Lortek Compliance

d. Update of the Compliance System: monitoring, analysis and continuous updating of risks and procedures. e. Training : LORTEK staff have received sufficient training to know the objectives and operation of the company’s Compliance System. f. Obligation to report possible unlawful or non-compliant conduct committed by LORTEK or external personnel and particularly those of a sexist, vexatious or discriminatory nature: an Ethical Channel is established for this purpose, accessible through the website www.lortek.es , managed in the first instance by an external company and fully guaranteeing its confidentiality. g. Obligation to cooperate: all LORTEK staff have the obligation to collaborate in any steps or investigations that may be necessary to clarify the facts related to the alleged violations. h. Means : LORTEK will devote sufficient resources to achieve an effective operation and continuous improvement of its Compliance System, with special reference to the duties of supervision, surveillance and control. i. Control body : LORTEK has an internal supervisory body for the compliance of its Compliance System. j. Consequences of non-compliance : LORTEK will apply the disciplinary regime and take the actions that correspond to it in law against breaches both of a criminal nature and of other internal regulations or legal application 4. Updating and revision This Policy will be reviewed and updated periodically, in order to adapt it to regulatory changes and those that may arise in the activities of LORTEK, ensuring at all times its effective implementation. 5. Approval and validity This Policy entered into force at the time of its approval by LORTEK’s Governing Council on 2 June 2022, has been revised and ratified on