Whistleblowing Guide

Purpose of the Guide

The purpose of this Guide is to inform those employees covered by the Group’s Whistleblowing Policy (hereinafter the “Policy”) as well as terminating employees, volunteers, trainees, trainees or even persons involved in recruitment processes, directors, shareholders, suppliers and subcontractors about the ways to report wrongdoing and the safeguards that protect them.

Content:

1. Why has this Guide been made available?
   2. When should I use the whistleblowing channel?
   3. How can I report irregularities?
   4. How will my report be handled?
   5. How is the whistleblower protected?

1. Why has this Guide been made available?

We remain committed to managing the organisation in the best possible way and we need your help to do this. This Guide aims to reaffirm that it is safe and acceptable to speak up, and to enable you to raise any concerns you may have about possible wrongdoing early and in the right way. Rather than waiting for evidence, we prefer that you raise the issue while it is still a concern.

This Guide also reflects the requirements under the transposition of the European Directive in Spain with Law 2/2023, of 20 February, which regulates the protection of persons who report irregularities in good faith (hereinafter “Whistleblower Protection Law”).

2. When should I use the Whistleblowing Policy?

Report wrongdoing when any of the situations listed in the “scope” section of the Group Whistleblowing Policy arise, e.g. breaches of regulations, non-compliance with corporate policies or procedures, conduct that could damage the company’s image, criminal offences, and legal breaches, among others.

3. How can I report irregularities?

As provided for in the Policy, you have at your disposal both an internal channel (with the possibility to report internally within the company and within the Group; the possibility to contact an external lawyer; and the possibility to make your report anonymously) and an external channel (the one implemented by law by the authorities as a consequence of the new developments of this update of the whistleblower protection law managed by an independent authority) to report irregularities.

Regardless of how you choose to raise a concern, the treatment will be the same, following the whistleblowing process and providing the whistleblower with the full protection afforded in the Policy and in section 5 of this Guide.

1. Internal channel for reporting irregularities. You can do this verbally or in writing through the following channels, which do not have to follow this precise order, you can do it in the way you feel most comfortable.

1. Internal communication through the Irregularities Channel (with the possibility of anonymous reporting through the following link): https://admiral.gccanaldenuncias.es/portal/denuncia
2. Group communication:
   1. If you are not comfortable with the Whistleblower Channel, you also have the possibility to go to the Group. To do so, send an email to whistle@admiralgroup.co.uk, clearly indicating that the email is addressed to the Whistleblowing Officer. You will be able to plan your concerns in Spanish.
   2. In the event that you wish to report a concern in relation to the Whistleblower (Karen Green) or any other member of the Board, you should clearly indicate that the email is addressed to the Chairman of the Admiral Group Board or any other member of the Board.

1. External channel for reporting irregularities. You can do this verbally or in writing.
   Although the law indicates that the internal channel is the preferred channel for reporting irregularities, whistleblowers can also make use of the external reporting channel of the Independent Authority for Whistleblower Protection, which is an independent administrative authority “AAI”.
   The information may be made in writing, by post or by any electronic means provided for this purpose addressed to the external information channel of the Independent Authority for Whistleblower Protection, IAI, or verbally, by telephone or by voice messaging system. At the whistleblower’s request, it may also be submitted through a face-to-face meeting. The I.P.A. shall in this case be the sanctioning body.

How will my report be handled?

Deadlines for whistleblowing handling:

We will acknowledge receipt of your communication within 7 days. As soon as you report the concern, we will assess the nature of the issue raised and consider what action might be appropriate. This could involve an informal review, an internal investigation or a more formal investigation. We will tell you who will deal with the matter, how you can contact them and what further assistance we may need from you. If you request it, we will write to you to send you a summary of the concern and how we intend to handle it. If you feel that we have misunderstood the concern or that information is missing, please let us know. We will respond to you within 3 months of receiving the concern, except in cases of particular complexity that require an extension of time, in which case this may be extended by up to a maximum of a further three months.

When raising a concern, it would be useful for us to know how you think it could best be resolved. If you have a personal interest in the matter, let us know at the outset to avoid conflict. If we feel that your concern is best dealt with under the grievance, bullying and harassment policy, or any other related procedure, we will inform you and discuss the best way forward. Where possible, we will inform you of the outcome of any investigation. However, please note that we may not be able to inform you of the specific actions we take if this would contravene our obligation of confidentiality to others.

Even if a complainant withdraws their concern, there may be cases where the Company also has a legitimate concern and needs to continue with the investigation. If this is the case, we will let you know.

5. How is the whistleblower protected?

If you raise a legitimate concern under the Policy, you will not risk losing your job – any form of retaliation is prohibited. This is known as “protected disclosure”. As long as you raise concerns in good faith, it doesn’t matter if you are wrong. Of course, this guarantee does not extend to those who maliciously raise a matter that they know to be false, it could lead to disciplinary proceedings, including dismissal, against any member of staff who is found to have made a false or malicious allegation.

In cases where a protected disclosure is made, the company will take all reasonable steps to ensure that no one under our control engages in harassing or retaliatory conduct. All information will be treated with the utmost confidentiality. However, there may be circumstances where we are required by law to disclose your identity; namely, if a report becomes the subject of a criminal investigation in which you may be called as a witness (you should be aware that the Public Prosecutor’s Office will be notified immediately where the facts reported could constitute a criminal offence). In other cases, problems may identify the person raising them simply by the fact that they have been raised. In such cases, we will discuss with you how best to proceed.

In addition, in addition to protecting the whistleblower, the whistleblower is given the opportunity to mitigate or even waive sanctions in the event that a whistleblower who has been involved in the commission of an administrative offence is himself the one who reports its existence (provided that this was before the initiation of the investigation or sanctioning procedure was notified). Remember that, throughout the process, you should not approach or accuse any person directly, try to investigate the matter yourself, or pass on your suspicions to anyone other than the appropriate persons or an external body. This is a necessary measure to protect everyone involved.