FORGING STEEL PRODUCTS has approved an internal information system that meets the requirements established in Law 2/2023, of February 20, regulating the protection of people who report regulatory infractions and the fight against corruption (hereinafter, “ Law 2/2023”). This System is a set of tools and procedures that are intended to facilitate the detection and management of possible violations (with the exceptions that will be explained) within FORGING STEEL PRODUCTS. The document “Complaint Channel Procedure” is integrated into the Regulatory Compliance Model, approved by the Board of Directors of FORGING STEEL PRODUCTS through minutes of 02/29/2024, and includes the main characteristics of the System.

The Compliance Officer is the person most responsible for supervising REGULATORY COMPLIANCE and has been designated by the governing body as the person responsible for managing the channel.

An internal information channel has been enabled so that information referring to certain infractions or non-compliance can be communicated (as defined in the following section).

Alleged Violations may be reported in several ways: FORGING STEEL PRODUCTS has set up a complaints channel accessible to all people wishing to make queries or report irregularities through the email canaldedenuncias@forgingsteelproducts.com or also through the FORGING STEEL PRODUCTS website by using a form ( Complaint Form) accessed through https://www.forgingsteelproducts.com.

This access through the web appears on the home page, in a separate and easily identifiable section. Interested parties who do not have an organic link with FORGING STEEL PRODUCTS (customers, suppliers and subcontractors) may also use the complaints channel publicly displayed on the FORGING STEEL PRODUCTS website, giving them the same treatment and under the same conditions of security than if it were formulated by a person from within the organization.

FORGING STEEL PRODUCTS SL allows communications regarding possible regulatory and SGC violations and their measures, policies and procedures to be made both anonymously and confidentially. That is why the following measures are established to implement anonymous communications:
– Enable an ethics or complaints mailbox in the organization where the communication can be deposited.
– Send the communication by postal mail to the attention of the Compliance Officer at the organization’s address (BO ARREGUI S/N,48340 AMOREBIETA-ETXANO(BIZKAIA)).

If the alleged Infringement refers to facts or circumstances in which the System Controller has intervened, the information may be sent to the person responsible for the Administration Department, who will then assume, provisionally and for the sole purposes of managing that information, the functions of System Manager.

What behaviors are susceptible to being reported, grouped into the FOLLOWING CATEGORIES:

1. Immoral or illegal conduct or actions in the performance of work. The commission of conduct that may violate occupational risk regulations, compromising safety and health at work, or that constitute a violation of the labor provisions, procedures or ethical codes of FORGING STEEL PRODUCTS.
2. Inadequate or lucrative management of business resources. Conflicts of interest, the use of business assets for own purposes or inadequate management or handling of resources.
3. Theft: Any type of robbery, theft or theft of personal property.
4. Workplace or sexual harassment. Any type of abuse of power and harassment (work, sexual or other) through intimidation, oral, written or physical threats.
5. Discriminatory treatment or influence peddling. Mobing (different treatment of an employee with respect to his colleagues for reasons not related to job performance), influence peddling or misuse of information.
6. Misuse of classified information.
7. Fraud and corruption. Actions or omissions that may constitute a serious or very serious criminal or administrative offense, such as fraud, tax fraud, money laundering or any other type of corruption.

Any member of FORGING STEEL PRODUCTS, understood as all people professionally related to the company, whether because they are workers (whatever the regime, including interns), or because they are shareholders, directors or members of the Board of Directors, as well as candidates in selection processes, can transmit information about alleged Infractions, directly or through representation.

External third parties such as self-employed workers, supplier companies, contractors and subcontractors (and their employees) may also do so, and may therefore communicate the indicated Infractions, fully subject to their requirements and procedure.

In any of the cases indicated above, the informant can choose to remain anonymous (not reveal his or her identity) or identify himself. In the latter case, its confidentiality will be guaranteed in full compliance with the provisions of Law 2/2023 and the personal data protection regulations.

The reporting person will have the right to know the status of the processing of their communication and the results of the investigation (with an obligation of confidentiality), except in cases in which they have expressly renounced receiving communications or the confidentiality or good purpose of the communication may be compromised. the investigation. To do this, you must provide an email address or other means of communication and undertake to preserve the confidentiality of the content of the notifications received.

To analyze the provisional verisimilitude of the information, the reporting person must provide as much information as possible about the alleged Infringement, including:

• A basic description of the facts. What alleged violation could have been committed and how?
• The (approximate) dates on which it was committed. When?Persons suspected of having committed the Infraction, participants in it and other possible knowledgeable persons. Who is it?
• The documents, audios, videos, data or any other sources of information (whether on paper or in computer format) that can be used to corroborate or clarify the alleged Infringement. What evidence or indications do you have?

The reporting person who has communicated information in writing will receive an acknowledgment of receipt within 7 calendar days after receipt of the information by the System Manager (unless the reporting person has declined to receive information or has made a communication anonymous without indicating any means of contact).

When the System Manager considers that the information received is totally or partially confusing or insufficient, she may request the corresponding extensions or clarifications from the informant who has identified herself (or provided a means of communication).

Preliminary analysis of the information The System Manager will carry out a preliminary analysis of the information and make one of the following decisions:

1. Disallow communication:

• When the facts reported lack all plausibility.
• When the facts reported do not constitute an Infringement or, even when they may be, no evidence or principle of proof has been provided that could minimally corroborate them.
•  When the communication is manifestly unfounded or there are, in the opinion of the System Controller, rational indications that the information or evidence or principles of proof provided have been obtained illicitly.
• When the communication does not present significant new information about an Infraction already reported and closed, which is already public knowledge or with respect to which the System Controller already had prior knowledge and had not considered that an infraction existed (unless there are new circumstances and evidence or relevant evidentiary principles that justify it).

1. Start an investigation.

The procedures deemed appropriate will be carried out to clarify the facts and to investigate the persons allegedly responsible.

If the successful outcome of the investigation allows it, the affected person or persons will be informed of the facts, giving them the opportunity to make allegations. In any case, the identity of the informant will be kept secret and may not be revealed to the person or persons affected.

Once all the investigation procedures have been completed, the System Manager will prepare a final report specifying the conclusions drawn and their assessment of the reported facts. You can propose two possible actions:

• File the procedure, if it is considered that the act does not constitute an Infraction, that its perpetration does not appear sufficiently justified or that a known author has not been proven.
• Proposal to continue the procedure, if it is considered that the procedures carried out converge with rational indications that an Infraction may have been committed by the affected person or persons.

In this case, you may propose, depending on the case: (i) the filing of a criminal complaint before the Provincial Prosecutor’s Office or corresponding Court; (ii) the presentation of an administrative complaint before the corresponding authority; and/or (iii) the adoption of corrective measures.

Final Decision

The System Manager will send the final report to the administrative body, so that they can decide whether to archive the file or agree to any or all of the proposals made by the Compliance Officer.

In general, this decision must be made within a maximum period of 3 months from the acknowledgment of receipt of the communication (if an acknowledgment of receipt has not been sent – because it is an anonymous communication, for example -, the period will begin from the elapse of 7 calendar days after receipt of the communication). However, the period may be extended by another 3 months if the investigation is complex.

FORGING STEEL PRODUCTS will guarantee the protection of the good faith informant against possible retaliation by the organization or third parties. Retaliation means not only those that have disciplinary content, but also restrictions on internal promotion, access to training, conciliation measures, etc.

However, certain requirements are required for such protection to be granted:

• That the information provided is true or that the reporting person has a reasonable and objective justification to believe in its truthfulness at the time of communication. Furthermore, the information must not have been obtained illegally, nor may it be already public knowledge or based on mere rumors or assumptions. 

Law 2/2023 establishes that intentionally reporting false information is considered a very serious offense, which can lead to financial penalties of between 30,001 and 300,000 euros. Furthermore, this conduct of providing false information may be subject to disciplinary sanctions by Alconza.

If the System Manager considers that a communication may be false or based on bad faith, it will inform the administrative body or the Management Department so that the corresponding measures can be taken or initiated.