In the context of the entry into force of the EU Directive on the protection of whistleblowers, and its transposition into Spanish law via Law 2/2023 of 20 February, regulating the protection of persons reporting regulatory breaches and combating corruption, Engel & Völkers is making a digital reporting system available to all its employees, external self-employed contractors and suppliers, accessible via the following link: https://dabocanaldenuncia.com/MAZALREALTY

MAZAL REALTY S.L.’s Internal Procedure for the Complaints Channel

Last updated: 13 April 2026

Contents

1. Introduction
2. Definitions
3. Scope of application
4. Management of the Ethics Channel or Whistleblowing Scheme
5. Guiding principles of the Ethics Channel
6. Receipt of reports
7. Whistleblowing management system
8. Process for handling reports received
9. Closure of cases and preparation of reports
   • Receipt of the communicationPreliminary analysis of its content
   • Acceptance for processing
   • Registration
   • Acknowledgement of receipt
   • Referral or delegationInvestigation or verification of the facts
   • Decision and proposed course of action
   • Notification of the decision to those concerned
   • Closure of the case and preparation of reports
10. Protection of personal data
11. Commitments of the Compliance Function
12. Relationship with other current procedures
13. Statement of compliance
14. Approval, entry into force and updating

1. INTRODUCTION

MAZAL REALTY S.L. has implemented a Code of Ethics and Whistleblowing Policy which sets out the ethical principles and standards of conduct to which it is committed in its business activities, and defines the framework of behaviour to be followed by the Organisation’s Members in the course of their professional duties.

In order to provide an appropriate response to any queries, discrepancies or irregularities regarding compliance with this Code, and to assist in monitoring compliance with all regulations applicable to our organisation and its members, this Ethics and Whistleblowing Channel is established as a means of communication and reporting, in accordance with the procedure set out in this document.

The Ethics Channel is, therefore, a confidential and transparent channel of communication designed to ensure that both members of our organisation and other stakeholders to have an appropriate channel for reporting any conduct that may involve an irregularity or any act contrary to the law or the standards of conduct set out in the Code of Ethics and other applicable internal regulations, whether committed by other Members of the Organisation or by representatives or employees of companies that collaborate with our organisation in its various activities.

Its purpose is to establish the necessary mechanisms to communicate and manage at an early stage any matter relating to the scope, compliance with or interpretation of the regulations applicable to the Organisation, as well as, in particular, any conduct that could give rise to a criminal offence entailing criminal liability for the legal entity.

The purpose of this document is to set out the procedure for this communication channel.

2. DEFINITIONS:

The definitions of terms frequently used in this document are set out below:

Report: a statement by which any Member of the Organisation, Business Partner or Third Party raises an issue concerning the scope, interpretation or

compliance with the regulations applicable to the Organisation. Depending on its content, a report may constitute an enquiry or a complaint.

• Enquiry: a communication in which any Member of the Organisation, Business Partner or Third Party requests clarification, a response or guidance regarding the scope, interpretation or compliance with the regulations applicable to the Organisation.
• Report: a communication concerning a possible breach of the regulations applicable to the Head of the Internal Reporting System.
• Alleged Offender: a natural or legal person against whom an alleged breach is being investigated by the Head of the Internal Reporting System at MAZAL REALTY S.L.
• Whistleblower: a natural or legal person with access to the Ethics Channel who makes a report.
• Breach: any act or omission that constitutes a violation of the regulations applicable to MAZAL REALTY S.L.. A breach may be of varying degrees of seriousness, ranging from a mere formal failure to comply with a requirement set out in an internal regulation to the commission of acts constituting a criminal offence potentially attributable to the Organisation.
• Members of the Organisation: the members of the Board of Directors, senior managers, employees, workers, temporary staff or those working under a collaboration agreement, and volunteers of the Organisation, as well as any other persons under the hierarchical authority of any of the aforementioned.
• Head of the Internal Reporting System: A single-person or collegiate body, vested with autonomous powers of initiative and control, entrusted, amongst other tasks, with the responsibility of supervising the proper functioning of the Organisation’s Compliance Management System in general.
• Business Partners: any legal entity or natural person, other than Members of the Organisation, with whom the Organisation maintains or intends to establish some form of business relationship. This includes, but is not limited to, intermediaries such as agents or brokers, external consultants, suppliers and customers.
• Parties affected by this document: all Members of the Organisation, as well as Business Partners or Third Parties who have a business relationship with MAZAL REALTY S.L.
• Third Party: a natural or legal person or body independent of the Organisation.

SCOPE OF APPLICATION

This whistleblowing channel has been established to enable various stakeholders – such as senior management, employees, partners, shareholders, members of the organisation’s governing body, suppliers, representatives of the general public, any person working for or under the supervision and direction of contractors, subcontractors and suppliers, etc., with whom the Organisation has a working or professional relationship, to communicate their concerns, suggestions, possible misconduct or any breach of the rules set out in the Code of Conduct, Anti-Corruption Policy or other internal or external regulations.

It is a confidential and even anonymous channel through which any irregular conduct taking place within the Organisation may be reported:

The Ethics or Whistleblowing Channel must be clearly visible on our organisation’s website and easily accessible to members of our organisation and/or, failing that, in a prominent location at the physical premises where the company operates.

4. MANAGEMENT OF THE ETHICS OR WHISTLEBLOWING CHANNEL

The ethics or whistleblowing channel is hosted on an external web platform that meets the highest standards of confidentiality and information security; it also allows reports and/or enquiries to be made anonymously.

The management of the Ethics or Whistleblowing Channel is the responsibility of an external company with which the relevant service provision contract has been formalised and which complies with the standards of confidentiality and security regarding information received through the whistleblowing channel. This entity must undertake the tasks detailed below:

1. Receipt, verification and processing of reports received.
2. Management and maintenance of the archive of cases received and the files generated.
3. Review and monitoring of the operation of the Ethics or Whistleblowing Channel.
4. Regular updating of the Procedure.
5. Maintenance of the register of reports received and the internal investigations to which they have given rise.

5. GUIDING PRINCIPLES OF THE ETHICS CHANNEL

1. Duty to report: Members of our organisation, as well as other stakeholders, who have reasonable grounds to suspect that an irregularity has been committed or that an act contrary to the law or to the applicable internal rules voluntarily adopted by the Organisation has taken place, must report this to the Head of the Internal Reporting System. In the case of persons who have an employment relationship with the Organisation, a commercial relationship or who provide a service, this obligation is considered an essential part of good faith in contractual compliance. Therefore, all employees are obliged to bring to the attention of the Head of the Internal Reporting System any information or indication that a breach of the applicable regulations may have been committed or may be committed.
2. Confidentiality guarantee: The identity of any person reporting a breach via the Ethics Channel will be treated as confidential information and may even be anonymous. Consequently, it will not be disclosed to those who may be involved in a verification process. The details of the persons making the report may only be disclosed to administrative or judicial authorities, to the extent that they require such information as a result of the proceedings arising from the subject matter of the report, or to persons involved in any subsequent investigation or legal proceedings initiated by and as a result of the report. The transfer of data shall be carried out in accordance with the provisions of legislation on the protection of personal data.
3. Promotion of the Ethics Channel: Our organisation will promote awareness of this reporting channel in order to improve the functioning of its services, and therefore encourages and welcomes its use.
4. Whistleblower protection: Reporting, whether made by individuals outside or within the Organisation, is a practice that the Organisation encourages and welcomes, in the interests of improving the performance of its business activities; consequently, it shall not result in any adverse consequences for the whistleblower.
5. False reports: A false report shall be understood to mean: (1) one that is not based on facts or evidence from which an irregularity or improper conduct can reasonably be inferred; (2) one made even where the person making the report is aware that the facts are false and/or deliberately misrepresents them. Should the investigation reveal that a report has been made in bad faith on the basis of false or distorted information, it will be ascertained whether there is an employment relationship with the whistleblower so that, where appropriate, the matter may be referred to the Director or Head of Human Resources for them to take such disciplinary action as they deem fit.

6. RECEIPT OF COMMUNICATIONS

Reports to the Ethics Hotline or complaints can be submitted via various channels:

1. Email: [email protected]
2. Web: marbella-ev.com
3. Phone number: 952868406
4. Postal address: 5 Príncipe Alfonso de Hohenlohe Boulevard, CC Poveda, 29602, Marbella (Málaga)

For the attention of SEMADAR BEN DOR BALTER

7. COMPLAINT MANAGEMENT SYSTEM

This includes the IT tools provided by MAZAL REALTY S.L. to record and archive communications received and the documentation generated during its

processing procedure.

MAZAL REALTY S.L.’s Complaints Management System has the necessary technical and organisational security measures in place to ensure the highest possible level of confidentiality. Information containing sensitive personal data will be processed with the appropriate security measures in accordance with the provisions of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons (hereinafter, the GDPR).

The Head of the Internal Reporting System shall maintain an up-to-date list of persons authorised to access the information contained in the Whistleblowing Portal, specifying the actions they are permitted to carry out, if deemed appropriate. Access to the data contained in documents processed through the whistleblowing channel shall be restricted exclusively to staff carrying out compliance functions, internal audit of the Organisation and, where applicable, external audit.

8. PROCESS FOR HANDLING RECEIVED COMMUNICATIONS

The processing of incoming communications must be carried out in accordance with the following stages:

1. Receipt of the communication.
2. Preliminary analysis of its content.
3. Acceptance for processing.
4. Registration.
5. Acknowledgement of receipt.
6. Transfer or delegation.
7. Investigation or verification of the facts.
8. Decision and proposed course of action.
9. Notification of the decision to those concerned.
10. Closure of the case and preparation of reports for submission to the governing bodies.

• Receipt of the communication.

Reports submitted via the Ethics Channel may be received through the various channels of access to the Channel set out in section 6 of this procedure.

Once a report has been received, the person responsible for the internal management of the whistleblowing channel will forward it to the person responsible for the Internal Reporting System, who will act in accordance with its content as follows:

• If the content of the communication is an enquiry, the Head of the Internal Reporting System will respond to the questions raised as soon as possible, via the same channel through which the enquiry was received;
• If the content of the communication suggests that a breach may have occurred or may occur, such communication will be treated as a complaint and will be subject to preliminary analysis in order to determine whether it should be accepted and registered or rejected.

• Preliminary analysis of its content.

Any report concerning a possible breach (i.e. a complaint) must be subject to a preliminary assessment by the Head of the Internal Reporting System to decide whether to accept and register it or to reject it.

The Head of the Internal Reporting System shall document the reasons for accepting and registering, or for rejecting, a report concerning a possible breach, using a form which may contain, as appropriate, the following information:

• A descriptive title for the complaint, including its unique reference number and date of receipt.
• A summary of the information provided in the complaint, distinguishing between objective and subjective details.
• An analysis of the information and documentation submitted with the complaint.
• Assessment of the content of the complaint and the reliability of the complainant. The anonymity of the complainant shall, in principle, be treated as an indication of reduced credibility of the facts reported.
• Decision on whether to accept the report for processing, stating, where appropriate, the steps to be taken.
• Exceptional measures adopted, in the event that the Head of the Internal Reporting System has deemed them necessary or appropriate on grounds of urgency.
• Appointment of the investigating officer, should the Head of the Internal Reporting System deem it appropriate to delegate this function.

This preliminary assessment will determine whether it is appropriate to forward information to other departments within the organisation that does not fall within the scope of this channel or that requires a separate, specific procedure, where applicable.

If the communication concerns the actions of a Partner of our organisation, it will be investigated in collaboration with the department responsible for liaising with that Partner and, where appropriate, forwarded to the person in charge of the Internal Reporting System who performs similar duties within that organisation.

In the case of reports highlighting a malfunction within a Department or Area of the Organisation or a breach of commitments to clients, the established channels for handling such complaints or claims will be used, and the informant will be informed that the matter has been referred.

A decision will also be made as to whether the investigation should be combined with other similar procedures already underway.

• Acceptance for consideration.

In order to be accepted for processing, complaints must include:

• The facts or conduct to which the report relates, and their impact on the Organisation, the whistleblower, colleagues, business partners or third parties.
• The supporting evidence or proof available (documents, witnesses, etc.).

The fact that the whistleblower has not been identified shall not be sufficient grounds for dismissing a complaint.

In the event that the report is anonymous, the person responsible for the internal reporting system shall, in accordance with due diligence, assess whether to investigate the facts or to reject the report without further action. To this end, they must evaluate the apparent veracity of the complaint and the information or evidence provided. In any event, they must document their decision in writing.

No complaint shall be processed where it is manifest that the conduct in question does not constitute behaviour that could imply the commission of any irregularity or any act contrary to the law or the standards of conduct set out in the Code of Ethics.

• Registration.

Las denuncias admitidas a trámite se registrarán en un libro registro con un número de referencia único a efectos de que sea fácilmente localizable, cumplimentando un formato normalizado de registro.

• Confirmation of receipt.

Once the preliminary assessment of the report has been carried out, if the whistleblower is correctly identified in the report, the person responsible for the internal reporting system will acknowledge receipt, providing information as follows: Regardless of how the report is categorised by the person responsible for the internal reporting system, an acknowledgement of receipt will be sent to the whistleblower within a maximum of 7 calendar days of receipt.

If the report is deemed irrelevant, inadmissible or unrelated to the purposes of this Procedure, the informant will be sent a notification to that effect.

The informant must also be informed of the referral to other channels designated for the handling of commercial or other complaints or claims.

If the whistleblower chooses to make an anonymous report without providing a contact email address, upon completion of the reporting process they will receive a pop-up window confirming receipt of the report, in which a reference number will be assigned so that they can obtain information about it in future communications.

Please note that if the whistleblower does not provide a contact email address – which does not necessarily have to identify them – they will not be able to receive communications from our organisation regarding the status of their report or other updates; however, please do not worry, as we will respond within the legally established timeframe, and you will be able to access updates on your complaint by visiting the link dabocanaldenuncia.com/MAZALREALTY using the same username and password with which you submitted your complaint, and including the complaint’s reference number.

Where a report is deemed relevant but its content is insufficient, incomplete, or does not provide the necessary details to enable the investigation to begin, a notification will be sent informing the whistleblower that the report has been accepted and requesting the necessary additional information.

Where the complaint is valid and the information or documentation provided is sufficient to initiate the relevant investigation, a notification will be sent informing the complainant that the relevant investigation has commenced.

MAZAL REALTY S.L. must at all times guarantee the confidentiality of the whistleblower and ensure there is no retaliation for reports made in good faith. Consequently, the identity of the whistleblower or any circumstances that might make them identifiable to the accused shall be excluded from the information provided to the accused in the exercise of their right of access.

The deadline for acknowledging receipt of reports submitted by whistleblowers must not exceed seven calendar days.

However, where there is a significant risk that such notification could jeopardise the effective investigation of the facts forming the subject of the report or the collection and analysis of the necessary evidence, the person responsible for the internal reporting system may include a written justification in the file to waive this notification requirement.

• Transfer or delegation.

The person responsible for the internal reporting system may delegate all or part of the investigation process or request the support of specialists from the relevant departments or subsidiary companies to assist with the investigation of any complaints received.

These investigators must maintain confidentiality and professional secrecy throughout their involvement and must at all times adhere to the principles of this procedure.

If a complaint received via the Ethics Channel falls within the remit of the Confidential Advisory Service on sexual harassment, the person responsible for the internal reporting system shall forward it to the said Confidential Advisory Service for processing. The Confidential Advisory Service shall inform the Head of the Internal Reporting System of the closure of its proceedings so that the latter may include them in their reports to the governing bodies.

If, at any stage of the process, it comes to light that

judicial or administrative proceedings are underway in relation to the same facts, the person responsible for the internal reporting system may decide to suspend the proceedings under the Ethics Channel and resume them if there are relevant issues that have not been resolved in those proceedings.

• Investigation or verification of the facts.

The person responsible for the internal reporting system must inform the person against whom the complaint has been made of the content of the complaint, giving them the opportunity to explain and substantiate their position regarding its content.

The investigation shall be conducted by the person responsible for the internal reporting system or the person or persons designated by them for this purpose, depending on the type of complaint and the checks deemed necessary. During the course of the investigation, the following actions may be taken:

1. Request for clarification/further information: where necessary, the person who made the report will be asked to clarify or provide further details, supplying any documents and/or information they may have to substantiate the existence of the irregular act or conduct.
2. Verification of the truthfulness and accuracy of the report in relation to the conduct described, whilst respecting the rights of those involved. All Members of the Organisation are obliged to cooperate fully during the verification process. The statements of witnesses and those involved will be treated as strictly confidential. Notes or reports may be requested from the relevant Departments or Divisions.
3. Interview with the accused: whilst respecting their rights, they will be informed of the content of the complaint so that they may give their account of events and provide any evidence they may have. Similarly, private interviews will be held with all persons who may be involved. In all cases, a written record of these interviews will be drawn up, which must be signed by those present at the end of the meetings. Depending on the nature of the facts under investigation, interviews may be conducted in the presence of a witness (a line manager, a colleague or another person deemed appropriate). In this case, the witness must also sign the minutes of the meetings. Expert reports from internal or external professionals. Access to documents relating to the reported incident, including the accused’s corporate emails, in accordance with the established rules.
4. Any other actions deemed necessary during the proceedings.

The person responsible for the internal reporting system or, where applicable, the investigator, must keep a written record of all sessions held during the investigation and all interviews conducted in the course of the investigation.

In the case of formal meetings, a summary note must be signed at the end of each meeting, with the agreement, where possible, of all those present.

• Conclusion and proposed course of action

Once the preliminary investigation has been completed, the person in charge of the internal reporting system shall draw up a report and a conclusion or decision. If an investigator has been involved, they shall submit a signed report setting out their proposed decision, which must also be ratified by the signature of the person in charge of the internal reporting system. The written decision must contain, at a minimum, the following details:

1. Description of the reported case.
2. Actions taken during the investigation of the case, as well as any relevant documentation reviewed that may constitute evidence to support the conclusions.
3. Findings of the investigation. Assessment or evaluation of the established facts.
4. Proposal, where appropriate, of corrective measures, addressed to those with the authority to decide on and implement them.

The procedure must be completed as soon as possible, within a maximum of three months from receipt of the report or, if no acknowledgement of receipt was sent to the whistleblower, within three months from the expiry of the seven-day period following the submission of the report, except in particularly complex cases requiring an extension of the deadline, in which case it may be extended by a maximum of a further three months.

If the decision concludes that a Member of the Organisation has committed a breach, corrective measures shall be applied and, where appropriate, the matter shall be referred to the Director or Head of the Human Resources Department for the application of the relevant disciplinary measures or, where appropriate, to the Director of the Legal Department.

If the matter involves a business partner supplying goods, services and/or supplies, the person responsible for the internal reporting system shall notify the department or division that entered into the contract or that is responsible for fulfilling its obligations.

Irrespective of the above measures, if the verified actions relate

to administrative or judicial proceedings, whether or not the Organisation is a party to them, the Legal Department, if any, and the competent authorities shall be informed immediately.

Where the content of the complaint or the investigation thereof reveals the possible existence of relevant criminal liabilities that may affect the Organisation, the person responsible for the internal reporting system must immediately inform the entity’s governing body, which shall be responsible for taking the relevant decisions regarding the complaint once it has received an adequate report on its content.

In the event that it is established that a complaint has been lodged in bad faith on the basis of false or distorted information provided by an employee, this shall be brought to the attention of the Director or Head of Human Resources so that they may, where appropriate, take the disciplinary measures they deem fit.

• Notification of the decision to those concerned

The person responsible for the internal reporting system shall notify the whistleblower and the person against whom the complaint was made in writing of the conclusion of the investigation and its findings, stating whether or not there has been a breach of the Organisation’s applicable regulations and, in particular, of its Code of Ethics.

• Closure of the file and preparation of the register

In any event, a register containing no personal data will be created from the communications received, their assessment and the decisions taken, in order to carry out the relevant investigations and reports, and to take steps to rectify the situation where appropriate.

9. PROTECTION OF PERSONAL DATA

PRIVACY POLICY FOR THE ETHICS OR WHISTLEBLOWING CHANNEL

1. Purpose
   • The purpose of this section of the Ethics Channel or complaints procedure is to inform reporters of how their data will be processed for the management and handling of complaints submitted via the channel. To this end, the Ethics Channel’s privacy policy is also set out on the corporate website.
   • To ensure the proper configuration and design of the Ethics Channel, the Organisation fully complies with the applicable data protection regulations; in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and its implementing regulations.
   • Similarly, the Ethics Channel has been designed in accordance with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.
2. Processing of your personal data and legal basis
   • The purpose of the Ethics or Whistleblowing Channel is to manage reports received regarding breaches of the regulations applicable to MAZAL REALTY S.L. committed by members of the organisation or business partners, to investigate the reported incidents, and to take the appropriate corrective measures.
   • This is a confidential communication channel between members of the organisation, business partners and third parties associated with the organisation.
   • The information contained in the Channel will be deleted three months after the case has been resolved and will be removed once the legal time limits during which administrative or judicial proceedings may be brought against the legal entity have elapsed; in any event, not before 10 years have passed if the report relates to money laundering or terrorist financing.
   • Legitimacy is established by consent, which has been given and obtained through the Ethics Channel.
3. Recipients of the data
   • Access to the information provided by the data subject will be restricted to the person responsible for the internal information system at MAZAL REALTY S.L., as well as to staff authorised by that person (except where a request is made regarding commercial transactions in which the relevant departments or areas are required to be involved)
   • Data will not be disclosed to third parties, except where legally required, in which case the information will be made available to public authorities, judges and courts for the purpose of addressing any potential liabilities.
4. Exercising one’s rights
   • Data subjects may at any time exercise their rights of access, objection, rectification and erasure in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council and Organic Law 3/2018 of 5 December.
   • In certain circumstances, data subjects may request the restriction of the processing of their data, in which case the Ethical Channel will retain such data solely for the purpose of exercising or defending claims.
   • Where technically possible, the data subject may request the portability of their data to another data controller.
   • To exercise these rights, in accordance with current legislation, data subjects may use the email address [email protected], attaching a copy of a valid identification document (ID card or passport) and expressly stating the right they are requesting.
   • The data subject may lodge a complaint with the Spanish Data Protection Agency, particularly if they are not satisfied with the exercise of their rights; for further details, please visit the website https://www.aepd.es.
5. The principle of proportionality and data minimisation
   • Personal data collected through the Ethics Channel: Its use will be limited to what is strictly and objectively necessary to process complaints and, where appropriate, to verify the facts reported; It will be processed at all times in accordance with applicable data protection regulations, for legitimate and specific purposes relating to any investigation that may arise as a result of the complaint; It will not be used for incompatible purposes; It shall be adequate and not excessive in relation to the aforementioned purposes.
6. Restrictions on access to data
   • Access to the data contained in these systems shall be restricted exclusively to the bodies responsible for carrying out compliance functions, the organisation’s internal audit functions and, where applicable, external audit functions. Only where disciplinary measures may be taken against a Member of the Organisation shall the processing of data be permitted for staff with human resources management and control functions. Furthermore, as indicated, the Organisation may engage the services of external professionals to provide certain services relating to the management of the Ethics Channel.
7. Security and confidentiality measures
   • The Organisation shall ensure that all necessary technical and organisational measures are taken to safeguard the security of the data recorded, in order to protect it from unauthorised disclosure or access. To this end, the Organisation has adopted appropriate measures to guarantee the confidentiality of all information and will ensure that data relating to the identity of the whistleblower is not disclosed to the accused during the investigation, whilst respecting the fundamental rights of the individual in all cases, without prejudice to any actions that may be taken by the competent judicial authorities.

10. COMPLIANCE FUNCTION COMMITMENTS

The person responsible for the internal reporting system, as well as, in support of them, any persons acting on their behalf, and any person involved in the management and processing of the Ethics Channel or in the handling of reports, must carry out their work with the utmost diligence and confidentiality, refraining from disclosing any information, data or background details to which they have access in the course of their duties, and from using such information for their own benefit or that of a third party.

The person responsible for the internal reporting system and any person involved in the management of the Ethics Channel must refrain from acting if a conflict of interest arises due to the persons affected by the report or the matter in question; they must notify the entity’s governing body and the case must be assigned to a qualified person who is not subject to such a conflict.

11. RELATIONSHIP WITH OTHER APPLICABLE PROCEDURES

This Ethics Channel must not interfere with the procedures of the Confidential Advisory Service responsible for handling cases of harassment and/or sexual violence, which will continue to be governed by its own specific regulations.

12. STATEMENT OF COMPLIANCE

As compliance with ethical rules and standards is a commitment for the entire Organisation and constitutes a strategic objective for it, all staff are expected to be familiar with and adhere to the contents of this Procedure.

MAZAL REALTY S.L. will take immediate action in the event of any breach of the provisions of this Procedure, in accordance with its internal regulations and within the parameters set out in current legislation.

13. APPROVAL, ENTRY INTO FORCE AND UPDATING

This Canal Ético procedure was approved by the board of directors at its meeting on 13 April 2026.

It is now fully in force in its entirety.

This Canal Ético procedure must be kept up to date. To this end, it must be reviewed on a regular basis annually, and on an ad hoc basis whenever there are changes to the strategic objectives or applicable legislation.

It is the responsibility of the Head of the Internal Reporting System to assess any proposed amendments.

CHANGE CONTROL

Version 1.0 approved by the Management Board