CODE OF ETHICS, INTERNAL INFORMATION SYSTEM AND WHISTLEBLOWING CHANNEL

As part of CONSUM’s general policy on Corporate Social Responsibility (CSR), internal good governance procedures have been established which, in addition to fulfilling the preventive function in criminal matters within the new criminal liability of legal persons, promote the ethical behaviour of its employees (whether they are worker-members or salaried employees) and, at the same time, ensure compliance with both internal regulations and current legislation, all within the scope of the cooperative’s activity.

The initial document on which this prevention policy is based is the Corporate Governance Code, approved by the Governing Council on 23 February 2012. In development of the same, the Consum Code of Ethics and Conduct was approved at the meeting of the Governing Council on 25 January 2018, which also approved the implementation of a whistleblower’s channel called the Internal Information System, as an instrument through which employees, customers, interested third parties and suppliers or creditors of CONSUM may report the possible commission of criminal acts within the organisation or any conduct or irregularity related to non-compliance with any legal or internal rule or with CONSUM’s Code of Ethics and Conduct.

In addition, and in compliance with the provisions of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, by agreement of 25 May 2023, the Governing Council approved the creation of the “Internal Information System” (IIS) and its implementation protocol, which is available to any interested party at the following link: link.

It is important to stress that the prestige and corporate reputation of the co-operative is a basic element for the success of the organisation, which is a guarantee of the continuity of the business and, therefore, of its sustainability. It is therefore important that all Consum stakeholders are aware of these instruments and place special emphasis on their compliance, and it must be made clear that it is up to each and every one of those who make up the co-operative to make this aspiration a success, as the fact that everyone acts with integrity not only protects the image at the level of corporate reputation, but also allows the co-operative to become a place where everyone who works there is proud to belong to it. For this reason, our Code of Ethics and Conduct defines the guidelines for behaviour that make CONSUM a benchmark within the commercial food distribution sector in Spain.

In this regard, it is hereby stated for the record that all persons to whom these regulations are addressed may make complaints by filling in the relevant form found in the “Complaints Channel” section of our corporate website, it being stated for the record that all those who, in good faith, report such irregularities, will be protected against any type of reprisal, discrimination or penalisation as a result of the complaints they may file.

CONSUM guarantees the utmost confidentiality in this regard and submits to current data protection regulations in the processing of personal information provided with the complaint or obtained in the course of processing it.