​will be maintained, where possible, to request clarifications without compromising anonymity.

Essential principles of the management procedure

El Círculo de Bellas Artes Manage communications with diligence, traceability, and guarantees. In particular:

· Registration and file: the communication is registered and a file is opened with an identification code.

· Acknowledgement of receipt: within a maximum of 7 calendar days, unless the informant waives it or if it could compromise confidentiality.

· Preliminary evaluation: a decision is made regarding admission, referral to another internal procedure, or reasoned dismissal.

· Internal investigation: The Channel Manager will conduct the investigation applying criteria of necessity and confidentiality.

• Rights of the affected person: their right to defense and hearing is guaranteed; communication may be postponed if there is a risk of frustrating the investigation.

• Response to the informant: maximum period of 3 months, extendable up to 6 months in cases of special complexity, documenting and communicating the extension when appropriate.

Channel Guarantees

• Confidentiality and restricted access to the identity of the informant, third parties and the actions.

• Prohibition of reprisals and protection measures for the informant and their environment.

• Presumption of innocence and respect for the rights of the people affected.

• Data protection: minimization, limitation of access and retention in accordance with applicable regulations.

Head of the Ethical Channel

The Head of the Ethics Channel del Círculo de Bellas Artes It is a collegiate body composed of the following people:

· Ms. Ana Sonia Zapata, in her capacity as Economic-Financial Director.

· Mr. Victor Manuel Benito Garcia, in his capacity as Head of Personnel.

· Ms. Ana Ortiz Zaforas, in her capacity as Chief of Staff.

External information channels

Without prejudice to the use of this Channel, the informant may resort to external channels with the competent authorities. At the state level, there is an external channel with the Independent Authority for the Protection of Informants. The submission channels are as follows:

• Dedicated mailbox and procedures on the electronic portal: https://sede.proteccioninformante.gob.es • Informative website: https://www.proteccioninformante.gob.es

• Email (preferred use for general information): canal.externo@proteccioninformante.es

· Postal address: Independent Authority for the Protection of Informants, Calle Luis Cabrera 9, 28002 Madrid, Spain.

In this case, similar authorities may exist in certain Autonomous Communities. Círculo de Bellas Artes This information will be kept up to date on the corporate website and intranet.