Ethical Mailbox

Complaints channel

With the aim of guaranteeing transparency and integrity in the HIGHLAND GOLD S.LWe have set up a whistleblowing channel in accordance with Law 2/2023 of 20 February on the protection of persons who report regulatory violations and the fight against corruption. Through this channel, you can confidentially report any irregularity or regulatory infringement affecting the company.

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Responsible use of the complaints channel

Please use this channel responsibly, contributing to a safe and ethical working environment.

What can be reported?
The law protects natural persons who report, through any of the procedures provided for in the law, of:

(a) any act or omission which may constitute an infringement of European Union law provided that:

1. Enter within the scope of application of the European Union acts listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law, irrespective of the classification of such breaches in the domestic legal system;

2. affect the financial interests of the European Union as referred to in Article 325 of the Treaty on the Functioning of the European Union (TFEU); or

3. have an effect on the internal market, as referred to in Article 26(2) of the TFEU, including infringements of European Union rules on competition and aid granted by states, as well as infringements relating to the internal market in relation to acts that infringe company tax rules or practices aimed at obtaining a tax advantage that distorts the object or purpose of the legislation applicable to company taxation.

b) Actions or omissions that may constitute a serious or very serious criminal or administrative offence. In any case, this shall be understood to include all serious or very serious criminal or administrative offences that involve financial loss to the Public Treasury and Social Security.

2. Such protection shall not exclude the application of the rules relating to criminal proceedings, including investigative measures.

3. The protection provided for in this Act for workers who report breaches of labour law in matters of health and safety at work shall be without prejudice to that established in their specific regulations.

4. The protection provided for in this Act shall not apply to information affecting classified information. Nor shall it affect the obligations resulting from the protection of the professional secrecy of the medical and legal professions, the duty of confidentiality of the Security Forces and Corps within the scope of their actions, as well as the secrecy of judicial deliberations.

5. The provisions of this law shall not apply to information relating to infringements in the processing of procurement procedures that contain classified information or that have been declared secret or reserved, or those whose execution must be accompanied by special security measures in accordance with the legislation in force, or where the protection of interests essential to State security so requires. 6. In the event of public information or disclosure of any of the offences referred to in Part II of the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, the specific regulations on reporting offences in such matters shall apply. - Article 63 of the Law specifies that communicating or publicly disclosing information knowing it to be false shall constitute a very serious infringement.

How to access the Complaints Channel?

Hemos implementado la plataforma Tramit App para que podáis presentar denuncias de forma confidencial y segura. Podéis acceder al canal de denuncias aquí: Complaints channel

When making a report, it is recommended to provide as much information as possible to facilitate the analysis and investigation of the facts. Suggested data to include are:

- Identification of the alleged offender, if possible.

- Detailed description of the facts complained of.

- Date and place of occurrence.

- Any documents or evidence to support the complaint.

Confidentiality and Whistleblower Protection
- Confidentiality: All reports will be treated with complete confidentiality. It is possible to make reports anonymously.

- Protection: Whistleblowers acting in good faith will be protected against retaliation.

Data protection policy
The Law establishes that the processing of personal data derived from its compliance will be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (General Data Protection Regulation, GDPR); in Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights; and in Title VI of Law 2/2023 itself. The Controller of the Internal Information System is responsible for the processing of the data received through the established internal channel.
Complaints Management Process
1. Submitting the complaint: Access the link mentioned above and follow the Tramit App instructions. It is important that you save the code generated by Tramit App for your follow-up of the complaint.

2. Confirmation: You will receive confirmation of receipt of the complaint within 7 days.

3. Investigation: The complaint will be investigated impartially and you will receive a resolution within a maximum of 3 months.

4. Follow-up: You will be able to follow the status of your complaint through the Tramit App platform. Please use this channel responsibly, contributing to a safe and ethical working environment.

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Highland Gold Mallorca
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