COMMITTED TO OUR DNA

Ethical behaviour is one of the explicit commitments incorporated in the Nueva Pescanova Group’s corporate DNA. To give concrete content to these values, principles and rules of ethical behaviour, we have established a set of rules on business ethics, institutional integrity and compliance with the law, which guide our business conduct as a Group and that of each of the professionals of the Group, without exception.

OUR COMPLIANCE CHANNEL

The Nueva Pescanova Group’s Compliance Channel is the global, direct and integrated communication mechanism through which any person, whether or not belonging to the Group (employees, suppliers, customers, other stakeholders and third parties in general) and from any place in the world, can submit to the Compliance Unit, in a transparent and confidential manner, even anonymously, Requests or Complaints relating to our system of business ethics, institutional integrity and legal compliance (Compliance matters). Our Compliance Unit is an internal, collegial and permanent body, with autonomy and independence of action, charged, among other things, with ensuring effective respect for and compliance with our Compliance System.

Therefore, by its very nature, the Compliance Channel requires users (whether or not they are employees of the Nueva Pescanova Group) to use it in a responsible, reasonable, proportionate and loyal manner. It is expressly forbidden to communicate or provide information with manifest bad faith, for misleading purposes or to unjustly damage the honour, privacy or good name of any person. Users must act in good faith, with respect, and with due decorum and moral decency. The Nueva Pescanova Group shall not be held responsible for the defamatory or false comments that a user of the Channel may make towards a third party, without prejudice to the legal action that, where appropriate, the affected party may take against the user who uses the Channel in a malicious manner. The Channel user warrants that the personal information provided is true, accurate, complete and up to date.

The conditions of use, operational rules, information principles and rules of procedure of the Channel are set out in the Regulation of the Compliance Channel of the Nueva Pescanova Group.

In order to guarantee the best standards of confidentiality, protection of personal data, privacy and security of information, as well as secure, transparent, agile and traceable management of the communications made (especially when they are anonymous), the Nueva Pescanova Group has a technological tool called WhistleBlower, which is managed by an external supplier specialised in this type of information systems and which uses the highest level of security standards. Through WhistleBlower it is possible to:

• REQUEST, by clicking HERE, to submit to the Compliance Unit any doubt of interpretation, request for guidance on how to proceed in a specific case, resolution of doubtful situations where an opinion is sought on how to resolve an ethical or compliance issue, advice on a Compliance issue or matter, etc.

• REPORT, by clicking HERE, to inform the Compliance Unit of any situation, action, behaviour or conduct (active or passive) involving a professional of the Nueva Pescanova Group (or related third parties) that may be allegedly illegal, unlawful, irregular or, ultimately, contrary to the rules and regulations set out in Our Code of Ethics, the Supplier’s Ethical and Social Charter, the Corporate Policy for the Prevention of Criminal Risks or the Anti-Corruption Code, among others, and other provisions of our Corporate Governance and Compliance Regulatory System.

In order to submit a communication through WhistleBlower, in addition to the rules of the Compliance Channel, you must read and expressly accept the Privacy Policy of WhistleBlower of the Nueva Pescanova.