Legal Notice

This Disclaimer (the “Disclaimer”) governs the use of the website www.soltec.com (the “Website”), which is owned by SOLTEC ENERGIAS RENOVABLES S.L.U.

 

1. OWNERSHIP OF THE WEBSITE

1.1. The owner of the website is SOLTEC ENERGIAS RENOVABLES S.L.U. (“Soltec”), with tax identification number B73292161, dociled at C/ Gabriel Campillo Contreras, (Pol. Ind. La Serreta), s/n 30500 Molina de Segura, Murcia, telephone number +34 968 603 153 and e-mail address for this purpose info@soltec.com.

1.2. Soltec is a company constituted by means of a deed granted before the Notary Public of Molina de Segura, Mr. José Javier Escolano Navarro with protocol number 523 on the 26th of February 2004, registered in the Mercantile Registry of Murcia in Volume 2,074, Folio 110, Page number MU-44,701.

1.3. For the purposes of this Disclaimer, Soltec is SOLTEC ENERGIAS RENOVABLES S.L. as well as its subsidiaries, group companies and their staff and representatives.

1.4. The information contained in the Website refers to the services offered by Soltec in accordance with the regulations that govern in Spain and in the European Economic Area. The information contained in the Website is for informational purposes only and in no way constitutes any obligation for the parties accessing the Website (the “User(s)”).Users").

1.5. This Disclaimer regulates access and use of the Website by Users and will be complemented with any other legal texts that regulate any functionality, service, process, application, platform or means necessary for the use of the Website or the services described.

1.6. By accessing the Website, the User accepts this Legal Notice and declares and guarantees that the applicable laws and regulations allow him/her to access the Website and that he/she will make proper use of the Website in accordance with the laws, good faith, public order, traffic uses and this Legal Notice. The User shall be liable to Soltec or third parties for any damages that may be caused as a result of a breach of this obligation.

 

2. USERS

2.1. For the purposes of this Website, a user is any natural or legal person who accesses and browses the Website. Being a User implies full and unreserved acceptance of each and every one of the provisions included in this Disclaimer, which may be subject to change. Access to the Website also means that the User accepts that this information applies to all subsequent access to the Website and that such subsequent accesses are subject to the disclaimers, risk warnings and other information contained herein.

 

3. PURPOSE AND SCOPE

3.1. The purpose of the Website is to provide Users with information about Soltec's services.

3.2. For this purpose, Soltec grants a non-exclusive, non-sublicensable, non-transferable license to the Users to use the Website and the functionalities, content and other available features, which shall be subject to the rest of the Legal Notice and the applicable regulations.

 

4. INTELLECTUAL AND INDUSTRIAL PROPERTY

4.1. All intellectual and industrial property rights to the information, text, data, graphics, photographs, designs, software, trademarks, trade names, signs and other content of the Website are the property of Soltec and/or its licensors. Therefore, their use or exploitation in any way by the User is prohibited, except as part of the service of the Website in accordance with the Legal Notice.

4.2. The User acknowledges and accepts that the use of the Website does not imply the transfer of any intellectual or industrial property rights, such as copyright, trademarks, domain names, designs, patents, utility models, know-how or other rights over the Website; nor does it constitute any authorisation for the creation of developments derived from the Website, except for the limited, non-exclusive, non-transferable and free licence of use granted to Users of the Website in accordance with this Legal Notice.

4.3. In short, Users accessing the Website may view the contents and make, where appropriate, authorised private copies provided that the elements reproduced are not subsequently transferred to third parties, nor are they installed on servers connected to networks, nor are they subject to any type of exploitation.

4.4. The distribution, modification, transfer or public communication of the contents and any other act on the contents that has not been expressly authorised is prohibited.

4.5. At any time and for any reason, Soltec may terminate your right to use all or any part of the Site. You may not violate or attempt to violate the security of the Site.

 

5. CONDITIONS OF ACCESS AND USE

5.1. The Website is free and open access, however, Soltec conditions the use of some of the services offered on the Website to the prior request and completion of the corresponding form.

5.2. The User guarantees the authenticity and timeliness of all data provided to Soltec and shall be solely responsible for any false or inaccurate statements made.

5.3. The User expressly agrees to make appropriate use of the contents and services of Soltec and the Website and, in particular, not to use them or distribute information through the Website for, among others:

(a) Disseminate content that is criminal, violent, pornographic, racist, xenophobic, offensive, in defence of terrorism or, in general, contrary to the law in force, morals, customs or public order.

(b) Transmit or introduce into the network computer viruses or any other harmful component that impairs, limits or damages the Website or any connected network or interferes with the use by other Users, as well as perform actions that may alter, copy, spoil, interrupt, modify, decompile, disassemble, reverse engineer, or generate errors or damage to electronic documents, data or physical and logical systems of Soltec or third parties; as well as to license, lease, sell, imitate, or hinder the access of other Users to the Website and its services.

(c) Attempting to access the e-mail accounts of other Users or restricted areas of Soltec's or third parties' computer systems and, where appropriate, extracting information.

(d) infringing intellectual or industrial property rights (copyrights, domain names, trademarks, etc.), as well as violating the confidentiality of Soltec's or third parties' information and personal data protection rights.

(e) Impersonating another User, public authorities or a third party.

(f) Reproduce, copy, distribute, make available or in any other way publicly communicate, transform or modify the contents, unless authorised by the owner of the corresponding rights or it is legally permitted.

(g) Collect data for advertising purposes and to send advertising of any kind and communications for sales or other commercial purposes without prior request or consent.

(h) Use the Website, or any part of it, on other private or commercial websites, as well as make commercial use of the Website; or establish hyperlinks or hyperlinks to the Website or any of its contents (unless expressly authorized in writing by Soltec), refraining from making false, inaccurate or incorrect statements or indications about Soltec, or include illegal content, contrary to good customs and public order.

(i) Any other activities contrary to the law in force, to this Legal Notice, to morality, good customs or to the established public order, or with illicit, prohibited or harmful purposes to the rights and interests of Soltec or third parties.

5.4. Soltec reserves the right to block access to certain services of the Website to any User in the event that he/she violates the Legal Notice, the rights of third parties or the applicable legislation.

 

6. SERVICE AND WARRANTY EXCLUSIONS. LIABILITY

(a) Exclusions

6.1. Soltec shall use reasonable efforts to ensure the proper functioning of the Site. However, Soltec cannot ensure the availability of the Site or the absence of interruptions to the Service for the purpose of repairs and/or maintenance of the Site or lack of coverage or failure of equipment and/or networks necessary for the transmission of data, which are beyond its control. Soltec will take appropriate measures to reduce such interruptions.

Although Soltec shall use reasonable efforts to ensure that the information contained on the Site is accurate, correct and up to date, such information shall be deemed to be of a general nature and for informational and illustrative purposes only. In this regard, Soltec does not warrant the completeness, https://soltec.com/wp-content/uploads/2022/03/115-business-consulting-agency_blog_8-1.jpgeidad, accuracy, timeliness, currency or integrity of this information and accepts no liability whatsoever in connection therewith.

6.3. Soltec also reserves the right to correct, improve or modify the website and the information contained therein, when it deems appropriate and without prior notice, as well as to suspend access to it in order to carry out maintenance or improvement actions, not being responsible for the accuracy, insufficiency or authenticity of the information provided.

6.4. Soltec excludes, to the extent permitted by applicable law, any liability for damages of any kind arising from:

• The impossibility of accessing the website or the lack of truthfulness, accuracy, completeness and/or timeliness of the content, as well as the existence of vices and defects of any kind in the content transmitted, disseminated, stored, made available and accessed through the website or the services offered.
• The presence of viruses or other elements in the contents that may cause alterations in computer systems, electronic documents or user data.
• Failure to comply with the law, good faith, public order, traffic uses and this Legal Notice as a result of improper use of the Website. In particular, and by way of example, Soltec is not responsible for the actions of third parties that violate intellectual and industrial property rights, business secrets, rights to honour, personal and family privacy and self-image, as well as regulations on unfair competition, data protection and illegal advertising.

(b) Soltec Warranty

6.5. The Website is presented as is and neither Soltec nor any of its group companies warrant that the services will be uninterrupted or error free, nor do they guarantee the results obtained from the use of the service.

6.6. Soltec provides the service without warranties of any kind, either express or implied, including, but not limited to, warranties of title or implied warranties of satisfactory quality or https://soltec.com/wp-content/uploads/2022/03/115-business-consulting-agency_blog_8-1.jpgeidad for a particular purpose or otherwise, except those warranties which are implied and which cannot be excluded, restricted or modified under applicable law.

6.7. The Website does not control, in general, the use that Users make of the Website. In particular, Soltec does not guarantee in any way that Users use the Website in accordance with the law, this Legal Notice, morality, generally accepted good customs and public order, nor that they do so in a diligent and prudent manner.

6.8. Any conditions, warranties or representations not expressly stated in this Legal Notice are excluded to the extent permitted by applicable law.

(c) Linked sites

 6.9. This website may contain links to other websites and incorporate information and/or services obtained from third parties, in order to facilitate the User's access to the information of collaborating or sponsoring companies. Soltec disclaims any responsibility for the information contained in these external links that is outside of this website and is not directly managed by Soltec.

6.10. The User understands that these other websites are independent from the Website and that Soltec has no control over, and is not responsible for, the content, operation or transmission received from such third parties and shall not be liable for any loss or damage in connection with the use of or reliance on any such content, goods or services available on any such site or resource. The sole function of such links is for informational purposes, for the convenience of the User, and it is the User's responsibility to read and accept the terms of use and privacy and cookie policies posted on the linked websites or applications referred to.

(d) User Guarantees

6.11. The User uses the Website at his/her own risk. By accessing the Website, the User agrees to use it in accordance with applicable laws and regulations and to accept this Legal Notice and all its terms and conditions. The User shall be solely liable to Soltec and/or third parties for any loss or damage that may be caused as a result of a breach of this obligation. In this regard, Soltec shall not be liable for any damage or alteration in the User's equipment as a result of the use of the Website and is exempt from any liability.

6.12. The User is solely responsible for ensuring that his or her computer system has all the relevant technical specifications necessary to use the Website.

 

7. DATA PROTECTION AND COOKIES

7.1. Soltec is committed to protecting the personal data of its Users and will therefore only use such data in accordance with the provisions of the Privacy Policy.

7.2. This website uses cookies to manage navigation and other functions of the website. Users will find information regarding the use of own and third party cookies in the Cookies Policy.

8. GENERAL PROVISIONS

(a) Invalidity of clause

8.1. If any provision or condition of this Legal Notice shall become or be declared illegal, invalid or unenforceable for any reason, such condition or provision shall be deemed severed without prejudice to the enforceability of the remaining provisions of this Legal Notice.

 (b) Amendments

8.2. Soltec reserves the right to modify or update the information contained in this Legal Notice, at any time, when it deems appropriate and without prior notice, and shall not be liable for the accuracy, inadequacy or authenticity of the information provided.

8.3. Soltec shall publish on the Website the new version of the Legal Notice each time it changes. The User will be informed, once he/she accesses the Website again, about any change in the terms of this Legal Notice.

 (c) Jurisdiction and applicable law.

8.4. The Legal Notice is governed by Spanish law.

8.5. Any controversy that may arise as a result of the use of the Website or the Legal Notice shall be submitted to the competent courts of the city of Murcia and, in the case of a User acting as a consumer, to the court of the domicile corresponding to the User/consumer.

The User, if acting as a consumer, may also submit any dispute arising out of or in connection with these Terms of Use to an alternative dispute resolution ("ADR") procedure. The list of ADR platforms available from the European Commission can be found at the following link: https://webgate.ec.europa.eu/odr/main/index.cfm?event=main.home.chooseLanguage.

CRIMINAL COMPLIANCE POLICY

Introduction

Soltec Power Holdings S.A. and its subsidiaries (hereinafter referred to as the "Soltec Group" or the "Group") are companies engaged in the production and implementation of solar tracking projects for energy production.

As a consequence of the amendments made to Organic Law 10/1995 of 23 November 1995 on the Criminal Code by Organic Law 5/2010 (which came into force on 23 December 2010) and by Organic Law 1/2015 (which came into force on 30 March 2015), which introduced in the criminal jurisdiction the liability of legal persons in Spain, as well as the requirement of complementary legislation, the Soltec Group decided in 2020 to implement a system of regulatory compliance and crime prevention in order to prevent this type of contingencies from occurring within the Group. Given this purpose, since then steps have been taken for its effective implementation throughout the organisation under the provisions of this Policy, which, taking into account the international vocation of the organisation, has led to the adoption of this system by Soltec Group companies located around the world.

In this regard, the Group's Governing Body and Senior Management set out this Criminal Compliance Policy (hereinafter "the Policy") as an expression of their commitment to:

Compliance with all requirements and obligations arising from this Policy and the Corporate Compliance programme as a whole.

Compliance with all criminal legislation applicable to the Group.

Commitment to continuous improvement of both the Group and the Corporate Compliance programme itself.

 

2. Scope of application.

This Policy and the Corporate Compliance programme as a whole apply to the entire Group and, in particular, to its Governing Body, Senior Management, employees and any other interested parties.

In this regard, the activities in whose scope the offences to be prevented may be committed, and which are therefore covered by this Policy, are the following:

Holding and participation in the capital of other companies that carry out activities related to renewable energies.

The design, manufacture, supply, installation and maintenance of renewable energy equipment, including solar trackers.

The promotion and development of photovoltaic solar plants, as well as services related to these activities.

As an essential requirement for entering into any type of business relationship with the Group, any third party seeking to contract with the Group must expressly sign their acceptance of this Policy and the obligations arising from it, and in particular the Group's zero tolerance for the commission of criminal offences, both by members of the Group and by third parties with whom it contracts.

In this regard, the Group reserves the right to require those business partners with whom it establishes far-reaching relationships to have a criminal compliance management system or equivalent in order to give effect to the above; it may also terminate the contractual relationship in the event of non-compliance with the above by third parties.

3. Objectives.

With the implementation of this Policy and the criminal compliance system as a whole, the Group aims to:

Reinforce the organisation's zero-tolerance policy towards the commission of criminal offences.

Establish a model capable of identifying the most important criminal risks for the organisation and establish measures for their prevention, detection and management, as well as associated controls.

Involve all the organisation's personnel in this prevention system, involving them in compliance with both the Corporate Compliance programme as a whole and with criminal regulations in the exercise of the functions assigned to them within the organisation.

To assure the members of the organisation, customers, suppliers, judicial bodies and society in general that the Group complies with the duties of supervision and control in the exercise of its activity, and that it establishes the appropriate measures to prevent or reduce as much as possible the risk of the commission of crimes, exercising due control over directors, managers, employees and all persons associated with the Group.

To this end, on an annual basis, the organisation determines a series of Compliance objectives and develops the planning of measures aimed at achieving them.

In order to achieve the defined objectives, the general guiding principles of the programme, as well as the means designed to achieve them, are described below.

Finally, in line with the objective of fulfilling the programme's commitment to continuous improvement, the objectives set by the Group in this policy will also be subject to periodic review.

4. General principles of the Corporate Compliance programme.

The general principles that inspire and govern this Policy and the Corporate Compliance programme as a whole are as follows:

Compliance with criminal law, the Code of Conduct and its other internal protocols is required of all members of the Group and expressly prohibits the commission of criminal acts.

A Risk Assessment has been carried out which identifies all those activities in whose scope the crimes to be prevented may be committed, and to minimise the organisation's exposure to such crimes it has implemented a series of measures for the prevention, detection and management of the criminal risks identified.

The Group undertakes to comply with all the obligations derived from this Policy, as well as from the set of protocols, procedures and policies that form part of the Corporate Compliance programme.

Interested parties are obliged to report all facts or suspicious conduct relating to criminal risks, guaranteeing confidentiality and the absence of reprisals against the informant, through the channel set up for this purpose (canaldenuncia@soltec.com).

Training activities shall be carried out as often as necessary to ensure that all Group personnel are sufficiently familiar with this Policy and the rest of the Corporate Compliance programme.

The existence of the Compliance Body, as the body that will exercise the functions of the Compliance Officer, is hereby notified. The Compliance Body is independent from the Governing Body and will act as the authority responsible for the management, implementation and verification of compliance with the Corporate Compliance programme.

The Compliance Body will report to the Governing Body and Senior Management on a regular basis on its assessment of the effectiveness of and compliance with the Corporate Compliance programme; the Governing Body and Senior Management will also review the effectiveness of the programme; and a communication channel will be established between them to provide a framework for the continuous improvement of the programme.

Failure by members of the Group to comply with the obligations arising from this Policy and the Corporate Compliance Programme as a whole shall give rise to the application of the disciplinary regime provided for in the Workers' Statute and the Collective Bargaining Agreement applicable in Spain, and by the national labour regulations applicable abroad. In the case of any business partner, the provisions of the specific procedure applicable to it shall apply.

5. Corporate Compliance Programme

The Group's Corporate Compliance programme has been drawn up on the basis of an analysis of the criminal risks that could affect the organisation in the course of its business, and consists of a series of procedures, protocols and policies aimed at preventing, detecting, managing and sanctioning the materialisation of such criminal risks.

The main pillars of the Corporate Compliance programme are the following elements:

A Criminal Risk Assessment in which a detailed analysis is carried out of all those situations which, within the framework of the Group's activities, are susceptible to materialise in a criminal risk resulting in the commission of a criminal offence.

A Code of Conduct that aims to establish the Group's mission and values, as well as to establish a guide for the behaviour of the Group's members that serves as a basis for the establishment of the entire Corporate Compliance programme.

A Whistleblowing Channel, available to all members of the Group, as well as to any of the Group's business partners who consider it necessary to make use of it. Through this channel, any breach or suspected breach of the obligations set out in the Corporate Compliance programme can be reported. The Group guarantees confidentiality and freedom from retaliation for any whistleblower who makes use of it.

This Criminal Compliance Policy, as the parent document of the Corporate Compliance programme and the basis for its operation, as it sets out the main objectives and principles of the programme as a whole.

6. Review and improvement of the Criminal Compliance Policy

The Group undertakes to continuously review and improve this Policy and the Corporate Compliance Programme as a whole. The reviews shall be carried out on an annual basis, without prejudice to any extraordinary reviews that may be necessary due to regulatory changes or changes in the structure of the Group, breaches of the programme or any other exceptional circumstances that may make this advisable.

 

TAX COMPLIANCE POLICY

1.Objective

The Tax Compliance Policy of Soltec Power Holdings, S.A. and its subsidiaries (hereinafter "the Group") aims to implement an organisational and tax management model based on due control and the reinforcement of an ethical business culture with respect to compliance with tax obligations, which eliminates the risk of tax violations and tax fraud due to negligence or malice on the part of any member or collaborator of the company.

In this regard, the Group's governing body has implemented a set of internal measures and rules aimed at supervising, monitoring and controlling the activities of the Group's companies in order to guarantee and demonstrate due diligence in the fulfilment of tax obligations.

The Group is made up of different companies in various jurisdictions. It is the intention of the Governing Body of Soltec Power Holdings, S.A. to implement this Policy in all companies where it has control, regardless of the jurisdiction in which it is located, always adapted and tailored to the company in question. In those investee companies where the Group does not have control, the Governing Body shall promote the application of this policy or, at least, the implementation of a set of minimum supervisory measures, reporting and surveillance adapted to the specific situation of each company on tax matters.

The control and prevention model adopted by the Group through this policy is based on the identification of risk activities, the establishment of procedures for the adoption and execution of decisions in relation to these risks, the express provision of adequate financial resources, and the establishment of a disciplinary system in the event of non-compliance.

Likewise, the control and prevention model adopted has specific mechanisms for periodic review and supervision of https://soltec.com/wp-content/uploads/2022/03/115-business-consulting-agency_blog_8-1.jpgeidad of the measures adopted and their suitability to the characteristics and circumstances of the Group.

2. Principles and pillars of the Tax Compliance policy

The Policy on tax compliance is based on a series of practices based on due diligence and aimed at introducing control measures to ensure optimal tax management, the elimination of potential tax risks and the elimination of criminal risk.

Conceptually, the Policy on tax compliance The Group's work revolves around the following principles:

2.1 Objectivity. The policy of tax compliance is materialised in the adoption of concrete and specific measures that allow their application to be homogenised over time and regardless of who is responsible for their adoption.

2.2 Suitability. The measures taken in implementation of the tax compliance are intended to demonstrate the diligence of the management bodies in managing tax and customs risks and obligations.

2.3 Measurability. The measures implemented under the EU's tax compliance include measurable targets so that monitoring is affordable and scalable.

2.4 Efficiency. The policy of tax compliance is based on the minimum imposition of formal obligations by promoting the exploitation of synergies.

2.5 Relevance. The measures taken under the tax compliance of the Group have a real impact on the achievement of the final goal.

The principles underlying the model of tax compliance are embodied in measures that pursue the effectiveness and efficiency of the system in order to achieve the ultimate goal of good tax administration and, eventually, exemption from criminal liability for the legal person.

The measures of tax compliance developed and implemented by the Group are based on the following pillars:

2.6 Decision-making. Tax decisions are made by the members of the Tax Department, under the supervision and direction of the Chief Financial Officer (hereinafter referred to as "CFO"), "CFO"), within the framework of the Fiscal Policy approved by the governing body.

The members of the Tax Department are responsible for informing the Governing Body of tax and customs decisions and for having its approval on those of major significance.

2.7 Resources. The Governing Body shall have the necessary information for tax-related decision-making. The persons responsible for making and implementing tax and customs decisions have sufficient professional qualifications and the necessary material resources to do so. However, in compliance with the principles governing the Group's tax strategy and the good practices deriving therefrom, the persons responsible undertake to keep the CFO and the Governing Body informed prior to making decisions of particular relevance and of a tax nature.

2.8 Traceability. There are mechanisms in place to record decision-making and the assignment of persons responsible for compliance with tax obligations and the implementation of measures. To this end, the traceability of information in tax decision-making is part of the Group's tax strategy. As proof of this, the persons responsible for tax matters undertake to expressly record the adoption of decisions or the taking of measures in the Company's internal files.

2.9 Special operations. Those operations have been identified which, due to their special relevance, must have a specific treatment in terms of decision-making, resources allocated and traceability..

3. Features of the Tax Compliance Policy

The Policy on tax compliance of the Group, promoted and approved by the governing body, requires, in all cases, compliance with the tax legislation applicable to the Group and consideration of the doctrine of the courts of law and the Directorate General of Taxation to interpret the tax rules and to classify, for tax purposes, a transaction to be carried out or that has been carried out within the Group.

The Policy on tax compliance is consistent with the aims and objectives of the Group, which are to eliminate the risk of tax offences and tax fraud due to negligence or malice on the part of any member or collaborator of the company, by implementing a tax organisation and management model based on due tax control and reinforcing the ethical corporate culture with regard to compliance with tax obligations.

In this way, by means of this tax compliance all members of the Group are expressly prohibited from wilfully or negligently committing tax offences and offences, in order to minimise the occurrence of such conduct.

In addition, the tax compliance minimises the Group's exposure to tax risks in an effective, efficient and proportionate manner by introducing a set of organisational rules and protocols to identify, detect, prevent and mitigate tax risks.

Likewise, through the analysis of internal and external factors relevant to the management system of the tax complianceIn addition to the identification of stakeholders and the subjective and objective scope of the programme, a set of Organisational Standards have been defined to provide an appropriate framework for the definition, review and achievement of the programme's objectives. compliance taxation.

The Policy on tax compliance It also includes a Responsible Governance Body Declaration and a Commitment of active collaboration of the Group's management to comply with the requirements set out in the management system of the Group. tax compliance.

Along the same lines, channels of communication of non-compliance or well-founded suspicions of non-compliance have been established, guaranteeing that the informant will not suffer reprisals, in the following terms:

According to the relevant Whistleblowing Protocol, it is the obligation of all staff, regardless of their status and category, to report to the compliance body any reasonable suspicion or knowledge of possible breaches of any Policy, Rule or Protocol implemented in the Group as a result of the Corporate Compliance and Tax Compliance.

As set out in the relevant Protocol on Internal Whistleblowing Policy and Procedures, no employee may be discriminated against for reporting in good faith breaches of any Policy, Standard or Protocol implemented within the Group as a consequence of the development of the Corporate Compliance and Tax Compliance.

In this way, through the tax compliance of the Group, it is expressly stated that it is committed to the continuous improvement of the Group's management system. tax compliance.

By virtue thereof, the Governing Authority, by itself, or through its Tax Compliance Body (hereinafter referred to as the "Tax Compliance Body"), may, in accordance with the provisions of this Article, establish a Tax Compliance Body (hereinafter referred to as the "Tax Compliance Body"), "Tax Compliance Officer".)The Commission shall encourage the review of this Policy. tax compliance and its organisational rules, adopting such modifications and improvements as it deems appropriate, in accordance with the regulations applicable at any given time.

In this respect, the Tax Compliance Officer embodies the position as the ultimate guarantor of the supervision, monitoring and control of the requirements necessary for the proper performance of the tax compliance and, to this end, it has sufficient resources and staff with the appropriate skills, status, authority and independence. Finally, the rules adopted by the Group within the framework of the tax compliance have the nature of an internal rule, so that any breach will be sanctioned in accordance with the provisions of current labour legislation, as established in the Workers' Statute and in the Collective Bargaining Agreement signed by the company, taking into account the seriousness of the conduct carried out.

4. Instruments of Tax Compliance

For the purposes of implementing the present Policy tax complianceThe rules are developed organisational described below.  

The Governing Body has approved the management framework that underpins and delimits the tax compliance of the Group.

In this respect, a number of structural rules have been approved, the aim of which is to highlight and reinforce the Group's due diligence in tax management.

Standard 001: Conceptual framework for tax management. Standard defining the Group's tax organisation and management model. In addition, this standard includes a declaration of responsibility from the governing body, as well as a declaration of responsibility from the CFO and the key persons in tax matters, certifying that the Group's tax policies are in line with the tax policy of the Group. tax compliance have been properly implemented and are sufficient.

Standard 002: Involvement of the governing body and senior management in the company's tax policy and its implementation. A rule that records the involvement of the governing body and senior management in the design of the Group's tax policy and the escalation of tax decisions of particular relevance.

Rule 003: Appointment of the Tax Compliance Body. Rule intended to record the appointment and functions of the Tax compliance officer and specialised teams by the Governing Body.

Standard 004: Functional organisation chart and chain of command in the tax area. A standard that aims to reflect the role of the Governing Body in the design of a functional organigram and chain of command (functional organisation chart) of the Group for tax matters.

Standard 005: Annual training and competence plan. The purpose of this rule is to approve an annual tax training plan for the Group's employees in order to train and update all members involved in making or implementing tax-related decisions. In addition, the competencies of the Group's members are set out.

Standard 006: Protocol for monitoring the outcome of inspections. The purpose of this rule is the approval by the governing body of a protocol for the evaluation, monitoring and implementation of measures in relation to the outcome of tax inspections, in order to achieve the correct implementation of the consequences arising in non-inspected years, which must be used by those responsible for the Group's tax management in relation to tax inspection procedures.

Standard 007: Protocol for monitoring and reporting on issues with implications for future years. Rule aimed at implementing mechanisms to ensure the appropriate tax treatment of those issues that may have implications for future years.

Rule 008: Definition of the special operations map. The purpose of this standard is to define the operations which, for the purposes of the implementation of the tax compliance of the Group, shall be classified as "special operations".

Standard 009: Protocol for documentation of decision-making in relevant matters. A rule aimed at establishing mechanisms for documenting decision-making in tax matters.

Standard 010: Communication and dissemination of standards. Standard defining the guidelines and procedures for the communication and dissemination of the management standards adopted by the Group within the framework of the Group's tax compliance.

Standard 011: Management of security measures tax compliance. Standard defining the mechanisms for the management of the tax compliance and the rules and procedures adopted thereunder.

Standard 012: Fiscal risk management. Standard approving the protocol for the identification, assessment, management and adoption of measures in relation to the Group's tax risks.

Rule 013. Protocol for the conservation of tax information. Rule approving the protocol for the conservation of tax information in relation to all those decisions, agreements or documentation which, due to their nature, could have tax implications.

Standard 014. Performance appraisal system. Standard that covers the monitoring and evaluation of the performance of the management system for the tax compliance in order to ensure that its objectives are achieved.Non-compliance with the policy of tax compliancepenalty system

In the event of non-compliance by any employee or collaborator with the policy of tax compliance The penalty regime applicable shall be that established in the Workers' Statute and in the Collective Bargaining Agreement signed by the company, taking into account the seriousness of the conduct carried out.

The Group's Human Resources Department will be responsible for tailoring the sanction to each individual's conduct.

 See Standard 002 Governing body and senior management involvement in tax policy and Standard 004 Functional organisation chart and chain of command in the tax area.