JB Capital Markets, S.V., S.A.

In compliance with the provisions of the Group Code of Conduct of Grupo de Inversiones Zulú S.L.U. (hereinafter referred to as “the Group”) and the regulations governing the protection of persons who report regulatory and anti-corruption violations, i.e. Law 2/2023 of 20 February on the protection of persons who report regulatory and anti-corruption violations (hereinafter referred to as “Law 2/2023”), the Group provides members of the Group’s Board of Directors, employees (with current or former employment relationship), shareholders and agents of the Group, as well as third parties (suppliers, contractors, subcontractors, customers, etc. of the Group) with a Whistleblower Reporting Channel that allows them to (i) to report actions or omissions that may constitute a serious or very serious criminal or administrative offence, as well as any breach of the legislation in force, especially those falling within the material scope of application of Law 2/2023; (ii) report any allegedly unlawful acts or acts constituting breaches of the Code of Conduct, the Internal Code of Conduct, any other internal regulations, such as those relating to the prevention of money laundering and the financing of terrorism, as well as any irregular or inappropriate conduct; and (iii) to make enquiries regarding the interpretation and application of the manuals or internal regulations that must be complied with by the members of the Board of Directors, senior management, employees and agents of the Group or in the event of doubt or concern as to whether a given situation could be considered an act of the kind described in points (i) and (ii) above, all subject to the principles and guarantees detailed in the document “Whistleblower Protection”. Complaints should be addressed to:

  1. By sending an e-mail to canaldenuncias@jbcapital.com.
  2. By sending a letter to the address Calle Serrano Anguita, nº1, 28004, Madrid, for the attention of the Director of the Director of the Compliance Department of JB Capital Markets, S.V., S.A.U. (hereinafter referred to as “JB Capital”).
  3. By a personal interview with the Compliance Director of JB Capital.
  4. When the reported person (individually or together with other persons) is a member of the Compliance Department of JB Capital or the Criminal Compliance Body, the communication shall be made in one of two ways: (i) by sending a letter to the attention of the Director of the Legal Department of JB Capital at the postal address of Calle Serrano Anguita 1, 28004 Madrid; (ii) by a personal interview with the Director of the Legal Department of JB Capital.
  5. When the person being reported (individually or together with other persons) is the Director of the Legal Department of JB Capital, the communication shall be made in one of two ways: (i) by sending a letter to the attention of the Director of Compliance Department, the Director of HR and the Head of Risk Management of JB Capital, the three positions must be mentioned in the letter without specifying the body to which they belong, at the postal address of Calle Serrano Anguita 1, 28004 Madrid; (ii) by personal interview with the Director of Compliance Department of JB Capital and, in the absence of the latter, with the Director of HR and/or the Head of Risk Management of JB Capital.

For more information on the Whistleblower Reporting Channel and its applicable data protection rules, please refer to the following documents: