COMMUNICATION POLICY AND COMPLAINT FOLLOW-UP

I. Introduction

Motorline Electrocelos, S.A. has always been guided by principles of integrity and honesty, respecting current legislation and carrying out its activity guided by the principles of professional ethics dominant in legal commerce.

In this sense, and in compliance with the provisions of Decree-Law no. 109-E/2021, of December 9 (which establishes the General Corruption Prevention Regime), a reporting channel was created, which allows the reporting of irregular practices , particularly related to corruption or related infractions, in order to effectively combat such behavior, through a means of rapid reporting and open to all who contact Motorline Electrocelos, S.A., preserving, however, the confidentiality and anonymity of whistleblowers .

This policy aims to stipulate and regulate all procedures necessary for the reception, follow-up and conclusion of each reporting process, closely following the requirements imposed by Law no. 93/2021, of December 20, which enshrines the Regime General Protection for Whistleblowers of Infractions.

II. Scope of the Reporting Channel

The reporting channel is intended to be used in particular by natural persons who become aware of an infraction, whether already completed, yet to occur, or about to be committed, in the context of their professional activity or their relationship with Motorline Electrocelos , S.A.. In this sense, the following may be considered Whistleblowers:

  • Employees, interns and volunteers, as well as people in the recruitment process;
  • Customers, service providers, suppliers and anyone who maintains, directly or indirectly, a contractual relationship with Motorline Electrocelos, S.A.;
  • Holders of social participation and members of management and supervisory bodies.

Infringements are considered to be all acts or omissions, intentional or negligent, that violate the applicable legislation in force (national, community and international), the Code of Conduct of Motorline Electrocelos, S.A., or any ethical principles applicable to the exercise of the functions in question. , involving, in particular:

  • Harassment;
  • Discrimination;
  • Corruption;
  • Money laundering;
  • Organized crime;
  • Terrorist financing;
  • Security, privacy and data protection;
  • Interest conflicts;
  • Fraud;
  • Embezzlement of funds;
  • Between others.

Certain issues go beyond the scope of the reporting channel, as they are not considered infractions in the relevant sense here. Therefore, the following issues will not be addressed through the reporting channel:

  • Complaints about the quality of products and services
  • Questions about labor dynamics
  • Exercise of rights under the General Data Protection Regulation

Such topics must be exposed in appropriate locations, namely through the Motorline Electrocelos, S.A. website, or through its internal channels.

III. Reception of Complaints

The reporting channel is available on the Motorline Electrocelos, S.A. website, and is accessible to any user. This channel is managed by an external entity (Trusty AG), which will independently ensure the preliminary analysis of the complaints received.

Only authorized people with competence to deal with complaints can access the information made available by Whistleblowers.

Whistleblowers may choose to remain anonymous when submitting the complaint, and, in any case, the confidentiality of the data provided is always assured.

Despite the possibility of anonymity, the complaint must contain all the data necessary to investigate the facts contained therein, as well as all the essential information that allows its subsequent processing. All reports that do not contain a clear and sufficient description of the facts that support the alleged infringement will not be subject to processing, without prejudice to the Reporter being able to be contacted to complete or clarify their report.

The Whistleblower is also allowed to rectify or change their complaint based on emerging facts, through new communication in the reporting channel.

Considering the existence of an internal reporting channel, the Whistleblower cannot previously resort to external means of reporting, nor can they publicly disclose the infraction, except if:

  • You have reasonable grounds to believe that the infringement cannot be effectively addressed or resolved internally or that there is a risk of retaliation;
  • Has initially submitted an internal complaint without having been informed of the measures envisaged or adopted following the complaint within three months of receiving the complaint;
  • The infraction constitutes a crime or administrative offense punishable by a fine exceeding €50,000.00 – and the Reporter may, in these cases, resort to external reporting channels.

And except if:

  • The Reporter has reasonable grounds to believe that the infringement may constitute an imminent or manifest danger to the public interest, that the infringement cannot be effectively addressed or resolved by the competent authorities, given the specific circumstances of the case, or that there is a risk of retaliation including in the event of an external complaint;
  • The Whistleblower has submitted an internal complaint and an external complaint, or directly an external complaint, without appropriate measures having been adopted within the legal deadlines – and the Whistleblower may, in this second set of cases, publicly disclose an infraction.

IV. Handling Complaints

Within seven days of receipt of the complaint, the Whistleblower is notified of this receipt and of the requirements, competent authorities, form and admissibility of the external complaint, in cases where this is applicable.

After an initial screening, carried out by an external and independent entity, the Motorline Electrocelos, S.A. Ethics Group will begin the necessary investigations to investigate the facts alleged in the complaint.

Subsequently, the Ethics Group prepares a report explaining what was found, concluding what solution should be given to the case. The process may be archived if the complaint is found to be unfounded or there is no infringement. On the other hand, the report may also contain the measures to be adopted to end the infringement – namely the opening of an internal investigation or the involvement of the competent authorities.

The measures planned or adopted to follow up on the complaint and their justification are communicated to the Whistleblower within three months from the date of receipt of the complaint.

All reports made through the Motorline Electrocelos, S.A. reporting channel will be treated confidentially. In fact, all information relating to the complaint will only be disclosed to those responsible for processing it who actually need to know that information.

Those responsible who become aware of data and information related to the complaints and processes that accompany them are bound by a duty of secrecy and confidentiality.

Anyone who reports an infraction under the terms and scope of this Policy cannot be subject to any retaliation, threat, harassment, intimidation or discrimination as a result of submitting the report.

However, if the complaint was presented in bad faith, without the author being able to ignore its lack of foundation, Motorline Electrocelos, S.A. reserves the right to apply the sanctions and penalties that apply to the case.

Whistleblowers who choose to identify themselves in the communication made on the reporting channel consent to their personal data being processed for the aforementioned purposes. These whistleblowers have the right to access, rectify and delete the personal data provided, and may also limit their processing and revoke the consent provided at any time, using the address qualidade@electrocelos.com for this purpose.

All data is archived securely, ensuring confidentiality. Motorline Electrocelos, S.A. maintains all complaint processes for a period of five years, this period may be exceeded in the event of legal litigation related to the complaint. In these cases, the processes will be preserved until the respective court decision becomes final. However, personal data that is not clearly relevant to the processing of the complaint will not be kept.

This Policy is available for consultation on the Motorline Electrocelos, S.A. website, coming into force immediately.

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